Customer Service Standards
Washington Association of Telecommunications Officers and Advisors
Spring Conference – Chelan, WA
May 1-2, 2014
Brian T. Grogan, Esq.
612-877-5340
brian.grogan@lawmoss.com
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Customer Service
Many jurisdictions have adopted the FCC’s
customer service obligations (47 C.F.R. § 76.309)
Two main issues:
1. Telephone Response Time
2. Installations and Service Calls
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Customer Service
1. Telephone Response Time
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24/7 customer service
Answer time within 30 secs (90%)
•
–
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Under “Normal Operating Conditions (NOC)”
Busy signal less than 3%
Call received by automated response unit (ARU)
•
Or live human being
2. Installations and Service Calls
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Within 7 days of request
4 hour time block (during Normal Business Hours)
Within 24 hours of interruption
Begin corrections next business day
3
Regional Call Centers
• Combining customer service operations to
serve 100,000+ subscribers
– Has resulted in loss of local presence/office
• Many call centers handle multiple services
– Cable Service
– High-speed data (cable modem)
– Local telephony
4
Call Center Performance
• Some centers struggle handling voice, video
and data service calls
– Historical difficulty meeting 90% compliance
• Industry has history of blaming poor telephone
responsiveness on:
– Voice and data service calls
• Rollout of new services
• Time consuming calls
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Service Level Performance
•
TSL - Telephone Service Level TSL: HWSL / NCH
– Calls answered in 30 seconds
– NCO - Number of calls offered to the call center
– NCH - Number of calls handled by the call
center
– HWSL - Number of calls handled within service
level by call center
– ASA - Average Speed of answer for all calls
•
Should be less than 30 seconds
– % ATB - percentage all trunks busy > 3%
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Month
NCO
NCH
HWSL
TSL
ASA
%ATB
2011-4
15795
15684
14769
94.2%
11.64
0%
2011-5
11867
11812
11332
95.9%
9.55
0.1%
2011-6
9203
9151
8659
94.6%
13.23
0.0%
36865
36647
34760
94.9%
11.30
0%
Q2-QTD
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Normal Operating Conditions
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•
Defined by FCC
Within the control of operator
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•
Not within the control of operator
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–
–
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Upgrades
Rate increases
Peak demand
Power outages
Weather
Telephone network outages
Operators often argue that their call centers are not
under NOC
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Normal Operating Conditions
Example: Your system is served by regional call
center covering entire state
–
–
Storm 100 miles away results in heavy call volume
Subscribers in your City can’t get through on
telephone
– Is operator relieved of compliance because it was
not under NOC in part of their region?
Between line cuts, weather, telephone & power outages will
call center ever be under NOC?
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Normal Operating Conditions
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•
The larger the call center the bigger the problem
How can cities verify compliance with customer
service standards?
– Will objective local data be available?
– If no local data will operator rely on regional data?
•
Scrubbed data v. raw data
– Scrubbed data excludes time when operator is not
under NOC
– How is this calculated?
– Does your franchise permit access to data?
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City of Savage Case
•
City of Savage v. Triax Midwest Associates, L.P.
– unpublished MN Court of Appeals decision 9/29/98
•
City adopted FCC’s Customer Service Standards
(CSS)
– By providing Triax 90 days written notice
•
•
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City also had CSS in Franchise Agreement
City requested info to verify compliance
Triax failed / refused to provide info
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City of Savage Case
•
City found Triax in violation of franchise for its
failure to:
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open customer service center during normal
business hours
provide monthly compliant log
answer phones within 30 seconds
ensure busy signal less than 3% under normal
operating conditions
provide 4 hour appointment window for installations
and service calls
provide written information to subscribers
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City of Savage Case
•
•
Triax challenged to MN Court of Appeals
Court found City’s record
– Contained substantial evidence supporting noncompliance
•
Record consisting of numerous subscriber
complaints
– Found to be sufficient despite lack of telephone
records which Triax never produced
•
After decision Triax settled with City
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City of Savage – Part II
•
City found new operator in violation of franchise on
October 15, 2001
– Failure to provide quarterly telephone answering
reports “specific to the system serving the city.”
•
In early 2002, City drew $26,250 from security fund
under franchise
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City of Savage – Part II
•
•
Parties entered into Settlement Agreement in
October 2002.
Operator agreed to the following:
1. Special 800 # for customer service inquiries
exclusively for Savage residents
2. Separate and dedicated trunk capacity to handle
traffic on 800 Savage line
3. Separate 4 person staff of CSRs assigned
exclusively to handle incoming calls from Savage
residents
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City of Savage – Part II
4. Designed customized software to track Savage only
call information
5. Deploy roll-over lines for 24/7 live CSR assistance
6. Savage specific report format (14 days from end of
quarter)
•
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Daily ACD report printouts
Providing half hour by half hour call data
7. Financial settlement addressing City’s costs
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Future??
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Are the FCC standards obsolete?
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Email inquiries
iPad applications
On-line bill handling
Self install kits
Local office
– Will there be local offices in the next few years?
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Without local regulation
– Will industry be governed by competition, or
– Will cities have single provider and limited service
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Thank You
Brian T. Grogan, Esq.
Moss & Barnett, A Professional Association
4800 Wells Fargo Center, 90 South Seventh Street
Minneapolis, MN 55402-4129
(612) 877-5340 phone / (612) 877-5999 facsimile
E-mail: brian.grogan@lawmoss.com
Web site: www.lawmoss.com
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