North American Numbering Council
c/o Columbia Institute for Tele-Information
Columbia Business School
1A Uris Hall
3022 Broadway
New York, NY 10027-6902
February 15, 2005
Mr. Jeffrey Carlisle
Chief, Wireline Competition Bureau
Federal Communications Commission
445 Twelfth Street, S.W.
Washington, D.C. 20554
Re: Recommendation for Process Flow Change Based on INC Issue 407
(CC Docket No. 99-200)
Dear Mr. Carlisle:
The purpose of this letter is to recommend that the Commission take whatever steps are
necessary so that the process for assigning a central office code in a specific circumstance
can be modified. The proposed process modification is supported by the North American
Numbering Council (NANC), the Industry Numbering Committee (INC) and the North
American Numbering Plan Administrator (NANPA).
At the May 2004 meeting of the NANC, the INC requested input from NANC concerning
the existing process flow used by service providers to request dedicated central office
codes for a single customer in pooling rate centers. Specifically, the INC recommended
a process change so that requests by service providers for dedicated codes to be assigned
to a single customer in mandatory pooling rate centers could be processed directly
through NANPA rather than through the Pooling Administrator (PA). The INC explained
that this specific process change would be more efficient and expedient to both service
providers and to the single customer receiving the dedicated code. However, due to
wording in the Fourth Report & Order in CC Docket 99-200 (NRO IV), the INC cannot
adopt the process change without regulatory approval. Paragraph 14 in NRO IV states:
“In addition, we direct the NANPA to cease assignment of NXX codes to carriers
after they are required to participate in pooling. Carriers required to participate in
pooling must request and receive numbering resources from the national Pooling
Administrator (PA).”
INC Issue 407 under which the process change was discussed is attached (Attachment 1).
It is currently in Initial Closure at INC and will not become Final until regulatory
direction is received from either NANC or the FCC.
1
At the May 2004 NANC meeting, an Issue Management Group (IMG) was established to
examine potential impacts on consumers, service providers, and, in general, on local
number portability, if the INC recommendation was adopted. The IMG was composed of
NANC members representing a cross-section of the industry and included representatives
from state regulatory commissions.
At the September 2004 NANC meeting, the IMG presented to NANC its findings on the
INC’s recommendation. The IMG concluded that there were no negative impacts to the
consumer, no porting impacts, and that the PA’s role in the processing of a request for a
dedicated code for a single customer is essentially a “pass-through” role only. The IMG
also noted that all requests for a full NXX code assignment must be processed by
NANPA Code Administration using the code assignment criteria established in the INC’s
guidelines regardless of whether the full code request is submitted directly to NANPA or
is submitted through the PA. The IMG’s report and recommendation is attached
(Attachment 2). In summary, the IMG reported that its findings were consistent with the
findings of the INC and the IMG supported the INC recommendation.
Also, the NANPA has reviewed the INC Issue 407 and has determined that the issue does
not affect the NANP Administration System (NAS). NANPA noted that the
implementation of the recommended process change does impact NANPA operations but
can be implemented by NANPA at no additional cost. The complete analysis by NANPA
on INC Issue 407 is documented in NANPA Change Order #4 which is attached.
Based on the discussion at the INC, feedback from the IMG and the impact on NANPA,
NANC endorses the recommended process change that would allow a service provider
the option of submitting requests for a dedicated code for a single customer directly to
NANPA.
NANC requests that the FCC adopt the INC’s recommended process flow change and
take the steps necessary to implement the change as quickly as possible.
Please contact me if you have any questions about NANC’s recommendation.
Sincerely,
/Signed/
Robert C. Atkinson
NANC Chair
Attachment
cc:
NANC Members
Lisa Gelb, FCC
Narda Jones, FCC
Cheryl Callahan, FCC
Sanford Williams, FCC
2
ATTACHMENT 1 to NANC Letter
INDUSTRY NUMBERING COMMITTEE (INC) ISSUE IDENTIFICATION FORM
Treatment of Dedicated Codes for Single Customers in a Pooling
Environment
________________________________________________________________
____
ISSUE ORIGINATOR: Bill Shaughnessy
COMPANY: BellSouth
TELEPHONE #: 404-927-1364
REQUESTED RESOLUTION DATE:
LNPA
ISSUE #: 407
DATE SUBMITTED: 3/4/03
DATE ACCEPTED: 3/4/03
SUBCOMMITTEE ASSIGNED:
CURRENT STATUS: Initial
Pending
RESOLUTION DATE:
1.
ISSUE STATEMENT:
The CO/NXX Assignment Guidelines defines a single customer as one
customer requiring 10,000 consecutive telephone numbers from one central
office exchange.
Based on the existing Thousands Block Number (NXX-X) Pooling
Administration Assignment Guidelines, when a service provider needs a
dedicated code in a pooling rate center to satisfy the needs of a single
customer, the service provider submits the request for full NXX to the PA
who subsequently submits the request to the CO Code Administrator.
Upon receipt of the NXX code assignment from the CO Code Administrator,
the PA builds the BCD record for thousands-block(s). Service providers in
this instance will be billed for 11 records, the "A" record and the 0 through 9
block records in BIRRDS even though this NXX will not be pooled since it is
dedicated to a single customer.
2.
SUGGESTED RESOLUTION OR OUTPUT/SERVICE DESIRED:
BellSouth proposes that the Thousand Block Number (NXX-X) Pooling
Administration guidelines be modified to show that when a service provider
request a dedicated NXX for a single customer in a pooling rate center that
the dedicated NXX assigned to the customer is not marked as a “pooled”
code in BIRRDS. The customer will use all the numbers in the NXX and
none of the thousands-blocks will be donated to the Pool, so the code
should not be marked as a “pooled” code in BIRRDS. In addition, the
Guidelines should be revised regarding the submission of the Part 4 for a
dedicated NXX code in a pooling environment. The Service Provider who is
assigned the dedicated NXX code should be allowed to submit the Part 4
Form to NANPA directly through the Code Administration System (CAS)
3
since the Service Provider is notified of the code assignment via CAS and
the code will not be a pooled code.
3.
OTHER IMPACTS:
The CO/NXX Code Assignment Guidelines may need to be changed.
4.
CONTRIBUTIONS WORKED AGAINST ISSUE:
 LNPA-454
 LNPA-469
 LNPA-476
 LNPA-478
 LNPA-491
5.
CURRENT ACTIVITY:
INC 69: Issue accepted but not discussed.
INC 70: Discussed LNPA-454, and made some initial modifications to the
contribution. Participants will return to their companies and ensure that all of the
changes made as a result of LNPA-454 are correct and incorporate all the changes
that are necessary. The issue remains in Active status.
INC 71: The issue not discussed.
INC 72: The issue not discussed.
INC 73: The issue was discussed at the LNPA Workshop, along with new
contribution, LNPA-469, Proposed Changes to the LNPA Guidelines Based on
Issue 407 (BellSouth). INC agreed to accept the underlying concept of Issue 407
(and LNPA-469) and continue moving forward with its work on the issue. BellSouth
agreed to bring in a new contribution which will summarize specific text changes to
address the proposed process flow changes contained in Issue 407.
INC 74: The issue was discussed in the LNPA Workshop, along with new
contribution LNPA-476: Additional Proposed Changes to the LNPA Guidelines
Based on Issue 407. It was agreed to incorporate the text changes of LNPA-476
into the TBPAG Working Document. BellSouth agreed to bring a contribution to
INC 75 to address associated changes in the COCAG.
INC 75: Contribution LNPA-478 (Proposed Changes to the Sections: 3.1, 4.1,
4.1.4.1, 4.3.2, 5.2, & Glossary of CO/NXX Guidelines to Address Issues 407 –
Treatment of Dedicated for A Single Customer in a Pooling Environment) was
discussed. It was noted that INC should only incorporate the proposed text
changes in LNPA-478 which are not already covered by LNPA-481. Participants
made adjustments to the text of the contribution in the following sections of the
COCAG Working Document: 4.1.4.1-3; 5.2; and 8.2.2 and the following sections
of the TBPAG Working Document: 3.2; 4.2.1.h); 6.1.2; 7.4.4.; 7.5.3. It was noted
that the issue’s Resolution Statement should contain some indication of INC’s
awareness of potential FCC-NANC policy implications involved in the closure of
this issue. With this issue, INC agreed to follow the section of the new ATIS
Operating Procedures which states that an issue may be placed in Initial Closure
and then subsequently placed in the Initial Pending category after 21 days, since
4
the output of a regulatory body is at issue. The issue was placed in Initial Closure
(to be placed in Initial Pending on 4/30/04).
Friday, 4/30/04: Since no objections to the closure of this issue had been received
by this date, the issue is now placed in the Initial Pending category (since there are
FCC-NANC policy implications involved in the closure of this issue).
INC 78: INC agreed to add text to the resolution statement’s guidelines changes
which indicates that a customer letter will be required for the single customer
dedicated code request. INC then placed the issue in Initial Closure, with the
agreement that the issue will automatically be placed in Initial Pending 30 days
after the issue form is posted.
11/12/04: The issue was placed in Initial Pending.
6.
RESOLUTION:
The following text changes were made the TBPAG:
Sections 3.2:
A pooling SP’s requirement for an entire NXX Code (i.e., 10,000 TNs) to satisfy the
numbering needs for a single customer may at the SP’s discretion be obtained either
from the CO Code Administrator or from the PA (see Section 7.5.3). In either case, a
customer letter is required as supporting documentation and provided to the appropriate
administrator. An entire NXX code dedicated for a single customer’s use may be
classified as a non-pooled code at the discretion of the SP. When an SP submits a
request for a dedicated code for a single customer’s use and wants the code to be
marked as non-pooled, the request shall go through NANPA. (Issue 407) The SP will be
considered the CO Code Holder by leaving the pooling indicator field blank in Section
1.5 of the CO Code Part 1. In addition, the SP should write “Non-pooled code for
dedicated customer” in Section 1.7 of the Part 1.
Section 3.2 (last paragraph):
When an SP submits a request for a dedicated code for a single customer’s use and
wants the code to be marked as non-pooled, the request shall go through NANPA.
Section 4.1 (last paragraph):
An entire NXX code dedicated for a single customer’s use may be classified as a nonpooled code at the discretion of the SP. The SP will be considered the CO Code Holder
by leaving the pooling indicator field blank in Section 1.5 of the CO Code Part 1. In
addition, the SP should write “Non-pooled code for dedicated customer” in Section 1.7 of
the Part 1. The CO Code Holder for a code dedicated for a single customer’s use will
become a LERG Assignee when blocks from this code are donated to the Pool.
Section 4.2.1 h):
5
h) be responsible for providing to the PA the CO Code Part 4 that confirms a full NXX
that was obtained to meet an SP’s single customer request has been placed in service if
the dedicated code is obtained from the PA.
Section 6.1.2:
6.1.2
If SPs identify a significant change in their thousands-block forecast for a rate
area, they should provide an updated Thousands-Block Forecast Report
(Appendix 1) for that rate area as soon as possible to the PA. At the SP’s
discretion, the updated forecast should also identify an SP’s need for an entire
NXX code(s) (identified in thousands-blocks) to satisfy the need of a single
customer. This updated forecast will completely replace the previous thousandsblock forecast for a given rate area.
Section 7.4.4:
Step 3 - The LERG Assignee, designated in Step 2, is responsible for completing the
Central Office Code (NXX) Assignment Request - Part 1 form and submitting it to the
PA. The PA will then forward that Part 1 to the CO Code Administrator. The LERG
Assignee is also responsible for submitting the Thousands-Block Application Forms –
Part 1A to the PA for the thousands-block(s) retained. If the SP is retaining multiple
blocks and the routing information is different for those blocks, then a Part 1B must be
submitted.
Where the LERG Assignee has requested a dedicated NXX Code through the PA to
meet a specific customer request, the LERG Assignee is responsible for completing the
Thousands-Block Months to Exhaust and Utilization Certification Worksheet - TN Level
(Appendix 3) and submitting it to the PA. In this instance, the LERG Assignee should not
be required to submit Thousands-Blocks Forms Part 1A or Part 1B.
Section 7.5.2:
The PA, when applying to the CO Code Administrator for an NXX Code to a) satisfy the
needs of an SP’s single customer requiring 10,000 consecutive TNs when the SP elects
to submit this request through the PA or b)…..
Section 7.5.3 (last paragraph):
The PA will forward the CO Code Part 4 form to the CO Code Administrator. The SP to
whom the NXX has been assigned is responsible for providing the CO Code Part 4
(Assignment Request and Confirmation of Code In Service) to the PA that confirms that
the NXX obtained to provide an LRN for the SP or to meet an SP’s single customer
request for a full NXX Code has been placed in service.
6
The following text changes were made to the COCAG:
Section 3.1:
CO codes (NXXs) are assigned to entities for use at a Switching Entity or Point of
Interconnection they own or control. Where thousands-block number pooling has been
implemented, an entity assigned a CO Code is designated as the “LERG Assignee.”
However, an entire NXX code dedicated for a single customer’s use may be classified as
a non-pooled code at the discretion of the SP. In either case, a customer letter is
required as supporting documentation and provided to the appropriate administrator. In
that event, the SP will be considered the CO Code Holder by leaving the pooling
indicator field blank in Section 1.5 of the CO Code Part 1. In addition, the SP should
write “Non-pooled code for dedicated customer” in Section 1.7 of the Part 1.
Section: 4.1:
CO codes (NXXs) are assigned to entities for use at a Switching Entity or Point of
Interconnection they own or control. Where thousands-block number pooling has been
implemented, an entity assigned a CO Code is designated as the “LERG Assignee”,
except for an entire NXX code that is dedicated for a single customer’s use and is
designated as a non-pooled code by the code assignee. In that exception case the SP
assigned the dedicated code will be considered the CO Code Holder. Assignment of the
initial code(s) will be to the extent required to terminate PSTN traffic as authorized or
permitted by the appropriate regulatory or governmental authorities, and provided all the
criteria in Sections 4.1.1 through 4.1.3 are met. An initial code assignment will be based
on a unique rate center consistent with regulatory restriction.
Section 4.1.4.1 3):
3) to request an entire NXX code (i.e., 10,000 numbers) to satisfy the numbering needs
for a service provider’s single customer when the SP requires that the code be
marked as pooled. A single customer is defined as one customer requiring 10,000
consecutive telephone numbers from one central office exchange.
Section 4.3.2:
The PA when applying to the CO Code Administrator for an NXX Code to a) satisfy the
needs of an SP’s single customer requiring 10,000 consecutive TNs when the SP
submits this code request to the PA, or b) be assigned for LRN purposes, will certify the
need by providing the CO Code Administrator a copy of the “Thousands-Block Number
Pooling Months To Exhaust Certification Worksheet - TN Level” [Thousands-Block
Number (NXX-X) Pooling Administration Guidelines, Appendix 3] that is supplied to the
PA by the requesting SP in accordance with the Thousands-Block Number (NXX)
Pooling Administration Guidelines which covers:
7
Section 5.2:
5.2
Receive and process applications (CO Code (NXX) Assignment Request Form
Part 1) for CO codes (NXX) within the geographic NPA(s) for which the CO Code
Administrator is responsible.
For rate centers transitioning to pooling:

The CO Code Administrator will only process NXX requests received at least 33
calendar days prior to the Pool Start Date.

Within the 33 calendar days prior to Pool Start Date, applications for
codes/blocks will not be accepted. However within this 33-day interval, the
NANPA will continue to process code applications for:
 CO codes awarded via lottery;
 LRN requests;
 full CO code request for a single customer;
 CO code expedite requests;
 petition/safety valve requests;
 any requests from non-pooling capable carriers; and
 PA requests to the NANPA.
After Pool Start Date, all pooling-capable carriers will apply to the PA for all codes or
blocks marked as pooled.
Section 8.2.2:
8.2.2
If a Part 4 has not been received by the Administrator during the first five months
following the original effective date returned on the Part 3 and entered on the
ACD screen in BIRRDS, then the Administrator will send, via facsimile/electronic
mail, a reminder notice to the code assignee. The notice will be sent no later
than one month prior to the end of the 6th month, and will direct the assignee to
do one of the following by the end of the sixth month after the original effective
date returned on the Part 3 and entered on the ACD screen in BIRRDS:


If the code is in a non-pooling NPA, submit a Part 4 to NANPA
If the code is in a pooling NPA, and the code was assigned prior to the
implementation of pooling in the NPA, submit the Part 4 to NANPA
 If the code is in a pooling NPA, and the code was assigned to a pooling carrier after
pooling was implemented in the NPA, submit the Part 4 to the PA.
 If the code is in a pooling NPA but is marked non-pooled, submit the Part 4 to
NANPA.
If the code is no longer needed or not in service, return the code by submitting a Part 1.
Updated: 10/22/04
8
ATTACHMENT 2 to NANC Letter
NANC IMG Analysis On INC Issue 407
NANC Action Item:
The IMG will review INC’s Issue 407 with respect to consumer impact, procedure and other
implications and recommend whether NANC should urge the FCC to initiate an NPRM to
implement the INC recommendation.
Relevant Cite:
Paragraph 14 in NRO IV (paragraph 14)
In addition, we direct the NANPA to cease assignment of NXX codes to carriers after they are
required to participate in pooling. Carriers required to participate in pooling must request and
receive numbering resources from the national Pooling Administrator (PA).
Findings:
1. Porting Impact: Many NANC members questioned whether INC issue 407 would have an
impact on porting. There are no porting impacts.. Regardless if the carrier makes the
dedicated code request to the PA or directly to NANPA Code Administration, the existing
service provider portability procedures or processes remain the same. The existing process
flows still apply if a service provider received a request to port a single TN or multiple TNs
from a NXX code dedicated to a single customer.
2. Customer Impact: Adherence to paragraph 14 in NRO IV could lead to a delay of up to 14
calendar days for a dedicated code to be obtained for an end customer. The INC resolution to
issue 407 would potentially speed up delivery time of a new code to the customer by
eliminating the up to 14 day interval that is required for the PA to be involved in the
processing of the code request (See attached document describing steps). There are no
negative impacts to the end customer. The code assignment process is transparent to the end
customer other than the time interval required to be assigned a code.
3. Service Provider Impact: The requirement to submit a request for a dedicated code for a
single customer in a pooling environment as required by paragraph 14 adds up to 14 calendar
days to an already lengthy process for obtaining a code. In addition, the exchange of forms
between the Service Provider (SP) and PA/NANPA would be significantly reduced if the
dedicated code request was made directly to NANPA and would also be significantly reduced
when modifications are made to the dedicated code. (See Table Below). The requirement to
submit the dedicated code request through the PA also prevents the usage of the NANP
Administration System (NAS) to electronically submit the Part 1 request to NANPA. The
PA’s role in the processing of a request for a dedicated code for a single customer is
essentially a “pass-through” role only. The IMG notes that all requests for a full NXX code
assignment must be processed by NANPA Code Administration using the assignment criteria
established in the INC’s guidelines regardless of whether the full code request is submitted
directly to NANPA or is submitted through the PA.
9
Summary of Required Forms
NEW CODE REQUESTS
NEW CODE W PA
1 Part 1B
1 MTE (SP) (if growth)
1 Part 1 (SP)
1 Part 3 (PA suspension to SP)
1 Part 3 (NANPA to SP and PA)
10 Part 3 (PA to SP for blocks)
1 Part 4 (SP)
1 Evidence of Certification (SP) (if initial)
1 Evidence of Facilities readiness (SP) (if
initial)
Total:
Up to 16 Forms & 11 BIRRDS Records if
code is growth and marked pooled;
Up to 17 Forms & 11 BIRRDS Records if
code is initial and marked pooled.
If code is marked as non-pooled, on form,
then only 1 BIRRDS record.
NEW CODE W/O PA
1 Part 1 (SP)
1 MTE (SP) (if growth)
1 Part 3 (NANPA)
1 Part 4 (SP)
1 Evidence of Certification (if initial)
1 Evidence of Facilities readiness (if initial)
Total
Up to 4 Forms & 1 BIRRDS Record if code is
growth;
Up to 5 Forms & 1 BIRRDS Record if code
is initial.
MODIFICATIONS REQUESTS
CODE MODIFICATION W PA
CODE MODIFICATION W/O PA
1 Part 1 (SP)
1 Part 1 (SP)
10 Part 1A (SP)
1 Part 3 (NANPA)
10 Part 1B (SP)
1 Part 3 (PA suspension to SP)
10 Part 3 (PA to SP for blocks)
1 Part 3 (NANPA to SP and PA)
Total:
33 Forms & 11 BIRRDS Record changes
Total
2 Forms & 1 BIRRDS Record change
10
State Regulatory Concerns:
1.
State commissions that currently review copies of Part 1 code requests for a dedicated
code may not have sufficient time to review the application due to the shortening of the
process interval. Some states stated the need for at least 10 business days to review the Part
1. Problems cited in reviewing the Part 1 for dedicated codes is that service providers do not
submit the Part 1 to the state commission or do not provide sufficient information to
determine that the dedicated code request is legitimate.
Analysis:
The IMG notes that a limited number of state commissions review Part 1
code requests while the PA and/or NANPA processes the dedicated code
request. The IMG also notes that the standard interval for NANPA to
process any NXX code request is 10 business days. If a state commission
that is reviewing a request for a dedicated code has not received sufficient
information from the service provider requesting the code, the state
commission can request the NANPA to suspend the request until sufficient
information is provided or until the state commission can review the Part 1
request.
Also, the INC has reached agreement that, if requested, they will draft appropriate guideline
modifications that might result from the NANC’s recommendation regarding this issue such
modifications that might result from the NANC/FCC decision on this issue. Such guideline
modifications could include adding a requirement that a service provider requesting a
dedicated code for a single customer must submit a letter from that customer documenting the
customer’s need for a dedicated NXX.
The IMG notes Issue 407 was not intended to address any concerns related to ensuring that
dedicated code requests are legitimate. Such concerns will exist regardless of whether the
code request is submitted through the PA or directly to NANPA. These concerns should be
addressed through appropriate guideline modifications to require additional supporting
documentation from the service provider in order for a dedicated code to be assigned.
2.
The definition of a “dedicated customer” code is not well defined in the guidelines.
Analysis:
Section 4.1.4.1.3 of the Central Office Code Assignment Guidelines addresses requests for an
entire NXX code (i.e., 10,000 numbers) to satisfy the numbering needs for a service
provider’s single customer. A single customer is defined as one customer requiring
10,000 consecutive telephone numbers from one central office exchange. A “single
customer” is the same as a “dedicated customer.”
Conclusion:
Based on the analysis above, this IMG recommends that, in mandatory pooling areas, a service
provider have the option to submit requests for a dedicated code for a single customer directly to
NANPA. This would allow for a more efficient and expedient assignment process and would
allow needed numbers to be provided to end customers up to 14 calendar days sooner. In
addition, this would have no impact on the porting of numbers from the dedicated code and
would have no negative impacts on end customers.
The findings in our independent review are consistent with the findings of the INC on this issue.
12
Even though the Pooling Administrator participated in the IMG, the Pooling Administrator takes
no position in the conclusion of the IMG’s recommendation. However, the Pooling
Administrator does not, at this time, anticipate any impact on their operations. In addition,
NANPA indicated that the IMG recommendation would have minimal, or no impact on their
processing of dedicated code requests. .
Open Issue:
If the IMG recommendation is approved, the IMG does not believe it is within their purview to
determine how the FCC should implement the change to paragraph 14 in NRO IV. The IMG
leaves that decision to the FCC.
13
STEPS FOR DEDICATED CODE ASSIGNMENT
1. DEDICATED CODE REQUEST SUBMITTED TO THE PA





A Service Provider (the code applicant) submits Part 1 Code Request and supporting
documentation to the Pooling Administrator (PA)
The PA receives the Code Request and forwards it to NANPA CO Code
Administration if the request meets the code assignment criteria. The PA has 7
calendar days from receipt of the request to process the request and provide a Part 3
PA’s Response Form to the code applicant
NANPA CO Code Administration has 14 calendar days from receipt of the dedicated
code request from the PA to review and process the request and issue the CO Code
Administrator’s Part 3 Response Form to both the PA and the code applicant
Within 7 calendar days of the receipt of the NXX code assignment from the CO Code
Administrator, the PA informs the code applicant of the NXX code and thousandblocks assigned using the PA’s Part 3 Response Form
The dedicated code assignment is made by NANPA CO Code Administration and the
PA is not directly involved with the assignment of the code
2. DEDICATED CODE REQUEST SUBMITTED TO NANPA CO CODE
ADMINISTRATION



A Service Provider (the code applicant) submits Part 1 Code Request and supporting
documentation to NANPA CO Code Administration
NANPA CO Code Administration has 14 calendar days from receipt of the dedicated
code request from the applicant to review and process the request and issue the CO
Code Administrator’s Part 3 Response Form to the code applicant
NANPA CO Code Administration uses the code assignment criteria documented in
the Central Office Code Assignment Guidelines to determine whether the dedicated
code should be assigned regardless of whether the code request came through the PA
or was submitted directly to CO Code Administration