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September 17, 1998

Separate Statement
Commissioner Susan Ness

Re: Truth-in-Billing and Billing Format

Change can be confusing for consumers, and there is a lot of change underway in the communications industry. Choice can be confusing for consumers, and for most communications services there is a wide array of choices to be made among providers -- and even among offerings from a single provider.

I don't think it's the FCC's job to eliminate all confusion, but we can and should try to eliminate unnecessary confusion.

Today, consumer bills for communications services are complicated. We can't change that. But there is a legitimate governmental concern when bills are unintelligible or misleading or both, especially when those features make it easier for carriers or other service providers to extract more money from consumers' pockets than they could if the market was fully competitive and consumers were not being confused or misled.

I do not believe it necessary for the government to require -- or to forbid -- specific line items on consumers' bills. My main concern is with the bottom line, and I am happy that the Commission has managed to maintain and expand universal service, increase economic efficiency in the structure of access charges, and lower overall costs for interstate carriers.

As a result of our decisions, most consumers are getting more, and paying less.

But some consumers, though they are in fact better off, may not feel better off. This is partly because of the inadequate explanations they have received for individual line items that have appeared on their bills.

Other consumers actually are worse off, because carriers may have used the opportunity to confuse consumers and make them feel that some governmental actions require higher bills. Rate hikes should not masquerade as government-mandated fees.

Let me be clear. I do not believe it is a legitimate goal of government to impose costs on carriers and then try to prevent them from telling consumers about it. But, if government takes pains to lower carriers' costs in one area by more than they are going up in another, I have yet to hear a principled explanation why a carrier should tell the consumer about the latter but not the former.

Also, I have yet to hear anyone explain why trained customer service representatives routinely give out inaccurate information about the aggregate effects of access charge and universal service changes.

I am glad that consumer complaints about telephone bill line items are declining, but I still believe that there is more confusion and misinformation than necessary. I also believe that confusing billing formats exacerbate the problems of slamming and cramming, about which complaints continue to grow.

Consumers are entitled to bills that are intelligible and legitimate. Carriers, too, benefit when consumers can have confidence that their bills are legitimate and that they are receiving the full measure of savings they are due. It is my hope that this Notice will help us work with carriers, consumers, and other governmental entities to ensure that this is the case.