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During 2001 and 2002, Liberty conducted a Performance Measures Audit for the Regional Oversight Committee (ROC), which consists of commissioners, commission staff, and stakeholders with responsibility for or substantial interests in the local exchange operations of US WEST (now Qwest) across the 14-state region in which this local exchange carrier provides such service. Thirteen of those 14 state commissions participated in this audit. The Arizona Commission conducted a separate audit of performance measures; however it later asked Liberty to include its state in subsequent Qwest data reconciliation work. 

Liberty’s Performance Measures Audit for the ROC was the country’s most extensive OSS testing ever undertaken in the context of Section 271 proceedings to approve the RBOC’s entry into the interLATA market in states where it provides local service.  That testing process included what is still the country’s most comprehensive examination of the accuracy of wholesale performance measuring and reporting. 

The Qwest audit specifically addressed a series of more than 50 performance measures (which, with sub-measures, impose several hundred quantified performance standards) by which Qwest’s performance for CLECs will be measured. These measures, among the country’s most detailed and quantitative, govern nearly every measurable aspect of Qwest’s performance. Measures included in the audit covered the areas of electronic gateway availability, pre-ordering, ordering and provisioning, maintenance and repair, billing, database updates (including E911), directory assistance, network performance, and collocation.  

Liberty’ audit included the three following principal audit task areas:

  • Examining the systems, processes, and procedures by which Qwest measures and records performance results;

  • Conducting detailed tracking of the data Qwest uses to measure performance (to verify accuracy, completeness, and use in actual measurements of performance results);

  • Replicating Qwest’s calculations of performance results to verify their accuracy and completeness.

As part of its continuing work after the audit, Liberty conducted extensive data reconciliation work using data provided by CLECs operating in the Qwest region. This data reconciliation effort was geared to determining whether there were reasonable assurances that the performance as measured and reported by Qwest was equivalent to the performance that Qwest actually delivered. 

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