Attachment iv. PA_RNA Transition Plan.pdf

Version 1.1 July 8, 2020

PA Transition Plan

PA Transition Plan Version 1.1

Somos Confidential and Proprietary 1 Contract Number: 273FCC19C0002

Table of Contents

1. Overview

1.1 Scope

1.2 Systems Overview

1.2.1 Pooling Administration System (PAS)

1.2.2 Routing Number Administration System (RNAS)

1.3 Document Overview

2. Description of the Transition

2.1 Transition Meeting

2.2 PA and RNA Processes and System Familiarization and Training

3. Notification to the Stakeholders

4. Records Transfer

5. Current System Functions and Transition Processes

5.1 Thousands-Block Pooling Administration and p-ANI Administration Transition Plan

5.1.1 Functional Overview:

5.1.2 Systems Overview

5.1.3 Relationship between PAS/RNAS Systems and Other Databases

5.1.4 Reference Documents

5.2 Pooling Administration (PA) Director

5.3 Technical Operations Group

5.3.1 Functional Overview

5.3.2 Pooling Administration and Routing Number Administration Systems Transition ... 15

5.4 Pooling Administration and P-ANI Administration Groups

5.4.1 Functional Overview

5.4.2 Pooling Administrator and p-ANI Administrator Functions Transition

Somos Confidential and Proprietary 2 Contract Number: 273FCC19C0002

5.4.3 Support Tools

5.5 Other Pooling Administration Functions

5.5.1 Data Quality and Implementation Management

5.5.2 Industry Relations Transition Plan

5.5.3 Regulatory/Compliance Transition Plan

6. PA Forum Participation

7. Transition Costs

8. Change History

Appendix A: Inventory* and PAS/RNAS Tools and Licenses

Licenses and Tools for PAS/RNAS

Appendix B: Records

Appendix C: Timeline

Somos Confidential and Proprietary 3 Contract Number: 273FCC19C0002

1. Overview

1.1 Scope

In accordance with Incumbent’s FCC Contract Number 273FCC19C0002 for both thousands-block pooling and p-ANI administration services, Somos, Inc., as the National Pooling Administrator (PA) and Routing Number Administrator (RNA), (herein after “Incumbent”) hereby submits this Transition Plan (Plan) for the transfer of PA and RNA functions from Incumbent to a new Contractor, if required. This document complies with the contractual requirements set forth in FCC Contract 273FCC19C0002, Sections 3.20.5 and 4.20.5 Transition Plan, of the Technical Requirements Document, which directs that:

The contractor shall provide to the Government a detailed Transition Plan that provides for an efficient and orderly transition. This transition plan shall follow the format, as applicable, of Software Transition Plan (STrP) (Appendix B, Reference 24).

Reference to “the services continuity clause in Section I (52.237-03)” is found in Solicitation.

Section 52.237 of the Federal Acquisition Regulations (FAR) reads as follows:

52.237-3 -- Continuity of Services.

(a) The Contractor recognizes that the services under this contract are vital to the Government and must be continued without interruption and that, upon contract expiration, a successor, either the Government or another contractor, may continue them. The Contractor agrees to-

(1) Furnish phase-in training; and

(2) Exercise its best efforts and cooperation to effect an orderly and efficient transition to a successor.

(b) The Contractor shall, upon the Contracting Officer's written notice, (1) furnish phase-in, phase-out services for up to 90 days after this contract expires and (2) negotiate in good faith a plan with a successor to determine the nature and extent of phase-in, phase-out services required. The plan shall specify a training program and a date for transferring responsibilities for each division of work described in the plan, and shall be subject to the Contracting Officer's approval. The Contractor shall provide sufficient experienced personnel during the phase-in, phase-out period to ensure that the services called for by this contract are maintained at the required level of proficiency.

(c) The Contractor shall allow as many personnel as practicable to remain on the job to help the successor maintain the continuity and consistency of the services required by this contract. The Contractor also shall disclose necessary personnel records and allow the successor to conduct on-site interviews with these employees. If selected employees are agreeable to the

Somos Confidential and Proprietary 4 Contract Number: 273FCC19C0002 change, the Contractor shall release them at a mutually agreeable date and negotiate transfer of their earned fringe benefits to the successor.

(d) The Contractor shall be reimbursed for all reasonable phase-in, phase-out costs (i.e., costs incurred within the agreed period after contract expiration that result from phase-in, phase-out operations) and a fee (profit) not to exceed a pro rata portion of the fee (the profit) under this contract.

The objective of this plan is to ensure the continuity of PA and RNA functions in accordance with the requirements of law during the contract change. The plan will become operative only if a vendor other than Incumbent is awarded the next National Pooling Administration contract.

This plan establishes a 90-day transition period from the Incumbent to the newly selected vendor (hereinafter referred to as the “selected vendor”) that will commence on the date the FCC notifies the Incumbent of the contract award to the selected vendor and will enable Incumbent to conduct pre-transition and actual transition activities. Transition time intervals for individual functions and services performed by the PA and RNA are established in this plan to allow for an effective migration of responsibilities to the selected vendor.

The following assumptions were used in the development of this plan:

• The selected vendor will assume all PA and RNA responsibilities after the 90-day transition period;

• Incumbent, as both PA and RNA, will provide technical support for a period of up to 45 days over a six-month period after the transition period;

• The selected vendor will provide the resources needed to carry out its obligations during the transition; and

• The selected vendor will be thoroughly conversant with all Communications Industry (Industry) administration and assignment guidelines, the PA and RNA Requirements documents, and applicable federal and/or state directives pertaining to thousands-block pooling and pseudo-automatic number identification (p-ANI) administration.

If any of these assumptions are not met, the PA and RNA reserve the right to cease transition activities until the selected vendor resolves the deficiencies, after consultation with and approval of the FCC Contracting Officer.

Incumbent will transfer:

• Associated system data and contracts;

• All system documentation specified in the System Documentation Plan;

• Application code from Incumbent’s current source code container, currently CodeCommit;

Somos Confidential and Proprietary 5 Contract Number: 273FCC19C0002

• All specifications with instructions to deploy the Pooling Administration System (PAS) and the Routing Numbering Administration System (RNAS) in an AWS environment;

• PAS and RNAS data, records, and reports;

• PA and RNA operations files, records, and reports;

• Copies of most recently delivered Contract Data Requirements List (CDRLs) documents; and

Appendix A provides the specific software used in conjunction with PAS and RNAS and indicates which licenses are transferable to the newly selected vendor. Appendix B details the data records Incumbent will provide during transition.

1.2 Systems Overview

As indicated, there are two systems that will transfer according to this plan: PAS and RNAS.

Both systems are hosted on the Amazon Web Services (AWS) cloud platform under a master account transferable to the FCC when the Incumbent is no longer responsible for operating/maintaining the systems.

1.2.1 Pooling Administration System (PAS)

This section provides a general overview and purpose for the functions of PAS.

The PA is responsible for administering telephone numbers in blocks of a thousand (thousands -blocks) and manages these primary resources as pools of available thousands-blocks utilizing PAS. The thousands-blocks are added to and withdrawn from the pools and administered by the PA staff. The process is controlled using a number of Industry-defined forms contained in the Thousand-Block Pooling Administration Guidelines (TBPAG) created by the Industry Numbering Committee (INC). In addition to establishing the format of the forms, the Industry has also prescribed a sequence of events for each request, and strict time limits during which these events must occur.

Thousands-block administration uses PAS to process thousands-block requests. PAS is a web-based system that enables:

• Service providers and pooling administration staff to submit and process forms on line;

• Automatic tracking of forms submitted, enabling service providers and Pooling Administrators (PAs) to query and report on the status of applications; and

• Creation of a variety of reports used by the contractor and its customers.

Additionally, PAS provides an electronic means of creating, storing, and processing forms, as well as other documents used in the pooling administration process.

PAS tracks and stores the following additional information:

Somos Confidential and Proprietary 6 Contract Number: 273FCC19C0002

• Session data (login times, number of users logged in, etc.);

• INC Forms (Part 1, Part 1A, Part 1B, MTE, Part 3A, Part 4A and Part 5 forms);

• Forecast Data;

• User information contained in the user’s profile (i.e., company’s headquarters address, telephone number, etc.);

• All available, assigned, retained and reserved blocks, including all applicable historical information on all blocks; and

• Current and historical rate center, MSA, and LATA information.

PAS supports a web-based graphical user interface (GUI) to assist PA personnel in administering blocks; it is also used by service providers to request, modify, and return blocks.

The U.S. Local Number Portability Administrator (LNPA) personnel can access PAS through a GUI, although data is passed between PAS and the Number Portability Administration Center (NPAC) using an API interface. PAS also interfaces with the NANP Administration System (NAS), as directed by the national pooling contract.

Users that interact with PAS may include service providers, service provider consultants, PA staff, systems administrators, and state and federal regulators.

Since PAS is a web-based system, the PA website and the domain name of www.nationalpooling.com will also be transferred at the same time as PAS.

1.2.2 Routing Number Administration System (RNAS)

This section provides an overview of RNAS.

The RNA is responsible for administering non-dialable p-ANIs. These resources are administered by the RNA using the Industry-defined forms contained in the P-ANI Administration Guidelines created by the INC. In addition to establishing the format of the forms, the Industry has also prescribed a sequence of events for each request, and strict time limits during which these events must occur.

The RNA uses RNAS to process p-ANI requests. RNAS is a web-based system that enables:

• Service providers and RNA staff to submit and process forms on-line;

• Automatic tracking of forms submitted, enabling service providers and RNA to query and review the status of applications;

• Creation of a variety of reports used by the RNA in performing its duties.

Additionally, RNAS provides an electronic means of creating, storing, and processing forms, as well as other documents used in the RNA process.

http://www.nationalpooling.com/

Somos Confidential and Proprietary 7 Contract Number: 273FCC19C0002

RNAS tracks and stores the following additional information:

• Session data (login times, number of users logged in, etc.);

• INC Forms (Part 1 and Part 3 forms);

• Forecast Data;

• Annual Report Data;

• User information contained in the user’s profile (i.e., company’s address, telephone number, etc.); and

• Assigned, aging, and available p-ANIs.

RNAS supports a web-based graphical user interface (GUI) to assist the RNA in administering p-ANIs; it is also used by service providers to request p-ANIs.

Users of RNAS may include: FCC, state commissions; 9-1-1 governing authorities; Public Safety Answering Points (PSAPs); 9-1-1 system service providers; service providers; service provider consultants; and the RNA.

Since RNAS is a web-based system, the RNA website and the domain name of www.nationalpani.com will also be transferred at the same time as the RNA function.

1.3 Document Overview

This document identifies the role of each functional group within the national pooling administration organization and addresses how and when those activities will be transferred to the selected vendor.

http://www.nationalpani.com/

Somos Confidential and Proprietary 8 Contract Number: 273FCC19C0002

2. Description of the Transition

The transition will take place subsequent to the award of the new contract and will take no longer than 90 calendar days. During the transition period, notification, records transfer, training, web site transfer, systems transition, and assumption of PA and RNA responsibilities will occur. Plan Sections 3, 4, and 5 address those activities in more detail.

During the transition, the selected vendor will assume responsibilities for all thousands-block numbering and p-ANI resources currently administered by Incumbent as the PA and RNA.

Incumbent will perform its current number administration responsibilities through end of transition.

Incumbent will designate primary points of contact for transition activities. It is assumed that the selected vendor will also designate primary points of contact for the transition.

This plan envisions initial transition commencement meetings facilitated by the FCC, during which parties will review the document, add any additional detail as required, and identify the mutually-agreeable specific dates for actions. This plan assumes that the selected vendor will be using the existing systems and does not encompass any modifications or enhancements to the existing PAS or RNAS by the selected vendor.

2.1 Transition Meeting

It is anticipated that within one week of the contracting officer’s written notification to Incumbent, the FCC will conduct a transition meeting between the selected vendor and Incumbent to:

• Develop a mutually agreeable schedule for the PA and RNA Processes and Systems Familiarization and Training referenced in Section 2.2 below, and the start date for the actual transition period;

• Define the roles and responsibilities of both the selected and incumbent vendors in the effective and efficient transfer of the pooling and RNA functions; and

• Identify the information and training needs of the selected vendor.

Details of this plan may change during the transition meeting, either by mutual agreement of the parties, or at the direction of the FCC. All changes, modifications, or amendments to the plan must be in writing and must be approved by the FCC Contracting Officer.

2.2 PA and RNA Processes and System Familiarization and Training

As set forth in the timeline attached as Appendix C, Incumbent will provide the new vendor with an overview of and training for the PA and RNA processes and systems and supply the new vendor with information needed to operate PAS and RNAS in order to assume the duties of the PA and RNA. Section 5 details topics for the overview and training. The new vendor’s information needs shall be determined and agreed to at the transition meeting. As indicated in

Somos Confidential and Proprietary 9 Contract Number: 273FCC19C0002 the contract, Incumbent will provide, if requested, up to 45 working days of technical support over a six–month period after the transition period.

3. Notification to the Stakeholders

Notification to Industry members and regulators of the transition of PA and RNA functions from Incumbent to the selected vendor will be the responsibility of and performed by the selected vendor in a coordinated effort between Incumbent and the selected vendor through a variety of mechanisms, including e-mail distribution, notices posted to the PA and RNA web pages, and FCC-approved press releases. Coordination between Incumbent and the selected vendor will be necessary to ensure proper notification is provided, because the PA’s location, phone numbers, faxes numbers, and e-mail addresses will change during the transition.

4. Records Transfer

All paper and electronic thousands-block pooling and p-ANI records will be transferred to the selected vendor at the direction of the FCC. These records include those items specifically identified in this plan as well as records listed in Appendix B. The selected vendor will be responsible for all reasonable and necessary costs associated with packaging and delivery of paper and electronic records and portable data files.

5. Current System Functions and Transition Processes

5.1 Thousands-Block Pooling Administration and p-ANI Administration Transition Plan

5.1.1 Functional Overview:

The PA manages the assignment of thousands-blocks in the United States and Puerto Rico, governed by federal and state regulatory directives, the PA Technical Requirements, and the Industry-developed Thousands-Block Number (NXX-X) Pooling Administration Guidelines (TBPAG). Pooling administration responsibilities with respect to thousands-blocks include receiving and processing applications, maintaining records, reclamation, responding to telephone and e-mail inquiries, and preparing and providing reports on activities related to those tasks and the status of thousands-blocks.

The PA website (www.nationalpooling.com) serves as the repository for assignment information, as well as the place to find pooling reports, rate center files, user manuals, Frequently Asked Questions (FAQs), and the checklist for carriers just beginning to pool. In addition, the site serves as a gateway for entry into PAS.

The RNA manages the assignment of non-dialable p-ANIs (NPA-N11-XXXX) in the United States, Puerto Rico, and Virgin Islands using federal and state regulatory directives and the P-ANI Administration Guidelines created by the INC. The RNA responsibilities with respect to p-ANIs include receiving and processing applications, maintaining records, reclamation, http://www.nationalpooling.com/

Somos Confidential and Proprietary 10 Contract Number: 273FCC19C0002 responding to telephone and e-mail inquiries, and preparing and providing reports on activities related to those tasks and the status of p-ANIs.

The RNA website (www.nationalpani.com) is the gateway for entry into RNAS as well as the storage area for p-ANI-related information and user manuals.

5.1.2 Systems Overview

5.1.2.1 Pooling Administration System

The main PAS functionality includes:

• To create, store, execute, and administer Industry-defined forms by electronic means accessible to users via a connection to the World Wide Web.

• To generate reminder notices to users when time limits for events near expiration.

• To manage 1K block pools, as resources are added to or withdrawn from them.

• To minimize the amount of information service providers and PAs have to input manually.

Each user will create a profile that will be automatically invoked by PAS whenever the user logs in and will be used to auto-populate the appropriate fields in the forms the user accesses. As a user migrates from one form to another, any fields on the new form that are identical to or can be derived from fields on an earlier form, will also be auto-populated.

The two principal users of PAS are the service providers (SPs) and PAs. The service providers are external users who utilize the pooled resources. The PAs are internal users who administer the pooled resources.

The following Industry-defined forms govern the majority of the interactions between these two types of users and PAS:

• Part 1;

• Part 1A;

• Part 1B;

• Part 3A;

• Part 4A;

• Part 5;

• Forecast; and

• MTE (Month to Exhaust).

http://www.nationalpani.com/

Somos Confidential and Proprietary 11 Contract Number: 273FCC19C0002

PAS external users can submit forms via:

• The web-enabled GUI;

• Secure FTP file; and

• Fax or e-mail (as needed, only if web-based methods are not available).

The PA’s role is to ensure the SPs’ requests for resources are met in a timely and impartial manner, and in accordance with regulatory mandates and the TBPAG. PAS continuously and automatically performs a number of administrative functions, including sending out reminders for semi-annual forecasts or replenishing the pools, and automatically keeping track of the availability and status of the blocks in the various pools.

PAS supports a web-based graphical user interface (GUI) to assist PA personnel in administering blocks; it is also used by service providers to request, modify, and return blocks.

External users who may interact with PAS are:

• Service providers (SPs);

• Service provider consultants (SPCs);

• Federal Communication Commission users;

• NPAC users;

• State commission users;

• NANPA users; and

• Auditors.

Internal users that may interact with PAS are:

• Pooling Administration Director;

• Regional Director, Pooling Administration Services Center;

• Pooling Administration Manager (PAM);

• Senior Pooling Specialist (SPS);

• Pooling Administrators (PAs);

• Data Quality and Implementation Manager (DQIM);

• Sr. Data Analyst;

Somos Confidential and Proprietary 12 Contract Number: 273FCC19C0002

• Customer Service Representative;

• Regulatory/Compliance Senior Manager; and

• Industry Interface Representative.

PAS is hosted on the AWS cloud platform. The current architecture is configured so PAS is redundant in the primary region it operates out of (US-EAST-1), with a disaster recovery configuration in US-WEST-2. The AWS account can be transferred to the new vendor when the Incumbent is no longer responsible for operating and maintaining the systems. This account is shared for RNAS and PAS.

5.1.2.2 Routing Number Administration System (RNAS)

The main objectives of RNAS are as follows:

• To manage non-dialable p-ANIs as those resources are assigned from and returned to the p-ANI inventory;

• To execute, create, and store Industry-defined forms by electronic means accessible to users via a connection to the World Wide Web;

• To flag work items assigned to the RNA when the time limits for events are about to expire;

• To provide extensive reporting capabilities; and

• To make available to the PSAP community individual p-ANI assignment information for troubleshooting purposes.

The two principal users of RNAS are the service providers and the RNA. The service providers are external users who utilize the non-dialable p-ANIs. The RNA is an internal user who administers the non-dialable p-ANIs. The following Industry-defined forms govern the majority of the interactions between these two types of users and RNAS:

• Part 1;

• Part 3;

• Forecast; and

• Annual Report.

RNAS external users can submit forms one of two ways:

• Via the web-enabled GUI (Part 1, Forecast, and Annual Report); and

• Via e-mail (Part 1, Forecast and Annual Report).

Somos Confidential and Proprietary 13 Contract Number: 273FCC19C0002

The RNA’s role is to ensure the SPs’ requests for resources are met in a timely and impartial manner, and in accordance with regulatory mandates and the p-ANI Administration Guidelines.

RNAS automatically performs a number of administrative functions, including sending out reminders for semi-annual forecasts and annual reports.

RNAS supports a web-based graphical user interface (GUI) to assist RNA personnel in administering non-dialable p-ANIs; it is also used by service providers to request, modify, and return non-dialable p-ANIs.

External users that may interact with RNAS are:

• Service provider users (SPs);

• Service provider consultant users (SPCs);

• Federal Communication Commission users;

• State commission users;

• 911 Governing Authority users;

• PSAP users;

• 911 System Service Provider users; and

• Auditors.

Internal users that may interact with RNAS are:

• Pooling Administration Director;

• p-ANI Administrator;

• Regulatory/Compliance Senior Manager;

• Sr. Data Analyst; and

• Industry Interface Representative.

RNAS is hosted on the AWS cloud platform. The current architecture is configured so RNAS is redundant in the primary region it operates out of (US-EAST-1), with a disaster recovery configuration in US-WEST-2. RNAS and PAS share the AWS account, which can be transferred to the new vendor at the end of the Contract.

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5.1.3 Relationship between PAS/RNAS Systems and Other Databases

Because a block applicant must have a current NRUF Form 502 on file with the NANPA and with the PA before it can receive a thousands-block, PAS receives daily updates from NANPA on all SPs that have submitted a NRUF.

PAS and RNAS also automatically receive a daily list of delinquent OCNs on the FCC Red Light list from NANPA, which receives it from the FCC. If an OCN appears on the list in a delinquent status, a request for resources related to that OCN will be denied.

PAS also receives the SPID and LRN information on a daily basis from an LSMS provider. This arrangement is non-transferable, and the new contractor will need to establish their access to this data separately.

In addition, there is a separate, transferrable FCC PAS API test environment for the Local Number Portability Administrator (currently iconectiv) to test changes in PAS.

5.1.4 Reference Documents

All documents provided to the selected vendor during the transition process are listed in Appendix B.

5.2 Pooling Administration (PA) Director

The Pooling Administration Director has ultimate responsibility for the entire thousands-block pooling and RNA program, including the accuracy and timeliness of its deliverables, budget, payroll, compliance with the FCC and Industry requirements, performance evaluations, and the supervision, hiring, and training of staff, which includes the Manager of Security and Technical Operations (M/STO), the Data Quality and Implementation group, the Industry Relations, the Sr. Manager Regulatory/Compliance, the Pooling Administration Services Center (PASC), and the RNA group.

As needed, the Director interfaces with all internal and external customers, both regulators and Industry, to resolve all customer service issues. Additionally, the Director attends and participates in Emergency Services Interconnection Forum (ESIF), and other Industry groups, as necessary; and serves on relevant Industry Issue Management Groups (IMGs).

5.3 Technical Operations Group

5.3.1 Functional Overview

The Technical Operations Group is composed of the Director, Software Development and the Software Development and Application Support Team.

The Technical Operations Group supports PAS and RNAS with information and troubleshooting required for issues with customers and/or the system and creates and maintains custom applications. Further, it maintains PAS and RNAS servers, keeps the operating system and

Somos Confidential and Proprietary 15 Contract Number: 273FCC19C0002 software current, and assists end users with testing, troubleshooting, networking, and security concerns. This Group also performs software upgrades and updates, advises the team when updates are needed, maintains the testing environment, and deploys applications by upgrading the source code in PAS and RNAS.

The M/STO reports to the PA Director, and is responsible for:

• Maintaining the PA inventory and associated documentation including interfacing with the FCC on inventory matters;

• Supporting all pooling user equipment, laptops, printers, etc., and ensuring their security, and all software, hardware, and e-mail virus protections are kept up to date;

• Serving as the Corporate contact for all matters relating to the operation of the telephone and web services in the Concord, CA office, the LAN, and any physical plant issues;

• Maintaining the PA and RNA websites; and

• Assisting in periodic reviews and updates to the Security and Business Continuity/Disaster Recovery Plans.

5.3.2 Pooling Administration and Routing Number Administration Systems Transition

Transition of all systems’ components and functionalities without any down time is critical. It is assumed the new vendor will be capable of obtaining any user licenses for software without interruptions in service. In accordance with the agreed upon timeline, the Incumbent will operate the systems until the new vendor successfully cuts over to PAS and RNAS and is fully operational.

Incumbent proposes the following high-level approach for the transfer of the systems over the 90-day transition period, as reflected in more detail in Appendix C:

• Incumbent to review new Contractor’s transition plan and provide feedback and/or acceptance;

• Initial training session on PAS/RNAS applications, website, and database structures;

• Execution of new Contractor’s Transition Plan;

• System cut over; and

• Post cutover activities/support.

Incumbent’s technical support team will conduct a two-week technical educational session for the selected vendor’s technical support team. The first part of the training will focus on system architecture, application code, and database modules for PAS and RNAS. Thereafter, a portion

Somos Confidential and Proprietary 16 Contract Number: 273FCC19C0002 will be devoted to a review of web content management and reports generated by third-party tools from PAS and RNAS. Finally, a portion will focus on system administration support and review of service level agreements.

Incumbent will be available for technical support (i.e., answer questions, attend transition meetings, provide any system documentation and data, execute on agreed upon transition tasks) during execution of Contractor’s transition Plan. As stated previously, the processing of all PAS/RNAS applications during this period will still be Incumbent’s responsibility.

Near the end of the transition period, when notifications have been made, and the selected vendor is ready to receive live PAS and RNAS transactions, the cutover period will begin. After systems review, testing, and transition are complete, based on a set of Go/No-Go criteria, the FCC will authorize the cutover of thousands-block pooling administration and p-ANI administration from Incumbent to the selected vendor. This will occur on a weekend approximately 85 days into the transition. During this weekend, Incumbent and the selected vendor will perform a cutover. This cutover will include a direct data transfer of all live data from Incumbent primary server to the selected vendor’s primary server, or the final handoff from Incumbent to the new vendor of all AWS access keys.

5.4 Pooling Administration and P-ANI Administration Groups

5.4.1 Functional Overview

5.4.1.1 Pooling Administration Group

The Pooling Administration Group consists of the Regional Director for the Pooling Administration Services Center (PASC), Pooling Administration Manager, Senior Pooling Specialist, Pooling Administrators, and the Customer Service Representative, all of whom are located in Concord, CA. The Industry Interface Representative (referenced in Section 5.5.2.1), and the Manager/Security and Technical Operations are also located in Concord.

The Regional Director (RD/PASC) works closely with the PA Director and is responsible for the overall operation of the PASC. Those responsibilities include, but are not limited to, overseeing the staffing, handling escalated issues; interfacing with the Telecommunications Industry and regulatory agencies; and evaluating current workflows and identifying process improvements where needed. The RD/PASC also performs some Pooling Administrator tasks in a back-up capacity when necessary.

The Pooling Administration Manager (PAM), in addition to performing the Pooling Administrator functions identified below, trains and supervises the Pooling Administrators and handles escalated issues. Together with the PASC Regional Director and the Sr. Data Analyst, the PAM conducts PAS user acceptance and regression testing for any change orders as needed.

The Senior Pooling Specialist (SPS), in addition to performing the Pooling Administrator functions identified below, manages the reclamation process, handles mass modifications, and some monthly reporting requirements.

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The PAM and SPS also work with service providers to resolve customer outage issues and data discrepancies, interact with service providers and regulatory agencies, and, in conjunction with the Senior Manager, Regulatory/Compliance, educate service providers and regulatory staff on numbering-related items.

The Pooling Administrators (PAs) process Part 1A applications and Part 1 applications (that are sent directly to NANPA) in mandatory, mandatory single-service provider, and optional pooling rate centers in the United States and Puerto Rico. The types of requests the PAs process, whether submitted manually or through PAS, include applications for initial blocks (including reviewing required documentation such as the state or federal certifications and proof of facilities readiness), growth blocks, requests for central office codes for LRNs, pool replenishment or dedicated customers, block modifications (e.g., OCN and switch changes, any edits to the Part 1B submissions, rescheduling an effective date, etc.), block transfers, block disconnects, and changes and disconnects to pooled central office codes. The PAs also respond to inquiries by e-mail or telephone.

The Customer Service Representative (CSR) provides technical and non-technical support to internal and external customers in problem resolution. The CSR monitors trouble tickets to ensure timely resolution of problems and escalates issues in a timely manner. Additionally, the CSR handles creation, deletion, and maintenance of PAS user accounts and passwords and assists the PAs as needed.

5.4.1.2 P-ANI Administration

The p-ANI group consists of a PA Director and p-ANI administrator. The PA Director manages the RNA activities, which include:

• Developing M&Ps as necessary;

• Developing User Guides;

• Supervising the p-ANI administrator; and

• Ensuring p-ANIs are administered in compliance with the p-ANI Administration Guidelines.

Other functions (such as data quality assurance, compliance, regulatory interface, Industry interface) have been assumed by the person or team performing those functions for National Pooling Administration.

As needed, the PA Director and/or the Industry Interface Representative may participate in ESIF meetings that include any issues related to p-ANI. The PA Director and the Industry Interface Representative also prepare for INC meetings; the IIR brings in issues and contributions to INC meetings for amendments to the p-ANI Administration Guidelines.

5.4.2 Pooling Administrator and p-ANI Administrator Functions Transition

Pooling personnel will provide an overview of PAS and RNAS from the perspective of the administrators, its current operation, and a demonstration of how the current PAS and RNAS

Somos Confidential and Proprietary 18 Contract Number: 273FCC19C0002 internal and external GUIs work as identified in the timeline after the start of transition. The training will cover how the pooling administrators process applications and perform reclamation functions, as well as interactions with the NANPA, the NPAC, and iconectiv and how the p-ANI administrator processes applications. Additionally, there will be other training sessions, as reflected in Appendix C.

During the training session on the pooling and p-ANI administrators’ processes and their use of PAS and RNAS, Incumbent personnel will process applications side-by-side with the representatives of the selected vendor to familiarize them with the existing processes. This will include explaining the processing differences between applications for growth and initial blocks, the necessary review of paperwork, how to handle requests for whole codes for LRNs, for pool replenishment or for dedicated customers, requests for modifications, block reclamation processes, manual applications, and how to respond to inquiries by e-mail or telephone. It will also include training on applications for p-ANIs. This training activity will take place at Incumbent’s Concord, CA offices using the Pooling Administrator’s facilities and equipment.

During this time, the selected vendor will have the opportunity to become familiar with PAS and RNAS functionality and begin to understand thousands-block pooling and p-ANI processing functions. User documentation for PAS and RNAS functions is publicly available on the website; however, Incumbent will provide the selected vendor with a copy of all relevant documentation in electronic form. It is assumed that representatives from the selected vendor will have reviewed the user documentation prior to the commencement of training. Since critical work functions performed by the administrators must continue on a daily basis, these training sessions may require careful scheduling and/or the use of backup personnel during this training process.

The PA’s process training will occur under the direct supervision of the Pooling Administration Manager, and the p-ANI administrator’s process training will occur under the direct supervision of the PA Director.

On a date identified by Incumbent and the selected vendor, and notified to the users, Incumbent will cease accepting applications and other submissions such as disconnects and forecasts. Any applications or submissions that have not been processed by Incumbent will be provided to the selected vendor for processing.

The day immediately following the date identified as the last day Incumbent accepts pooling applications and p-ANI applications, the selected vendor will assume total responsibility for the pooling administration and p-ANI administration process at its own facilities. All pending applications and submissions will be directed to the new vendor for processing. Incumbent will either forward any pooling and p-ANI administration-related information that Incumbent may receive on or after that date to the selected vendor or will refer the submitting party directly to the selected vendor.

The selected vendor will be responsible for ensuring documentation is moved to its facility, upon a date agreed to by both parties and the FCC, but this date shall not be later than three business days after the last day Incumbent accepts and processes applications.

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The documents that will be submitted to the successor are listed in Appendix B and organized, to the extent possible, by function. The following supporting documentation will also be provided to the selected vendor:

• Certification and network readiness support documentation for Pooling,

• Proof of certification documentation for p-ANI, and

• Correspondence and orders.

5.4.3 Support Tools

Hardware

The PASC and p-ANI Administration groups uses MacBook Pro laptops that will not be transferred.

Software

The PASC and p-ANI Administration groups use a variety of software products, all of which are either standard-purchase software products or are programs using those same commercially available software products. The licenses for these products are owned by Incumbent and will not be transferred.

Other Resources

The PASC group currently uses other resources that include BIRRDS and the LERG, which are iconectiv products purchased by Incumbent. The selected vendor will have to procure its own access to the LERG, because the access contract is not transferable. The PA uses the

BIRRDS database when assigning, modifying, or disconnecting blocks. The PA updates the

BCD/BCR screen with information associated with a block. The LERG, which is an output of

BIRRDS, is used by pooling administration to identify OCNs.

5.5 Other Pooling Administration Functions

5.5.1 Data Quality and Implementation Management

5.5.1.1 Functional Overview

The Data Quality and Implementation Management group includes the Data Quality and Implementation Manager (DQIM) and the Sr. Data Analyst. The DQIM report to the RD/PASC and the Sr. DA report to the PA Director, both individua’s work virtually.

Data Quality and Implementation Manager and Sr. Data Analyst handle the following essential functions:

Somos Confidential and Proprietary 20 Contract Number: 273FCC19C0002

• Maintaining the accurate designation of the rate centers populated in PAS and regularly posting that information.

• Monitoring the impact of pooling on NANPA jeopardy and relief planning projects and participating in all NANPA NPA meetings.

• Responding to inquiries by phone or e-mail from service providers and regulators regarding pooling and rate center status.

• Monitoring NANPA activity for NPA splits and overlays and updating PAS accordingly.

• Notifying SPs in single service provider rate centers when a second SP requests resources in that rate center.

• Analyzing the semi-annual service provider forecasts submitted for all pooling rate centers (filed concurrent with each NRUF filing) and providing a detailed report to NANPA.

• Providing primary responsibility and backup for many reporting functions.

• Performing quality assurance functions and testing PAS.

The Data Quality and Implementation Manager provides continuity within the Pooling Administration organization between the service providers and Pooling Administrators with regard to the pooling status of all rate centers involved in thousands-block pooling. The DQIM is a resource for service providers participating in pooling; as well as a resource for Pooling Administration with the NANPA relief planners. The DQIM has been cross-trained to perform PA functions for purposes of Disaster Recovery/Business Continuity, performs operational audit reviews, and is required to perform Pooling Administrator tasks in a back-up capacity.

The Sr. Data Analyst is responsible for the development, production, and quality control of the majority of all external and internal reports for pooling data. Numerous periodic and ad hoc reports are required by the contract. Annual, semiannual, quarterly, and monthly reports are developed, produced, and sent to the FCC and, in some cases, posted to the PA website.

Data Quality and Implementation Management is also responsible for responding to FCC, state regulator, and service provider data requests. Data and quality analysis are required for all phases of the pooling administration operation, as is forecasting and tracking of historical trends in all phases of pooling data.

Data Quality and Implementation Management, with the Sr. Data Analyst, designs, develops, and manages multiple database queries used for internal and external reporting requirements, including:

• Rate center data in PAS;

• MSA data; and

• Ad hoc reports.

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The Sr. Data Analyst monitors bulletins and data released by the U.S. Office of Management and Budget and U.S. Census Bureau to maintain a current list of rate centers within the top 100 MSAs. Incumbent will provide the most current list of top-100 MSAs to the selected vendor;

however, updates and maintenance of that list would become the responsibility of the selected vendor.

5.5.1.2 Reference Documents

The following documents relating to ongoing Pooling Implementation Management, many of them historical, will be provided to the selected vendor, and are in addition to the documents found in Appendix B:

• Reports related to pooling statistics associated with NANPA relief meetings

• Archived monthly rate center file change reports

• First Implementation Meeting Schedules

• First Implementation Meeting Materials o Meeting Presentations o Code Holder Lists o Rate Center Lists o First Implementation Meeting Minutes

• Supplemental Implementation Meeting Schedules

• Supplemental Implementation Meeting Materials o Meeting Presentations o Code Holder Lists o Rate Center Lists o Supplemental Implementation Meeting Minutes

• Number Resource and Utilization/Forecast (NRUF) files o SP input forms o NPA-related 502 Forms

• Semiannual Reports

Somos Confidential and Proprietary 22 Contract Number: 273FCC19C0002 o NRUF Pooling Codes Report to NANPA o NRUF Pooling Results Report to the FCC.

5.5.1.3 System Overview

Development and processing of periodic reports to the FCC regarding pooling activity are done using standard, off-the-shelf data management software and database programs (e.g., Access).

No specific systems other than PAS and RNAS are used for reports and data analyses.

5.5.1.4 Relationship to Other PA Functions

The Data Quality and Implementation Management group functions are integrated into the entire fabric of the daily PA operations. Periodic and ad hoc reports provide information and analysis for management, PA administration, overall quality assurance, rate center file maintenance, and system operations. Virtually all internal and external data requirements that are not already provided on the website are developed through this report/data analysis function.

5.5.1.5 Reference Documents

All documents used by the Data Quality and Implementation Management group are also used by other functional groups in Pooling Administration and are found under reference documents in Appendix B. The following documentation relating to ongoing Data Quality and Implementation Management and data analysis shall be provided to the selected vendor:

• Quarterly pooling matrices reports;

• Monthly FCC pooling reports; and

• Semi-annual Pooling data reports.

5.5.1.6 Support Services

Hardware

The Data Quality and Implementation Management group uses Microsoft Windows-based laptops that will not be transferred.

Software

The Data Quality and Implementation Management function uses a variety of software products, all of which are either standard-purchase software products or are programs using those same commercially available software products. The licenses for these products are owned by Incumbent and will not be transferred.

Other Resources

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The Data Quality and Implementation Management group uses other resources, such as LERG and BIRRDS to produce some reports. LERG and BIRRDS are the property of another vendor, and cannot be transferred, because the contract allowing access is not transferable.

5.5.1.7 Data Analysis Processes and System Familiarization and Training

The majority of the processes and systems developed for producing standard reports continue to be relatively standard each month and quarter. Training will be provided on basic ad hoc reports generation and will be based upon a list of all previously generated ad hoc reports.

These sessions will not include training in the use of off-the-shelf software.

5.5.1.8 Transition

The Data Quality and Implementation Manager and the Sr. Data Analyst will meet with representatives of the selected vendor (see the Incumbent transition timeline, Appendix C), at a location chosen during the initial transition meeting, to describe and demonstrate their functions. Within seven days after completion of this training, paper and electronic Data Quality and Implementation Management group records will be transferred to the selected vendor. These records include those items specifically identified above. The selected vendor will be responsible for all reasonable and necessary costs associated with packaging, shipping, and delivery of paper records. At the completion of transition, the selected vendor will bear the responsibility of producing all reports presently generated.

During the transition period, Incumbent will provide training on specific reports (see Appendix C).

Incumbent will provide copies of all relevant data and programs via electronic file transfer or media (CD or e-mail). Schedules between Incumbent and the selected vendor will be set up at the initial meeting to provide any training on the operation or preparation of specific reports required in the existing contract. During the transition period, Incumbent will continue to prepare and distribute required pooling reports to the FCC and state regulators until the selected vendor takes over responsibility. Any reports scheduled for production after the transition period will be the responsibility of the selected vendor. Upon completion of the transfer of PAS, the selected vendor must assume the responsibility of generating all new and existing reports.

5.5.2 Industry Relations Transition Plan

5.5.2.1 Functional Overview

The Industry Relations (IR) function is handled by the Industry Interface Representative (IIR), who is located in Concord, CA and reports directly to the PA Director. The IR interfaces with Industry groups such as the INC and the Common Interest Group on Rating and Routing (CIGRR) to provide technical and operational expertise for pooling processes and functions.

The IIR attends Industry meetings such as the INC on behalf of the PA and RNA (see Section 6).

The IIR identifies how issues at these meetings affect the PA and RNA, provides input as

Somos Confidential and Proprietary 24 Contract Number: 273FCC19C0002 needed, and generally represents the PA and RNA as the subject matter expert. The IIR, together with the PAM, develops and maintains methods and procedures as well as user guides for the PASC operations center to ensure all personnel in the PASC perform their functions in compliance with Industry guidelines and the PA technical requirements. Additionally, when a change to PAS is required because of a change order, the IIR takes the lead in writing the technical requirements for PAS, and forwards them to the developers, and subsequently participates in any PAS user acceptance and full regression testing.

5.5.2.2 System Overview

The IR use a variety of software products, all of which are either standard-purchase software products or are programs using those same commercially available software products. The licenses for these products are owned by Incumbent and will not be transferred.

5.5.2.3 Relationship to Other PA Functions

IR interfaces with Industry groups and other Incumbent…