They receive a single telephone bill from their LEC, and are responsible for paying that bill for all lines within the control of the institution. As an aggregator, the institution selects and contracts with telecommunications carriers to provide local and long distance telephone service, and any other telecommunications services, to their students and staff. The institution then bills students for their telephone lines and local and long distance services that they utilize. Or, the institution may contract out the billing function. However, in all cases the institution is the underlying entity that is responsible for paying the telephone bill that is received from the LEC or other billing entity.
Students receive numerous solicitations for such services.
In the case of services which are billed based on ANI capture, the problem becomes more complex. The billing number supplied in ANI information is often a trunk line coming into the PBX, rather than an active telephone line. The charge simply appears on the institution's monthly telephone bill without being attributable to any individual or extension. The proposed requirements in Section 308.17, which would require express authorization of the responsible party, and would prohibit vendors, service bureaus and billing entities from collecting or attempting to collect these charges when they know or should have known that the person ordering the service was not the responsible party, would help to resolve this situation. One method of ensuring that vendors, service bureaus and billing entities have accurate information regarding the correct responsible party would be to require the vendor, service bureau and billing entity to subscribe to a database maintained by each LEC containing this information.