July 31, 2014
Re:

RFP No. ADOC 14-00003887/14-066-24
Inmate Telephone System
Request for Clarification dated July 18, 2014

Dear Ms. Yaw:
CenturyLink thanks the State of Arizona and the Department of Corrections for the opportunity
to submit these answers to the State’s clarifying questions.
As part of a Local Exchange Carrier serving most of Arizona’s population, we are uniquely
positioned to provide the highest level of service in addition to a very competitive financial offer.
In addition, we believe we are able to consistently meet or exceed all the State’s requirements
and desired features/services.
Please do not hesitate to contact me or Senior Account Manager Vicki Johnson at
859.734.9424 if you require any additional information.

Sincerely,

Paul Cooper, General Manager
CenturyLink Public Communications, Inc.
th
5454 W. 110 Street, Overland Park, KS 66211
913.345.6002
paul.n.cooper@centurylink.com

CenturyLink Clarification Response: Page 1 of 9
RFP No. ADOC14-00003887/14-066-24

Arizona DOC Inmate Telephone System
Submitted: July 31, 2014

 Tab 3 Scope of Work-Technical Requirements

1) Section 2.4.3.10 On the daily automatic turn on and off, does it has the ability to
set for multiple time per day?
CenturyLink response: Yes. The following example illustrates a group of phones that
are turned off during lunch and dinner periods (11:00 – 13:00 and 17:00 – 19:00) Monday
through Friday, but are available during lunch and dinner on Saturday, Sunday, and
holidays. These time blocks are simply separated by a comma in the fields within the
phone schedule screen.
The “Groupname” is a specific group of inmate telephones defined by the Department.
Typically a physical facility will have several groups defined, for example, Dayroom 2A,
Medical, Segregation, etc. Each Department facility can have their own defined groups,
and there is no limit to the number of groups that can be implemented.

Weekly Phone Schedule Screen

2) Section 2.4.3.24 Please explain the automatic deletion of numbers for family
members who block future calls from the inmate (page 25 of your proposal).
CenturyLink response: When a called party answers the phone, they receive automated
voice prompts that offer several options, including the options to “block all future calls from
this facility” by dialing the designated single-digit code on their telephone dial pad. The
called party is prompted twice to prevent accidental blocking. The voice prompts that the
called party would hear are included to illustrate the “double” prompting:
CenturyLink Clarification Response: Page 2 of 9
RFP No. ADOC14-00003887/14-066-24

Arizona DOC Inmate Telephone System
Submitted: July 31, 2014

 Hello, you have a collect\prepaid\debit call from [inmates name], an inmate at [facility name]
To accept this call, Press 5”
To refuse this call, hang up now”
To block this call and future calls from this facility, Press 9
If called party presses 9 on keypad:
To block this call and all future calls from this inmate, Press 7
To Block this call and all future calls from this facility, Press 9
If called party presses 7 on keypad:
You have chosen to block calls from this inmate, Press 1 if this is correct. Press 3 to return
to the previous menu
If called party presses 9 on keypad:
You have chosen to block calls from this facility, Press 1 if this is correct. Press 3 to return
to the previous menu
If the called party selects the option to block future calls from this inmate, their telephone
number is automatically blocked (placed in “keypad block” status) from future calling from
that inmate, with no Department staff intervention necessary. The number is not deleted,
but placed in “block” status.
If a number is blocked, the family member can simply call our call center to get their
number unblocked. Information on how to get numbers unblocked is on our website, and
should the Department wish, the State’s website can be linked to our website.
The following screen illustrates an active number and a number that is in keypad block
status. The blocked number can quickly be unblocked by selecting “Not Blocked” from the
drop-down menu.

Personal Allowed/Blocked Numbers Screen

If the Department would like to be notified of these blocking events, the IPS can be
configured so that the database entry event (blocking future calls from the inmate) triggers
an alert that automatically notifies designated Department staff.

CenturyLink Clarification Response: Page 3 of 9
RFP No. ADOC14-00003887/14-066-24

Arizona DOC Inmate Telephone System
Submitted: July 31, 2014

 Summary:


The called party is double-prompted prior to either refusing a single call from an
inmate or blocking all future calls from an inmate or facility. This reduces the
probability that family members incorrectly or inadvertently block all future calls
from Department facilities.



If a called party refuses all future calls, history is preserved by placing the number
into keypad block status for review by authorized staff.



Business rules for automated blocking, notifications to designated staff, etc. can
easily be configured from within the system.



If a called party incorrectly or inadvertently blocks all future calls from an inmate or
the Department, our call center or on-site administrators are always available to
unblock the number in a timely fashion.

3) Is continuous voice biometric monitoring available and is it at an additional cost?
CenturyLink response: Yes, continuous voice biometric monitoring is available
to the Department. Because it involves third party royalty payments, the
implementation of continuous voice biometrics would impact our commission offer.
“Pre-call” or “voice print” voice biometrics is also available, and at no impact to our
commission offer.
With over 50,000 inmates using continuous voice biometrics on the Enforcer
system, CenturyLink and ICSolutions are the most experienced implementers of
this technology and have built the required server infrastructure to accommodate
this resource-intensive service.

4) Section 2.4.10.1 Can CenturyLink provide a WinTel 7090SSE telephone? Is there a
security reason why this phone should not be used?
CenturyLink response: Yes, the WinTel 7090SSE can be provided for Department
facilities. There are no security issues with using the 7090SSE and its installation would
not impact our financial offer.

5) Section 2.4.17.14 Payment options - Is this direct billing with CenturyLink or with
incumbent local exchange companies (ILECs) and competitive local exchange
companies (CLECs)?
CenturyLink response: These collect billing arrangements are with CenturyLink,
Inc.’s traditional phone service unit as well as other ILECs and CLECs.
If we do not have a third-party billing arrangement for an end-user’s telephone
service (such as a cell phone company), the called party will be automatically routed
to a call center representative who will walk the called party through the simple
CenturyLink Clarification Response: Page 4 of 9
RFP No. ADOC14-00003887/14-066-24

Arizona DOC Inmate Telephone System
Submitted: July 31, 2014

 process for setting up a prepaid account. Per RFP requirements, there will be no
setup or other transaction fees for managing collect services or prepaid accounts.

6) Would CenturyLink provide the Department a list of facilities that use the ICS
platform?
CenturyLink response: The table below provides information on state DOC accounts
that have the ICS Enforcer currently installed. In addition, CenturyLink is in the process
installing the Enforcer platform at the Idaho Department of Correction under a five year
contract. This installation will support approximately 7,300 inmates at 15 sites with 550
phones. Note that the contracts for Iowa, New Hampshire, and Wyoming are held directly
by ICSolutions.
The Enforcer was also installed at the Illinois Department of Corrections under a contract
with Illinois-based LEC Consolidated Communications, before the contract was lost due
primarily to pricing. Illinois DOC has 30 facilities and approximately 49,000 inmates. A
letter describing the Enforcer’s historical performance in Illinois is attached at the end of
this response.
Finally, the platform is in use at an additional 150 county facilities that house close to 100,000
inmates.
CenturyLink uses the Enforcer platform exclusively on all new business due to its proven revenue
performance (due to its unique prepaid collect call routing and setup process), rich feature set,
stability, and support from developer ICSolutions.

State Departments of Correction with Enforcer Inmate
Telephone System
Account
Alabama DOC
Kansas DOC
Nevada DOC
Iowa DOC
New Hampshire DOC
Wyoming DOC

Sites

Population

Phones

29
13
18
9
4

25,000
9,500
12,800
8,500
2,550

1,171
967
678
415
246

5

1,950

87

7) Does CenturyLink have the ability to import call data and recordings from the
previous vendor for use?
CenturyLink response: Yes. This process requires only (1) a standard readable file format
including historical call detail records and (2) recordings in a non-proprietary playable format from
the outgoing vendor. Based on the sample file formats received, CenturyLink would
translate/normalize the outgoing vendor’s data format to the Department’s new IPS
platform. Prior to actually deploying the IPS, we will perform a robust series of tests to
CenturyLink Clarification Response: Page 5 of 9
RFP No. ADOC14-00003887/14-066-24

Arizona DOC Inmate Telephone System
Submitted: July 31, 2014

 ensure accuracy of all data transferred.
CenturyLink would not charge the Department or the outgoing vendor for performing this work.
This importing of historical data is in addition to the standard process of transferring over
data such as PINs, allowed numbers (PANs), and global numbers such as attorneys from
the previous provider.
Should CenturyLink be awarded this contract and subsequently lose it at a later date, we
commit to work with the incoming vendor to transfer all of the State’s data to the new
vendor. CenturyLink would not charge the State or the incoming vendor for this service.

8) Does the Department have the ability to view commission reports online?
CenturyLink response: Yes. The Department would have the ability to view all historical
commission reports online. The Department would also have access to real-time gross
revenue reports throughout the month so staff could forecast commission performance
using mid-month data.

9) Does CenturyLink block for uncollected calls when billed through a LEC or CLEC?
CenturyLink response: CenturyLink does not “block” calls without a customer being
given an opportunity to be brought to “current” status. If a LEC/CLEC-billed call comes
back to us as unpaid, we place a “soft block” on the line, so that next time the person
receives an inmate call, the family member is routed into our call center to pay their bill and
be brought to current status.
The bottom line is that with the Enforcer call routing engine, no customer is ever “hard
blocked” – that is, blocked without being given the opportunity to bring their account to
cleared/current status to continue receiving calls.
Another billing rule to note is that if the inmate is utilizing their debit account to pay for the
call and the called party’s account is still in bad payment status, CenturyLink will allow that
call to go through. This is because the party in non-payment status is the family member,
not the inmate paying for the call.

10) Please confirm in detail the assistance in repair of infrastructure of inmate
telephone post installation at no additional cost to the Department.
CenturyLink response: As part of a Local Exchange Carrier (LEC) serving most of
Arizona’s population, CenturyLink provides a unique set of capabilities in this area.
First, CenturyLink’s ADOC-dedicated service technicians are available for use by the
Department in whatever capacity they are needed by the Department – including the repair
of ADOC-internal telecommunications infrastructure.
Second, CenturyLink management has an expedited escalation channel within
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Arizona DOC Inmate Telephone System
Submitted: July 31, 2014

 CenturyLink, Inc.’s Arizona LEC operations should the Department experience issues with
any CenturyLink, Inc. services.
Finally, as discussed in our conference call and for those facilities in CenturyLink, Inc. LEC
territory, we are able to provide labor and consultation for cable maintenance issues
(materials excluded, except by mutual agreement) at Department facilities. These services
would be provided even if the cable is ADOC-owned, and would broadly include use of our
equipment for cable location, consultation regarding splicing or routing, etc. as required by
the particular situation. For contractual purposes, we request the ability to cap this
assistance to no more than three (3) instances per year. However, we commit to working
with the Department if further assistance is needed.
For out-of-territory facilities, CenturyLink cannot expressly commit to this type of
assistance. However, we offer to assess each out-of-territory situation on a case-by-case
basis with the Department. All ADOC facilities except for ASP-Apache, ASP-Ft. Grant,
and the Kingman facility are in CenturyLink, Inc. LEC territory.
All services described above would be at no cost to the Department and no impact to our
financial offer.

11) Please confirm there are no transaction fees, ancillary fees, billing fees, nor any other
types of fees billed to the Family and Friends.
CenturyLink response: Confirmed. CenturyLink will not charge any of these fees to
Family and Friends. In addition, we have successfully operated a no-fee billing program at
Kansas DOC since 2007. Our compliance with this no-fee policy is tested regularly by
internal and external resources, and we have never been found to be out of compliance
with this requirement.

12) Does FCC allow commission to be paid on interstate calls and are they included in
your offer?
CenturyLink response: Yes. Commission is allowed on all call types, including interstate,
under currently implemented FCC rules. Two points comprehensively summarize this
conclusion:
1. In the FCC’s Report and Order (FCC 13-113, released September 26, 2013), the FCC’s
commentary expressly states that the Commission declines to prohibit commissions on
any call types:
“We do not conclude that ICS [inmate calling service] providers and
correctional facilities cannot have arrangements that include site
commissions. We conclude only that…such commission payments are not
costs that can be recovered through interstate ICS rates.” (¶ 56) [emphasis
added]

2. Further and very important, the Report and Order was appealed at the D.C. Circuit
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Arizona DOC Inmate Telephone System
Submitted: July 31, 2014

 Court of Appeals. As part of the appeal, critical components of the Order were stayed
by the Court. In particular, the rules that ICS rates must be “cost-based” were stayed
and as a result, the determination that site commissions are not recoverable costs
currently has no legal effect. That is, the rules that certain providers use to claim that
interstate site commissions cannot be paid are not in effect today.1
Finally, on July 21, 2014 the FCC reiterated its position on commissions in its brief for the
Circuit Court appeal. The full document is available at:
http://transition.fcc.gov/Daily_Releases/Daily_Business/2014/db0722/DOC-328365A1.pdf.
See especially:
(p. 17) “…the Order does not bar inmate calling providers from having
‘arrangements’ with correctional facilities ‘that include site commissions’…”
(p. 63) “…the Order neither bars inmate calling providers from continuing to
pay site commissions out of their profits, nor restricts how correctional
facilities spend such payments.”

CenturyLink takes compliance with FCC rules, as well as its inmate communications
contracts, very seriously and conducted lengthy and thorough analysis of the Report and
Order and the Circuit Court’s partial stay. That analysis concluded that we could not refuse to
pay interstate commissions based on the portions of the FCC Report and Order that were
allowed to go into effect. This conclusion was made despite the fact that refusing to pay
interstate commissions would clearly be in CenturyLink’s financial interest.
Regarding commission on interstate calls, interstate commissions were not included in our
original offer in order to maximize our evaluation under the RFP’s rules.

1

Pages 1-88 of the Report and Order are simply commentary and explanation from the FCC regarding the actual rules to
go into effect. The actual rules, six in total, are on pages 89-91 of the document - three of which were importantly stayed
by the Court. The stayed rules were:

§64.6010 (“Cost-Based Rates for Inmate Calling Services”) which states rates must be based on costs
“reasonably and directly related to providing ICS services”;

§64.6020 (“Interim Safe Harbor”) which defines safe harbor rates at which providers are “presumptively in
compliance with §64.6010”; and

§64.6060 (“Annual Reporting and Certification Requirement”) which defines annual reporting requirements as well
as providers’ certification that they are compliant with rules including §64.6010
See full text at https://apps.fcc.gov/edocs_public/attachmatch/FCC-13-113A1.pdf. The Circuit Court’s partial stay is at
https://apps.fcc.gov/edocs_public/attachmatch/DOC-325090A1.pdf.
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Arizona DOC Inmate Telephone System
Submitted: July 31, 2014

 ADDITIONAL INFORMATION

CenturyLink Clarification Response: Page 9 of 9
RFP No. ADOC14-00003887/14-066-24

Arizona DOC Inmate Telephone System
Submitted: July 31, 2014