Testing an operational support system (OSS) of an incumbent provider for compliance with a regulatory scheme

A method for testing one or more operational support systems (OSSS) of an incumbent provider for compliance with a regulatory scheme, the method performed by an independent testing entity attempting to emulate a competitive provider that would access the OSSs in attempting to compete with the incumbent provider in an open market, the method comprising for each test of an OSS:

• conducting active testing of the OSS for the test according to a written detailed test plan for the test;
• evaluating performance of the incumbent provider during active testing according to predetermined evaluation criteria for the test;
• generating a written exception for each aspect of the test for which the testing entity determines during active testing that the incumbent provider fails to satisfy one or more applicable evaluation criteria, the exception describing such failure and the potential impact of the failure on competitive providers that would access the OSS in attempting to compete with the incumbent provider in an open market;
• for each exception, conducting an exception resolution process comprising:
• recording the exception in a master list of exceptions maintained in a computer-implemented centralized repository established for comprehensive cataloging, tracking, and reporting of exceptions across multiple tests, test domains, and jurisdications, the master list of exceptions comprising an exception identifier for each exception and a status of each exception, the status for the exception being updated as appropriate during the exception resolution process;
• submitting the exception to the incumbent provider for review, the exception submitted to the incumbent provider being considered a draft exception, the exception having a draft status in the master list of exceptions;
• receiving a written response to the draft exception from the incumbent provider challenging the draft exception on one or more factual bases;
• determining in cooperation with a regulatory entity administering the regulatory scheme that the draft exception should not be withdrawn, the draft exception being considered an open exception in response to the determination that the draft exception should not be withdrawn, the exception having an open status in the master list of exceptions;
• receiving a written response to the open exception from the incumbent provider describing one or more planned corrective activities of the incumbent provider to remediate the associated failure;
• subsequent to the corrective activities being performed, conducting additional active testing of the OSS according to the detailed test plan with respect to the corresponding aspect of the test;
• evaluating performance of the incumbent provider during the additional active testing according to applicable evaluation criteria;
• if the open exception is cleared, based on the testing entity determining in cooperation with the regulatory entity that the incumbent provider has satisfied applicable evaluation criteria during the additional active testing, generating a written closure statement for the open exception, the open exception being considered a closed exception in response to generation of the closure statement, the exception having a closed status in the master list of exceptions;
• and
• if the open exception is not cleared, based on the testing entity determining in cooperation with the regulatory entity that the incumbent provider has again failed to satisfy applicable evaluation criteria during the additional active testing, repeating the submitting, receiving, conducting, and evaluating steps until either the open exception is cleared or a predetermined time period for the test has elapsed;
• generating test results for the test;
• and
• issuing a final report for the test providing a sufficient basis for the regulatory entity to determine the compliance of the incumbent provider with the regulatory scheme.

A system used in connection with testing one or more operational support systems (OSSs) of an incumbent provider by an independent testing entity for compliance with a regulatory scheme, the testing entity attempting to emulate a competitive provider that would access the OSSs in attempting to compete with the incumbent provider in an open market, the system operating on one or more computer systems at one or more locations and comprising:

• a centralized repository supporting comprehensive cataloging, tracking, and reporting of exceptions across multiple tests, test domains, and jurisdictions, the centralized repository maintaining a master list of exceptions comprising an exception identifier for each exception and a status of each exception, the status for each exception being updated as appropriate during an exception resolution process, at least one exception:
• having been generated for a test in response to the testing entity determining, during active testing of the OSS for the test according to a written detailed test plan for the test, that the incumbent provider failed to satisfy a predetermined evaluation criterion for the test;
• describing such failure and the potential impact of the failure on competitive providers that would access the OSS in attempting to compete with the incumbent provider in an open market;
• having been recorded in the master list of exceptions;
• having been submitted to the incumbent provider for review as a draft exception having a draft status in the master list of exceptions;
• having been allowed to proceed as an open exception having an open status in the master list of exceptions in response to the testing entity receiving a written response to the draft exception from the incumbent provider challenging the draft exception on one or more factual bases and the testing entity determining in cooperation with a regulatory entity administering the regulatory scheme that the draft exception should not be withdrawn;
• and
• having been designated as a closed exception having a closed status in the master list of exceptions in response to the testing entity receiving a written response to the open exception from the incumbent provider describing one or more planned corrective activities of the incumbent provider to remediate the associated failure, the testing entity conducting additional active testing of the OSS according to the detailed test plan with respect to the corresponding aspect of the test subsequent to the corrective activities being performed, the testing entity evaluating performance of the incumbent provider during the additional active testing according to the evaluation criterion, the testing entity clearing the exception based on the testing entity determining in cooperation with the regulatory entity that the incumbent provider has satisfied the evaluation criterion during the additional active testing, and the testing entity generating a written closure statement for the exception;
• and
• a web server operable to make the master list of exceptions accessible to a plurality of interested parties in the form of Hypertext Markup Language (HTML) pages communicated to the interested parties from the web server.