oll-free (800-888) number that belongs to another carrier's subscriber. - A person places a VoIP call to a toll-free number connected to some- one on the PSTN. Terminating access fees. - A person whose phone is connected to the PSTN calls someone on another carrier's network. - A person places a VoIP call to someone on the PSTN. Access fees paid to carriers in rural, high-cost areas are set higher than those in urban areas. Moreover, intrastate access fees, which are set by states, are generally higher than interstate access fees. Access fee rates for local calls are minimal. Most Competition, Industry Structures, and Regulations large carriers don't bill one another for local calls. They use a bill and keep method SO that administrative billing efforts are eliminated. Instead, they assume that any differ- ences are made up by revenue from subscribers. Disputes Involving ICC Fees Despite rules governing access fee rates, telephone companies employ entire depart- ments to analyze and settle access fee disputes. The primary cause of disagreements is that it is often difficult to determine where traffic originated and how it should be rated, solely based on call records. The increased use of VoIP applications such as Skype cell phones compounds these complexities. There are no agreements as to whether VoIP calls to people on the PSTN should be rated as interstate, intrastate, or local, because VoIP calls do not carry location-identifying information. A major point of contention is traffic from providers of free conference services, chat lines, and adult entertainment services. Companies that provide these services often game the system through schemes known as traffic pumping and access stimula- tion. These providers often install telephone switches in rural or hard-to-cable areas with high access fees. They register as telephone companies to earn revenue from high access fees paid by carriers whose customers make free conference calls. Some carri- ers refuse to pay access fees to known traffic pumpers. If the parti