At its June Open Meeting, the FCC adopted a Further Notice of Proposed Rulemaking (FNPRM) that would transition the toll free intercarrier compensation system to a “bill-and-keep” regime. Under bill-and-keep, interconnecting carriers recover costs from their own subscribers rather than other carriers. The Commission has already adopted a national bill-and-keep framework for intercarrier compensation and implemented a multi-year transition for moving most terminating access charges to bill-and-keep. Currently, however, toll free originating access charges are not subject to bill-and-keep. The FNPRM proposes shifting these charges to bill-and-keep over a three-year period and seeks comment on how such a change would affect consumers, as well as on concerns that the reforms could discourage legitimate toll free calls. Comment and reply deadlines will be announced upon the FNPRM’s publication in the Federal Register, which has not yet occurred.