FCC now calls Neutral Platform with this new term “Advanced Platform”. As one person commented, to have a better lipstick, but nonetheless with same lip. ;-] So will call it ADV. I have been wondering about what if ADV finally get onboard, what are the consequences of that for VRS providers?
Before I delve into the consequences, let’s assume that this is how the scenario will play out. I have asked several experts on that and I got two different possible answers; the following thoughts are best guess scenarios. The reason for two different scenarios is that FCC has yet to spell out specifics for the ADV system. Keep in mind AFC will be offered to existing VRS providers to use, and if chosen they have to give up their million dollar ACD.
One possible scenario:
FCC contracts to one service/company to provide ADV and let’s call it Contracted ADV Provider (CADV). Only one-single contracted gov’t-run provider subbing labor out to multiple call centers (possible interpreter service providers) or any available interpreters throughout the USA. CADV could be competing against existing 6 VRS providers.
VRS industry could have CADV, and 6 VRS providers for total of 7 providers.
Second possible scenario:
There will be just one CADV provider as a prototype and FCC will let that continue for maybe a year to see how this works out.
Also, at this point ADV may be offered to existing certified VRS provider and any interpreting service providers anywhere in the USA – providing they submit proposals to show that they can meet 24/7, and ASA regulations. If the FCC accepts these proposals, they will be certified as ADV VRS provider (my guess on branding).
The first contracted CADV provider likely will remain. VRS industry could have: CADV, ADV VRS providers (could be a few or 50), and 6 current VRS provider. Total? Unknown.
Now the possible consequences:
During these before, during and afterwards test periods, reimbursement rates will gradually be reduced down to the rates that the FCC along with removal of various competitive tools that FCC felt are unnecessary because existing features of ADV that “will do the same thing”. Reimbursement rates will be reduced as result. It is important to note with new regulation, all VRS providers will be reimbursed only if they are providing labor (interpreting service) that meets 24/7 and ASA regs. Reducing reimbursement rates already have started15 months ago and will continue every 6 months for 3 more years.
The 6 current Certified VRS Providers will have difficult task of deciding on three options, whether to:
- keep their own million-dollar ACD or
- use free ADV or
- get out of business altogether.
If they chose to keep their own ACD, lot of expenses for upkeep and maintenance of ACD that were previously subsidized by reimbursement rates now will be mostly absorbed by providers.
Existing VRS providers also will have to decide how much of marketing costs they can do as most of their previous marketing costs were included in reimbursement rates, so now they will have to absorb these costs almost entirely.
Research and development of new features and products in the past were partly included in reimbursement rates now will no longer be subsidized or the very least greatly minimized thus certified VRS providers will also have to absorb most of the costs as well.
If existing VRS providers decide to go for ADV, they would have to lay off many positions as these positions are no longer supported by reduced reimbursement rates. Most of the layoffs will impact deaf/hard-of-hearing staff.
Because of the system of ADV and reduced reimbursement rates, there would be minimal incentives for either ADV VRS providers or existing certified VRS provider to come up with new product or features.
Providers relying on the reimbursement rates that are solely based on interpreting labor will have no or little incentive to come out with new features or products unless the FCC decides new features/products are worth spending extra money on (in other words, must get permission from the Commissioners, and release public notices before they are approved. We all know how long these take).
The salaries of VRS interpreters likely will need to be renegotiated to a lower income as reduced reimbursement rates will no longer support reasonable salaries of interpreters. Providers likely will try to hire less qualified interpreters to ensure affordability.
Because of the reducing reimbursement rates and absorbing the expenses of running VRS business, existing certified VRS provider(s) may altogether get out of business because the the profit is either non-existent or so small that not worth continuing the business. For example there were 6 or 7 IP Relay providers, now there are only 2 and even then both are thinking of getting out of business. Reason? No or very little profit and/or very high penalty fee.
Another possibility with second scenario: there may be 50 ADV VRS providers added to the VRS industry which will hurt the community interpreting service, and increase number of possible frauds as local interpreting service providers will focus on their local population and may encourage them via incentives (they may or may not be illegal) to use their services. To say nothing of creative frauds that may ensue and it will be extremely difficult for FCC to monitor all these.
Summarization: no matter what flavor ADV will be in, there will be negative consequences that will impact on deaf/HH and VRS industry.
eyes open & thumbs up,
Categories : Alerts, FCC Issues, VRS