Stand Alone VRS CA
In the past posts, I focused on Neutral Platform; that is, NP is a government-developed platform that has all the “features” and is available for free for any VRS providers and any interpreting service that wants to turn their services into Stand Alone VRS CA. In this post, I want to focus on Stand Alone VRS CA. What is “CA”? That is Communication Assistant which in this case, same as interpreter in relay environment.
Stand Alone VRS Ca basically means any interpreter service provider can apply to the FCC for certification as Stand Alone VRS CA provider. The catch? Have to use/download government-developed Neutral Platform and become “VRS provider”.
For example, Texas has like 30 to 40 Interpreter Services so theoretically all of them can become Stand Alone VRS CA providers to say nothing of hundreds if not thousands of interpreter services providers nationwide that can apply.
Can you imagine maybe 50 or more applications from Interpreter Services nationwide and that FCC has to review them? Of course, those who applied will have to meet the FCC certification requirements, but it will not be the same strict rules as what certified VRS providers had to go through as VRS Stand Alone CA providers are not allowed to have their own video conference, and they just only have to download the one that government created. So that’s a freebie for interpreting service providers. Remember existing VRS providers spent million of dollars developing their own unique platforms which VRS users now enjoy.
Anyway this Stand Alone VRS CA is basically opening up same can of worms all over again and allowing Interpreter providers join in becoming VRS providers, but with much less stringent cost requirements: just download from NP at no cost.
FCC just went through whittling down VRS providers from 52 down to 6 providers. I generally support that as VRS providers need to meet highest possible standard VRS regulations. However, with this allowance of Interpreter services tag on to NP will cause increased number of VRS providers. FCC will have lot more on its headache in monitoring all these and will less likely catch criminal actions (just like they missed a quite a few with the old 52 VRS providers). Same thing will happen with Stand Alone VRS CA if there are too many of them.
At any rate, it does make me wonder if FCC is discriminating against deaf/hh and allowing services run mostly by hearing persons become VRS providers. These old 52 VRS providers, I believe, majority of them were either deaf-owned or deaf-run and they were cut off by the FCC. Most of interpreting services are run by hearing persons and the FCC will allow these to become “VRS providers”.
FCC could have found ways to allow deaf-owned VRS providers to continue somehow perhaps by modifying regulation; FCC did not do that, but the FCC sure did for interpreting service providers. Perhaps the FCC is profiling to the extreme based on past bad experience? hmmm Based on the logic in this paragraph, it appears the FCC is discriminating against the deaf/hh.
Another issue: The FCC will not require certification of Interpreters simply because they knew it would raise reimbursement rates. I would be very interested how the FCC team will evaluate quality of interpreters without requiring certification? More likely the FCC will say “let the VRS Users decide which of the Stand Alone VRS CA offer high quality interpreters”. Wow, if that being the case, deaf/hh will have a frustrating of time finding a good quality service provider if there are many of them out there; makes me wonder if the FCC really cares for VRS users anymore? They used to. I guess nowadays cost is the bottom line for the bureaucratic and political FCC staff.
Current VRS providers do have their own unique evaluation procedures for hiring interpreters simply because VRS is different than regular community interpreting. These Research & Development in understanding VRS interpreting environments costs hundred thousands of dollars. At any rate, without having R&D which requires lot of money and the FCC will not subsidize that, Stand Alone VRS CA providers may have some difficulty adjusting to that.
It is very likely that the Stand Alone VRS CA providers will be paid at a much lower rate than VRS providers. Although FCC says that it will continue to support VRS providers so that deaf people can still use their products and services, but we know that over long run, hearing controlled economics will put pressure on phasing out VRS providers for cheaper Stand Alone VRS CA. How will FCC do that? By removing the outreach, R&D, marketing and the cost of interpreters (at decent salaries) expenses out of reimbursement rates, FCC is effectively forcing the current VRS providers to either get out or take on the standard Neutral Platform and provide inferior services.
Bottom line is that NP, FCC’s restricting guidelines, and reducing reimbursements will force all VRS providers to become Interpreting agencies. Existing VRS providers may be forced to jump to NP, abandon their platforms, and just become interpreting services and lose all the wonderful features existing VRS providers now offer. Switching to NP platform will offer inferior services.
This is not idle threat. Possible of that happening is real.
Once again, the FCC failed to understand tremendous economic benefits from high quality VRS providers.
Is that the path towards Functional Equivalence? I think NOT..hmm.. I take it back I know NOT.
eyes open & thumbs up,
Categories : Alerts, FCC Issues, Vlogs, VRS