Ed’s Telecom Alert

Folks,

A quickie one.

From Representative Kenny Marchant, R-Texas.  He basically wanted the FCC to understand the value of VRS for deaf community.

Marchant

And FCC responded with this letter:

FCC Letter

FCC representative basically said that VRS will be maintained.   

Reason I posted that in edsalert is simply because it looked like someone contacted Marchant and expressed concern of VRS being closed down. (VRS won't be closed down regardless, though.)

So it pays to let your congress folks know of your concerns so they will know and try to represent you by contacting appropriate persons.  As always, the more "appropriate" individuals are made aware of the issues, the more likely the issues will be protected.   It is your right to be heard and best way to do that is to contact your congress people and let them know.

eyes open & thumbs up,

Ed 

Folks,

I've decided to take a different approach on this post.   There will be no text in this one (future ones will continue to have text).  

Enjoy the video clip and please feel free to comment on the VRS Rates.  

eyes open & thumbs up,

Ed Bosson

PS: for those who do not know sign language; captioning is available now. 

Folks,

At one period in the past when people see VRS reimbursement rates above $7 per minute (not anymore now), naturally they want to get into the VRS business. So up to 52 VRS providers – majority were white label providers – were formed.  

Unfortunately, with so many VRS providers and the difficulty of oversight by the FCC for so many providers, frauds were likely to happen and they did happen.  So the FCC, DOJ, and FBI got into act and arrested quite a few of them.  

The FCC upon realizing the flexibility (in other words, too many loopholes that nefarious individuals/providers took advantage of) of the VRS regulations was that caused the frauds so the FCC had to start constricting the VRS regulations to ensure that the regulations are followed by all VRS providers (both white label and certified).   Sure enough, number of VRS providers were whittled down to 9 VRS providers:  Convo, ZVRS, SVRS, Purple, SnapVRS, HealincVRS, GraciasVRS, CAAG, and Lifelink.  HealincVRS and ZVRS had quite a few subcontracts. Viable's infrastructure was taken over by Snap!VRS after Viable itself went out of business following the FBI raids.  

All of these 9 VRS went through fine-tooth comb review and investigation by the FCC which subsequently narrowed number of VRS providers down to 6 VRS providers:  Convo, ZVRS, SVRS, Purple, GraciasVRS and CAAG.  Purple recently bought the Healinc along with its other purchased VRS providers.

By this time, VRS providers still in business; those providers who do not have more than 1 million minutes a month (so far only one) realized that VRS is not a "lucrative" business.  

Anyway, many folks ask me who owns these VRS providers? The following comments should give you an insight.  

• Convo is mostly deaf-owned (a few percentages to hearing) and deaf-operated and its management team link;

http://convorelay.com/company.html

• ZVRS is venture-capital (VC) owned with 20% to CSD/Ben Soukup and mostly hearing-managed and its link to management team;

http://www.zvrs.com/about-us/our-family/management-team; 

• SVRS is VC owned and hearing managed with one senior deaf manager and the link to management link: 

http://www.sorensonvrs.com/corporate_leadership

• Purple is VC owned 97%  and with rest of % to executives, and mostly hearing managed and its link to management team:

http://purple.us/leadership;

• GraciasVRS is interpreter owned, and hearing managed and no link to management team; 

• and finally this CAAG is interpreter owned, and hearing managed with one deaf manager (the deaf pix not on management team) and its management team link. 

http://caag4.com/index.php/come-in/bios/

So there are now 6 VRS certified providers; all still need to undergo further review by the FCC before final certification. However, my personal opinion is as we're so far down the road for having met the regulations so far, these listed VRS providers are for practical purposes VRS certified infinitely. 

So what about other VRS providers that have VRS certification like these providers? AmericanVRS and HawkVRS?  They are not providing service and if they do not come up with VRS plan to the FCC by the time of renewal, they will lose the VRS certification. AmericanVRS simply closed down. Others who had certification were taken over by other VRS providers. 

The summary is now:  one deaf-owned, two interpreter-owned and three VC-owned making total of 6 VRS providers now.

eyes open & thumbs up,

Ed

Postscript: For those who are curious about history of relay rates, here is the link:

http://www.r-l-s-a.com/TRS/RELAYRATESHISTORY.pdf

Double Postscript:  All these information are based on websites that I have googled plus talking with several individuals.  If you believe I erred, then comment away.  

Folks,

This is a thought-provoking comment by Karen Graham; check the link out.

KAREN GRAHAM THOUGHTS

Karen basically offered thoughts on new and much stricter VRS regulations and indicated who the victims may be as result of that.  

I consider Karen a good friend even though we've not had the length of time to call it "old friend". Nevertheless, we have a mutual respect for each other.   That said, I do have different perspective as compared to hers. I was fortunate for having worked in government in Texas for 20 years, and then as a co-owner of Convo that I have insight into both worlds.  

First, let me cite quotable comments from Karen's article. 

"The intent of the rule was to root out fraud and make VRS a more manageable industry for the federal government. Did their action lessen the probability of VRS companies acting in a fraudulent manner? Most importantly, are Deaf people receiving better service now than they were a year ago? How did the great VRS shake-up shake out?"

Good question!

Keep in mind Karen along with her partners owned Interpreting Service (SignOn) and did subcontract with a few VRS providers.   As you all know the FCC regulations do not permit subcontracts.  

"SignOn doesn’t exist in its original form any longer. In my case, I lost a livelihood. I’ve moved into a different field altogether and the days of monitoring the FCC announcements are a thing of the past."

"But some actors in this drama, like myself, were plumb out of luck – and out of work."

"One VRS provider who proceeded with certification suggested that the strictness of the rules was a challenge and perhaps limiting to efficient business operations. Requiring interpreters to be staff is often difficult in a freelance-oriented industry. Trying to discern the meaning of regulations, the increase in costs, and the impact on cash flow were some other concerns."

I acknowledge of "trying to discern the meaning of regulations.." as being tough one.  The much new stricter regulations for VRS is indeed complicated. As a co-owner of a VRS provider, we've had to hire a lawyer who is very familiar with the FCC and VRS regulations to ensure that the company is in compliance with the FCC VRS regulations.   I can readily tell you that it was one big reason why Convo became certified. 

"Some interpreters, not liking elements of work with the bigger VRS companies (e.g. scheduling, strictness in operations) have left VRS altogether. Some of the interpreters, who had no intention of becoming freelance-only interpreters, were propelled into the freelance world by necessity. Others just needed this push to move on to full-time freelance work, something they had been considering anyway."

" In my view, interpreters felt that they followed the FCC guidelines prior to the rule change and that they were no more conscientious and ethical than they were before the change."

" It appears as if the shift in balance moved some of the more experienced interpreters back to community freelance work as their primary source of income.  If so, how has that changed the quality of interpreting both in the community and in VRS?"

Finally these conclusions by Karen:

"In my opinion the changes haven’t necessarily helped."

"Perhaps the rule has eliminated fraud (has it?), which was its original intent, but many exemplary, law-abiding stakeholders became unintended victims."

All these are valid concerns and Karen has every right to pose her concerns.   

My perspective is simple enough which is that it was not the FCC who created these stricter rules; it was the nefarious and greedy individuals who forced the FCC to create a much stricter set of VRS regulations.  The frauds amounted to many millions of dollars and the FCC had to take action to prevent further pilfering of the federal funds.  

Also, oversight by the FCC was impossible with 50 plus VRS providers, but now with only 6 VRS providers with "ownership" clearly defined, the FCC can be assured of quality oversight to ensure that VRS providers meet the rules.  As matter of fact, the FCC recently did pay visit to all certified providers and examined their books, reviewed their interpreting training, and all that.   That will assure that the VRS industry will be in compliance with the federal rules and prevent further frauds.  

That said, I do admit that there are good and honest individuals and a few companies who are ethical got hurt by the stricter rules.  My point is that it is not the fault of the FCC for that, it is the nefarious and greedy individuals that caused all the problems.  

So what will the future be like?   I think that down the future, there will be opportunities to improve the regulations as to be more fair, but that only will happen if the FCC is satisfied with the integrity of the VRS industry; that may take a while. 

So tell me, Gentle Readers, what do you think?   Do you think FCC did wrong or what?  Let us know.   

eyes open & thumbs up,

Ed Bosson

Long Link: http://www.streetleverage.com/2012/10/sign-language-interpreters-the-unintended-victims-of-vrs-regulation-change/