VRS Stand Alone CA

16 04 2014

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,



Clarification: Neutral Platform & Reference Platform

7 04 2014

Hullo Savvy Readers,


In reviewing past posts on Neutral Platform (NP) I realized further clarification is needed on NP.  


What FCC did was release two separate RFPs (request for proposals):   One for Neutral Video Communication Service Platform (let’s call that “NP”) and one for VRS Access Technology Reference Platform (Reference Platform: “RP”).   


Big Difference!      


Partial modified quote by FCC the RFP on NP:  


The functions provided by the NP include the provision of :

  • a video link, 
  • user registration and validation, 
  • authentication, 
  • authorization, 
  • ACD platform functions, 
  • routing, 
  • call setup, 
  • mapping, 
  • call features (such as call forwarding and video mail), and 
  • such other features and functions.


In other words, RFP wants only the platform itself. FCC wants contract on a company that will develop the mechanism to make the platform to do these listed features.  


Now on partial modified quote by the FCC on RP:


A software product procured by or on behalf of the Commission that provides VRS functionality: 

  • including the ability to make and receive VRS and point-to-point calls, 
  • dial-around functionality, and 
  • the ability to update user registration location, and 
  • against which providers may test their own VRS access technology and
  • platforms for compliance with the Commission's interoperability and portability rules.


In this RP: Basically it seems to mean that FCC wants a software that has video codec that is “standard” and also allow VRS providers to make its own video codec as long as ALL of video products are interoperable with NP and other VRS Providers’s products (if they chose RP over NP).  Meaning, for example: Convo can make its own unique video codec that can only be used for Convo products and Convo VRS and at the same time these same products by using “standard” video codec can communicate with NP and other VRS Providers’s video products that also use “standard” video codec.  Other VRS providers can develop its own video codec to be used only among their video products if they wish.   At the same time ALL video products must use “standard” video codec (developed by RP RFP) to talk with other VRS Providers’s products.   


I hope I make sense.  


Most of VRS providers do NOT support NP, and they DO support RP.   


On the NP if developed and available, VRS providers only have one choice out of two possible options:   


First option: use the NP as provided by FCC. 




Second option: use their own platform (by using RP).    


VRS providers cannot use both at the same time. If use FCC’s NP, VRS providers become glorified interpreter services and give up their own platform.   


If VRS providers provide their own platform (which includes capability to connect with NP), creativity and competition lives on.  This is ideal.  


Sad to say, the catch?   If VRS providers use their own platform, it will have to be on their own cost or minimal allowance of cost to be part of reimbursement rate.  To have its own platform is not cheap and requires R & D and creative people and funds to make high quality products.  With NP, providers are “locked-in” to only what FCC’s NP provides.  FCC wants to push out creativity and innovative ideas by not funding providers who want to develop their own platforms and limit them to what features NP provide.  


RP is good because it allows competition among the VRS providers and they can develop new and better features.  Competition is alive in RP and not so in NP.    


The choice is clear. NP? nope, not good, really a bad idea. Monopolistic! RP? yes, a very good compromise.   Competition is fair for all involved providers.  


VRS industry does not need NP and the industry will do fine with RP only. 


eyes open & thumbs up,




PS:  By the way, some of you may be asking what the heck is Video Codec?   Oh, hard to explain, but basically it is code of logistics that will compress video to language that computer understands and is able to display video.  There are many different ways to compress video codes.   There is a standard video codec called H.264 that many VRS providers use.  There is a special video codec developed or bought or leased by other companies that can be exclusively used by one VRS providers.


David Bahar’s Video Clip on Neutral Platform

24 03 2014



I saw video clip by David Bahar on Neutral Platform and liked what I saw so I asked David for permission to post his video clip. He gave me a hearty go ahead.  So here it is…

For those who do not know sign language, the "CC" will show up once you start the video clip.  I am not sure why it does that, but it is now capioned.     David has good perspective; it is worth viewing.  

eyes open & thumbs up,


Neutral Platform

17 03 2014


On the next few video clips, I will be focusing on two items from VRS Reform. Neutral Video Communications Service, and Stand Alone VRS CA. On this video clip, I will focus on and outline issues for Neutral Video Communications Service and what it means for both industry and VRS Users.

Neutral Video Communications Service (Neutral Platform): this is where the FCC contracts out  as to create a neutral platform; meaning create technical setup which will work with a video codec that will become “standard” called VRS access technology reference platform. This is entirely software platform. The theory is to create a platform that will become standard platform for VRS industry to use. Get this: by either certified VRS providers or Community Interpreting Services (explained further in the next video clip on “Stand Alone VRS CA”}.

If existing certified VRS providers – Convo, ZVRS, Purple, SVRS and other VRS providers – want to use Neutral Platform (NP), they have to give up their own platform, possibly give up their hardware products and use NP if I understand the regulation right. Meaning what VRS Users enjoy with the existing VRS providers and their products will likely be gone if they chose to use NP. According to VRS Reform, VRS providers can “add” features to NP thus be “competitive”.

In other words, VRS providers can still use their products, but they would have to change programming to ensure that they are NP compatible. The FCC already stated they will not pay for these re-programming or pay small portion of that and VRS will have to do it at mostly on their own expense. Changing their existing products to make them NP compatible will cost lot of money. In addition, the FCC said that if any products provided by VRS providers are not NP compatible, they will not reimburse them. Looks like ALL products have to be NP compatible; meaning any better and higher quality video codec cannot be used.

On Reimbursement Rates the FCC will take a good portion of Research and Development expense out of rates on the premise that gov’t provided “standard neutral platform” and that VRS providers can have it at no cost. How can VRS providers develop their own platform and be innovative (Research & Development) without funds (reduced reimbursement rates)? Either they can’t or with great deal of difficulty. ROI (Return of Investment) will be so low that VRS providers may give up providing VRS or change over to Interpreting Services (explained in next video clip).

Current VRS providers are highly competitive and constantly coming up with new features, etc. and the core purpose of current VRS providers to help realize functional equivalence dream to become closer to the full access that hearing persons now have. However, all this will be minimized greatly because not enough funds to be creative and innovative to add features to NP.

VRS Industry, with the FCC discouraging new products and innovations, will decrease over time. Everyone knows any products developed by the federal government takes forever to change over to a new and better technology.

Conclusion? NP and FCC’s reducing reimbursement rates for R&D will eventually force existing VRS providers for economic reason abandon its platform and switch over to NP and become Interpreting Service Providers. Or worst yet get out of business. Or the one with highest call volume will be only one standing??

Bottom line is FCC wants to limit VRS industry to one product with basic features and will not reward those who develop better features because they think standard NP with basic features are all deaf/hh need. Same analogy: Rolls Royce vs Chevrolet and FCC wants us to have Chevrolet not fully realizing that Rolls Royce really is Chevrolet when it comes to Functional Equivalence.

It is a sad day that we all may have to step back to prehistoric thinking of what equality meant; deaf/hh once near to top of the totem pole along with hearing people now dropping down to bottom rungs. Not equals at the top of the totem pole anymore; that will happen if VRS Reforms continue.

eyes open & thumbs up…