Folks…
Many of you already have read or heard about the all-important ruling made by the FCC. Basically, the FCC released Further Notice of Proposed Rulemaking on VRS. Now Gentle Readers, this FNPRM has a far-reaching impact not only on VRS industry, but on Deaf/HH who use VRS as well.
VRS FNPRM
Well over 161 pages and not so easy to understand. The FCC started by explaining what VRS is, and then outlined past actions by the FCC on VRS. After setting the base of knowledge, the FCC basically covered these items.
1. Whether broadband affordability could be restricting Deaf/HH from using VRS?
The FCC wishes to explore how Deaf/HH/Deaf Blind and any other disabilities can have access to high speed broadband and be able to afford it. Subsidization or what? Asking for opinion on that.
"..that this broadband affordability barrier may be particularly acute for the deaf and hard of hearing community, such that some people who would benefit from VRS are unable to afford the required broadband Internet access service."
"one commenter observed, a disproportionate number of deaf American adults are unemployed, receive Social Security, live in poverty, or have household income below $20,000; broadband penetration among this community is therefore likely to be lower than the national average of approximately 65%."
And finally this "..we are concerned that the broadband- penetration ceiling may have become a constraint on the availability of the program. We seek information and data from commenters that would help us better analyze whether there is a gap between potential VRS demand and actual VRS subscribership attributable to the expense of broadband Internet access."
2. VRS Access Technology Standards
FCC is concerned that the VRS access technology is not appropriately developed to best meet the needs of Deaf/HH.
"..such as requiring that VRS providers ensure interoperability with competing providers and that the technologies used to access VRS services be portable between providers, the record indicates that these rules, in practice, have met with limited success in two particular areas: ensuring that VRS providers have a real opportunity to compete for other providers’ VRS users, and facilitating VRS users’ access to off-the-shelf VRS access technology."
The FCC is asking the question that the VRS users may not have appropriate access to "off-the-shelf" technology.
The FCC wondered: "..currently available commercial video technology can provide closer functional equivalence, may be less costly, and is likely to improve at a faster pace than the custom devices supplied exclusively by VRS providers, so that the installed base of VRS access technology may be (or may soon become) inferior to “off-the-shelf” offerings."
There is more to this; the FNPRM explores more on this.
3. Compensation Mechanism
The FCC felt that there is a better reimbursement mechanism than the current reimbursement by minutes. The FCC is of the opinion that reimbursement by minutes should be replaced by reimbursing per customer. In other words, the TRS Fund pays based on per customer, instead of per minutes.
There are conditions to that: Deaf/HH can only use one VRS provider and stay with that provider. FCC suggested that perhaps VRS provider can contract out for one year or term agreement.
The FCC puts out significant portion of rulemaking into this. I suggest that you read portion on this; the FCC did its best to convey rationale why per customer reimbursement is better than per minute reimbursement.
Disclaimer: Now I will this time not be neutral and convey my opinions. Be aware I am one of the owners of Convo so take it for what it is. However, those you who know me will know I am most interested in meeting Deaf/HH's needs and to ensure that VRS industry is healthy (after all I invented VRS so want VRS to be right for the Deaf/HH).
On broadband affordability: I do think there is significant number of Deaf/HH who are not able to afford high broadband speeds. What I am not sure how this can be addressed? Should VRS providers identify who cannot afford broadband and then offer to pay for the Internet cost? I think that would open up for frauds, so no go – my opinion. Should a program be set up where Deaf/HH will have to apply to get reimbursement? Who will be responsible for that? Nightmare right there, and possibly bureaucratic headache. I would be interested in knowing what commentators will suggest in the way of solution.
On technology issue: my wish is simple enough which is to ensure ALL video products are able to communicate with each other, and to make that happen, the FCC will need to decide on a video codec and require that to be the standard for all video products. Not unlike the voice for telephone. The FCC is asking until that happens, what should we do in the meantime? I would encourage the FCC at this time to keep the flexibility until the national video standard is adopted.
And, finally this: compensation mechanism. I am adamantly opposed to per customer reimbursement. Let's look at per customer system of other telephone companies. Large telephone companies that employ the model, often have hidden rules such as: cap on broadband usage,and inferior service. Obviously, that is not what we want.
Remember, VRS industry is different that it has human factor: Interpreters which none of other telephone service providers have. Interpreters are paid by the hour which to estimate the cost of interpreters and apply to per customer model is going to be extremely difficult.
VRS providers work very hard to make their product superior to other competitors because they want Deaf/HH to use VRS. Now with per customer reimbursement model and if VRS providers create superior video products causes the Deaf/HH to use VRS more, it will be losing money for VRS providers. So basically the more Deaf/HH use VRS and if per customer reimbursement is used, VRS providers will lose money. So VRS providers may not be motivated to create superior products.
With per account reimbursement, VRS industry may not pay attention to the Deaf/HH VRS users in business or government because they are considered high-end users thus are expensive.
Reimbursement by minutes model works just fine. The FCC already have set in motion lot of regulations to minimize frauds, and that should carry over just fine. With existing per minute reimbursement, we see VRS industry fiercely fighting for VRS users and offering many video products and very nice array of features. With per customer reimbursement model, we may not see these.
It seems to me, Gentle Readers, there can only be one logical and practical solution; keep the reimbursement by the minute model.
Tell me if you agree or disagree with me.
eyes open & thumbs up,
Ed Bosson
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