“Advanced” Platform

25 09 2014

Hullo Folks,

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,

Ed



Todd Elliott’s Letter to DOJ

11 09 2014

 Hullo Folks,

This is an interesting approach by Todd Elliott (click to the letter below).  Todd has been a valuable contributor to Edsalert as his comments are often thought-provoking.    This letter certainly is no different.    He chose to express concerns of the VRS Reforms – particularly Neutral Platform to the Dept of Justice. 

Excerpts: 

“I want to cover potential unforeseen consequences that may occur for the ‘Neutral Video Communications Service Provider’ (NCP)..”

“I am of the opinion that the NCP will lower the barriers of entry for competitors in the VRS business.”

“While more competition in the VRS industry is welcome, the unintended consequence of such increased competition will be its impact on scarce community interpreting resources.”

“.. and as a result, led to increased costs in using them in public and private settings,
much to the detriment to Deaf consumers.”

The above excerpts refer to making interpreter service providers into certified VRS providers thus taking away interpreters for community interpreting.

“I would like for someone in the Disability Rights Section of the DOJ to consult/collaborate with their peers at the FCC..”

Click to the link to get the full transcript; I recommend you read the transcript:

Todd’s Letter To DOJ

Not too bad an idea, really to get DOJ involved on access in all aspects – telecommunication, and public services and have DOJ and FCC team up (?) to ensure balance of interpreting services for the deaf/hard-of-hearing individuals.   

The core of local interpreting service providers is to provide community interpreting. Todd is saying please be sensitive to community interpreting needs.  He felt that because DOJ is responsible for “access” into regular public services thus should also check out access to community interpreting services.

He felt that if allowing local interpreting services become certified VRS providers, it would cause frauds, problems not unlike when VRS industry had 52 something VRS providers, and greatly reduced number of interpreters available for local interpreting services. 

eyes open & thumbs up,

Ed

PS: Apologies for not having video on this one, but felt text best serve the purpose.  



Regulator Cap

8 09 2014

 

 

Hello Folks,

 

Been quiet a while on Edsalert.    

 

I will do something different on Neutral Platform (NP) and Reference Platform (RP).  I will take off my Convo corporate cap, take off my edsalert advocate cap, and putting “back” on regulator cap as I was a regulator for 19 years with Texas PUC. Keep in mind, regulator can be a person, agency, or department.   

 

Disclaimer: this will focus on general thinking of typical regulator that is interested in saving costs, and how regulator process the order of NP and RP, not a full comprehensive analysis, and my opinion alone.   

 

Obviously understanding Neutral Platform and Reference Platform should be first order of business.   

 

NP and RP are mandates from FCC which were approved by the president-select FCC Commissioners (at the mercy of political party’s wishes).  As a regulator one must follow through, like it or not.  How to go about it is different matter, and often it is up to regulator to decide how procedure should be done.

 

NP is a service that allows VRS providers and Interpreting Services to utilize one-standard NP system to provide VRS, and RP is a video conference software where interoperability is guaranteed among VRS providers by requiring ONE video codec. 

 

As a regulator, the obvious logical step is to first establish RP first.  Why RP first? NP cannot do without RP.  It is like putting wagon front of horse; it should be horse front of wagon so it can pull wagon. In other words, NP (the wagon) needs video conference program (the horse) to make NP a complete project.  

 

So do RP first and then enforce that required RP among VRS providers and their products; disallow ANY proprietary video codec.  Only designated RP video codec to be used.  

 

Now on to NP which basically is to create government-developed Auto Call Distributor (ACD) by outscoring via Request for Proposal procedure.

 

Once NP is created then regulator has to go through process of reviewing, approving, and certifying Interpreter service providers’s proposals and to determine which should be certified as a VRS provider.  To prevent too many VRS providers as in the past; regulator should restrict to a specified number of VRS providers that will be allowed.  Perhaps no more than 5 to be chosen based on the best proposals submitted.   

 

On other hand, if choose no restriction, then if many of the proposals by interpreter groups “met” the rules then regulator would be forced to approve all interpreter groups to be certified as VRS providers. If that happens and as many as could 50 be selected, that will almost guarantee frauds, cheating, etc. not unlike what had happened in the past.  

 

So limitation option will likely be chosen by regulator. 

 

Interpreter groups that got rejected may file lawsuit(s) against FCC as they might feel they met the regulations to the letter.  Regulator likely will risk that anyway as it is much, much harder for a regulator to oversee 56 VRS providers..

 

Role of typical regulator is always to keep the cost low. Regulator likely will think like these following orders: 

 

  • by creating NP, regulator can take out most of the cost of building ACD out of reimbursement rates; 
  • by not certifying interpreters, regulator can force minimal salary of interpreters thus reducing reimbursement rates even lower; 
  • by requiring RP, regulator can take out research & development costs of coding video conference programs out of reimbursement rates;
  • by limiting the number of VRS providers to be certified will ensure low oversight costs for regulator; and   
  • by outscoring marketing for national advertising, regulator can take out most of the marketing costs out of reimbursement rates.

 

Reimbursement rates then will be reduced from all these thus overall cost of VRS will be lower.   

 

That is what I think typical regulator would have done as a regulator.  Remember the disclaimer: this is not a full comprehensive analysis, but give an idea of what regulator might do.  

 

Now taking off the regulator cap, and putting edsalert cap back on, it seems common sense that on paper NP may look good, but make no mistake of the fact that it is a government-run and not based on competitive background.   RP should be done first and that, I suspect, will take care of lot of problems to the point possibility where NP may be deemed unnecessary as problems with interoperability issues did create lot of problems that prompted someone to think up NP.  

 

eyes open & thumbs up,

 

Ed

 

PS: For those who do not know what RP and NP are, please look to edsalert archive on these as they have been explained in depth with several posts.  Other links like DeafNews, NAD, TDI, FCC, and others have explained these as well.

 


Neutral and Reference Platforms Clarification

8 05 2014

Folks,

After getting feedback from FaceBook and emails, etc.   I’ve decided to try again to explain the concept of Neutral Platform (NP) and Reference Platform (RP).  

Let’s focus on ACD first as this term ACD is the key in understanding what NP is.  ACD means Auto Call Distributor.  ACD is the brain/heart of all Call Centers.  Without ACD, VRS cannot be provided.  

So Neutral Platform is an ACD.  Referral Platform is not an ACD.  I think confusion came from the fact both use the term “platform”. 

RP is just a required software specification that requires providers to use to ensure interoperability among the providers. Once video conference software is adopted by the FCC, all existing VRS providers MUST ensure that their proprietary video conference products are interoperable with the required video conference software to ensure interoperability. By the way, government-run NP is required to use the required standard video conference software from RP.

RP is the benchmark test for interoperability.   Pass the RP test, then can provide VRS.  Fail the test, can’t provide VRS.

RP guarantees interoperability.     

More on NP: FCC released Request For Proposal (RFP) that made a list of features to create a Neutral Platform which is an ACD.  Features include: Video Mail; Call Forward; Verification of required procedures such as: address, name, etc; Speed Answer, Security Check, any other desired telecommunication features, etc.

Existing VRS providers ALREADY have ACD as that was a required item to be certified as VRS Providers.  Existing VRS providers already have the features of which current VRS users utilize and enjoy.

The difference between NP and ACD from VRS providers is this:   NP is a government-run ACD whereas ACDs from VRS providers are privately-run.  This is a very important point.  

Stand Alone CA providers can only use NP (ACD); FCC rules will not allow Stand Alone CA providers to have its own proprietary ACD. Existing VRS Providers have two choices: they can use their own proprietary ACD (at their own expense), or change over to government-run NP and give up their proprietary ACD (in other words, become interpreting service provider). 

 

Items:

Neutral Platform

Reference Platform

See # For Further Explanation

Development of Video Conference Software

No

Yes

#1

Creation of ACD

Yes, but restricted to RFP specs

No

#2

#1 Video Conference Software:  Only RP develops video conference software that is “standard” and will be required for all providers to use.  #2 ACD (Auto Call Distributor): NP is an ACD.  Stand Alone CA or VRS providers who chose NP route has to use ACD system from NP. 

Additional notes:

Existing VRS providers ALREADY have ACD (required by original VRS regulation to begin with) and they can choose to keep their own ACDs if they so choose.  

VRS providers who incorporate the required software (RP) into their products can use their own ACDs and can be creative and come up with new features not available by other providers (that’s competitive right there).  But only if the reimbursement rates include reasonable R & D expenses for VRS providers then the competitiveness will be lively.

Can NP providers get new features?  Yes, but remember that any new features added to NP will require complicated government procedures to approve the funds and the decision likely will be a political one. It is a foregone conclusion that federal government processing anything will be slower than snail to get anything approved especially if it entails additional costs.  In other words, once the first new features are approved for NP, then VRS users will see same old features for a long time before any new features become available.

Stand Alone CA providers and VRS providers who chose NP will only become interpreting service providers.  Nice new features offered by existing VRS providers will be GONE or replaced with NP features if they are forced to use NP because that may be the only way for existing VRS providers to make profit. 

The marketing strategy for NP providers likely will be based on “our interpreters are better than theirs” and that’s it.  Because of NP, all features are same by providers who use NP so no sense to advertise that their “features” are better than others.  All are the same for NP providers.

Remember FCC already reduced funds for R & D for new features/products costs on reimbursement rate for existing VRS providers.  That reduction of rate may be a way for FCC to force existing VRS providers to change over to use NP and abandon their own proprietary ACD and any future new features in order to stay afloat financially.  

Possible scenario for NP:  VRS will be run/controlled 100% by government if ALL existing VRS providers change over to NP because of forced economic reasons. VRS could ultimately become a government-run nationalized service. I don’t think we want that.

Again, the choice is clear.  With NP, VRS will go downhill on quality just like the text IP Relay did.  A little bit history here: IP Relay had 4 or 5 providers. FCC started reducing the reimbursement rates, and now there are only 2 IP Relay Providers.   Sprint recently submitted comments that if reimbursement rate continue to be reduced, Sprint will get out of the business as the company said can’t provide quality service with low reimbursement rate.      

Better solution: Remove NP, and keep RP, and ensure reimbursement rate is reasonable then the lively competition will continue and new products/features will keep coming up as fast as the VRS industry can create them.  

Any questions, please feel free to ask.  Feel free to comment as well.   If I made mistake, please point them out.  I will be happy to clarify or correct them. 

eyes open & thumbs up,      

Ed