Ed’s Telecom Alert

All..

I got a private email asking me if there is any circumstance that I would support VRS working from home.  Also, a few private emails that don’t I trust interpreters?  Let’s think on it. The issue is about ironclad confidentiality and this must be met; it is not enough to say "I trust this person".  Trust has nothing to do with that.   I trust most, if not nearly all interpreters and I know they cede to code of ethics very well.  Then what is the problem?  It has to do with reasonable doubt.   So the question begs on how to remove the reasonable doubt?  

If done from home; then it would need to be a room with one door. The room would need to be soundproofed as well so family or dogs won’t react to noises by video interpreter.   Perhaps a cubicle within the room.  There would need to be at least two remote camera that is locked to two sites and "on" all the time; one to video interpreter so the quality assurance control can be maintained remotely if needed and one to the door to ensure no one comes in and out and can be viewed remotely by HQ.      

There would need to be a software program or some kind of foolproof system set up where if need to get support from the HQ. For example, to replace video interpreter (time up or get tired or something), or to provide support.     Emergency procedure needs to be well thought out to maximize the speed of processing an emergency call. 

Would I go for that?   My answer is only if the interpreter pool is at VERY critical point.   I do not think we’ve gotten there yet, and I think there are other viable solutions that are better met – such as sharing of pool of terps by a few VRS providers, or even VRS providers working with other VRS providers in utilizing their pool of terps, etc.  

Comments, anyone?

eyes open & thumbs up,

Ed

All..

This alert is really an ongoing issue that crops up from time to time since Day 1 (1995).   Recently, I was asked by an interpreter who was doing research on VRS regulations.  One question was whether a video interpreter for VRS is allowed to interpret from his/her home or not.   

Here are my thoughts (my interpretation of the federal relay regulations), and the I will follow up on one conversation I had with a VRS provider, LifeLink, regarding this issue. 

I believe that the Video Interpreters from VRS should NOT be permitted to interpret from one’s home is based on TRS rule on Confidentiality and Conversation Content.  Meaning that the VRS provider MUST be able to prove the confidentiality of VI; the logical question follows is how?  Work environment has to be controlled, monitored, and be within an enclosed location with security tools in place.  Only way to do that is from within an enclosed system such as a VRS center where all VIs congregate and work in with controlled and monitored system where there is a supervisor and, possibly, security guard in place to ensure that confidentiality rule is followed; i.e. not allow anyone enter VI’s working environments. 

A possible scenario of abuse if done from home is that if from home, maybe a  husband or wife or a good friend will watch the VI doing interpreting.  It is not enough to say VI has  highest code of ethics that they won’t do that. Maybe an abusive husband insist on watching wife do the work and wife (VI) is powerless to stop that.  Many possible problems if done from home. 

Additionally, we deafies want to be assured that VI is not being viewed by someone off the monitor viewing.  Only in a  controlled environment, are we assured of that. I would go on record, any VRS providers that allow VI be interpreted from home, I will not use that VRS.   Most deaf that I know if they know VRS is from home environment, will not use the service, either.       

Keep in mind that there is no rule from the federal relay regulations that actually says "Video Interpreter  cannot work from home".   It is based on the context of the  rule that defines what is allowable and not allowable (as interpreted by the decision makers or VRS providers or lawyers).   (Note: perhaps that is where the FCC should do a clarification on this.)  
 
A few of VRI (video remote  interpreting) do work from home.   VRI is not subsidized by the federal funds thus not obliged to follow federal relay regulations. This is different and usually the deaf person knows with full knowledge that this was from interpreter’s home.  VRI is paid by the deaf or the called party. 

To my knowledge, I think that only one VRS provider allows its VIs to work from home; I believe that is LifeLink.  Best way to get facts is to call direct and pop the question.  So an interpreter coordinator from LifeLink and I video chatted.   I explained that this conversation will be summarized and posted in edsalert. 

And so I popped the question.  Answer was something like that: the HQ is in NY and that there are different office locations (not in HQ) that VI use to provide VRS work.  I asked and repeatedly asked are these office locations at home, she never responded that they were from home – instead said they are from "office locations".  That the offices are adequately protected and that highest possible confidentiality safeguards are in place.  She could have said, "No, they were not from home" and she didn’t.   It also became apparent without her telling me so that there is only one VI per office.   Assumptions are dangerous, but it seems to be that this evasive action seem to indicate that the company knew that many deaf will not use VRS if they do it from home. 

Why do the company do that?  Saves oodles of $$$ which is understandable.  

If any info posted here is not right, please feel free to say so.  I will not block comments regarding that.   I would love to hear from LifeLinks on this issue and the company can clarify the issue.   I could be completely be wrong and would not mind being wrong if the company has more factual info to share with us all to prove that VRS calls are indeed at highest possible confidentiality level.  Just say so won’t be as convincingly persuasive as additional details.  

Finally, Gentle Alert Readers who use VRS, I would love to hear from you.  Would you object to using VRS if VI did it from home?  I know a few deaf would not mind and I also know a few who would mind.  Let me hear from you…

eyes open & thumbs up,

Ed

All..

It seems that the VRS/VRI in England ended because of lack of funds.  They had been depending on charity to process VRS calls, but the charity funds have run out.   They call VRS "SignTalk".

VRS Ends In England

Comments made by UK folks clearly showed how valuable SignTalk had been.  

I sincerely hope that UK Government will take action and help these UK deaf folks get their VRS up and running.  

eyes open & thumbs up,

Ed

All..

Six highly influental organizations got together and submitted a Reply Comments to the VRS Rates that the FCC released not too long time ago.  These six organizations are: TDI, NAD, CCASDHH, HLAA, and ALDA (if you want to know who they are, click the link). 

Nat’l Orgs Responds to VRS Rates

Basically they are saying freeze the reimbursement rate of VRS until a better mousetrap of methodology of figuring out the cost can be made.  Here are some of the reasons why:

• freeze the rates until all issues of figuring out fair reimbursement rates are made
• felt the current computing of reimbursement rates are flawed
• Interstate TRS Fund Council should assume more evaluation responsibility; i.e. be able to review proprietary data and cost breakdowns so they can appropriately advise Commission
• that reimbursement rates cover all reasonable costs including outreach/marketing of generic and brand names as well as R&D to enhance VRS
• at the same time, not to hand in a blank check to VRS providers

These are valid concerns. 

Note of information.  Only the NECA and the FCC know the actual cost breakdowns.  The Interstate TRS Fund Council are not privileged to see such important cost breakdowns.    Also, only the VRS providers provide the cost breakdown to the NECA/FCC.  

All the hulaboo was from VRS providers complaining of the reimbursement rates being reduced so apparently these organizations VRS users listened to the VRS providers and wrote these comments.   I wanted this point to be clear to the Alert Readers.  It was not from the actual review of cost breakdowns that the organizations determined the methodology was flawed. It was from VRS Providers saying so. 

That said, I do, however, agree VERY STRONGLY that the Interstate TRS Fund Council be given authority to review proprietary data.   I’ve been member of this Council for many years and often wished for that.   It would help the Council be in position to advise Commission more articulately.

eyes open & thumbs up,

Ed
RT Admin.