Ed’s Telecom Alert

All..

Seems the FCC granted nunc pro tunc petitions dating back to previous date to a group of hearing aid companies.    Nunc Pro Tunc means although the deadline was already past, and due to unforseeable circumstances, the FCC would allow retroactive to the past date the petition request for waiver. This is to "bypass" the penalty that could be assessed to the hearing aid company that failed to meet the required ruling by the FCC (the last sentence is my assumption - so I could be wrong).    Rest of the Memo/Order is above my head and I do not understand what they are about.  Presumably those of you who do wear hearing aids prob will be able to understand what this is about.   

Hearing Aid FCC Memo and Order

eyes open & thumbs up,

Ed B.
RT Admin.

All..

Thanks to a listserve that shared this article; I figured y’all will find this article revealing.  Click to this very intriguing article.  It impacts deaf as well.   I’ve used VRS to call a company just to find out where I can mail a product to for repairs only to get a never-ending voice prompts to get to where I want.  I thought "ridiculous!"    I know many of you can attest to this as well. 

Voice

Amusing albeit a bit disturbing and makes Deaf wonder where will this lead to for persons who depend on visual aids?  Click and read on.  

eyes open & thumbs up,

Ed B.
RT Admin.

All..

Happy Thanksgiving Holiday! 

Wow - this is a MUST reading of the FCC’s latest report, order and declaratory ruling as it will impact VRS providers as well as some of the consumers.   

I will try to summarize this, basically it is about how relay providers - VRS, IP Relay, traditional TTY Relay, Speech to speech, and Captioning Telephone Service - are paid in a different way.   The FCC also had declaratory ruling which means it outlines rules what VRS providers can do and cannot do.   

If u want the gritty details, click. 

Latest FCC report, order, and Declaratory Ruling

Here is my brief summarization of the FCC stuff.

I will start with Declaratory Ruling first because it impacts VRS users, organizations, and VRS providers. 

Please bear in mind this is not a NEW rule; it is based on past ruling that the FCC felt need to clarify.  The following declarations are:

• Relay providers may NOT offer consumer financial or other incentives (i.e. rewards) - directly or indirectly - to make relay calls.   Examples: sweepstakes that encourage VRS user to call particular VRS provider; that is not allowed.
• That use of customer call base or database by VRS providers to contact relay users for political or marketing practices are not allowed.  What this means is that VRS providers cannot use VRS user’s information to contact VRS users for political or improper marketing practices.  Example of that is by deploying an email message, postcards, etc. to inform them about pending TRS compensation issues and urge them to contact the Commission about the compensation rates.  This is not allowed. 
• Track relay user’s usage and then determine if person should get a new video phone or upgrade. this is not allowed. 
• Impermissable VRS marketing practices such as "use this VRS or you will not get upgrades" or "to get this video phone, you must use our VRS" or "if you want to keep the video phone, you must use VRS".  All these are not allowed. 
• Sponsorship that are tied to service usage. Examples of that is state association or local deaf club or alumni club having a contract to receive financial incentives (like 25 cents per min or something like that). These are not allowed. 
• Charitable contributions by a provider based on total calls made. 
• Charitable contributions/gifts/payment by a provider based on "failure of a call to meet specific time" (in other words, long wait) - a contribution will be made to a third party organization.  This is not allowed. 
• By registering with a provider and become its "VIP" customer and receive reward or financial incentive. This is not allowed. 
• Providers cannot give relay users equipment (i.e. video phone or pagers) as part of outreach efforts or for other purpose, and then seeing lack of use of the provider, get back the equipment. 

Why did the FCC decide to do these?    The Title IV of the ADA indicate (according to the FCC) that relay providers are intended to be "dial tone"; in other words, provide telephone service.  Also, relay users do not pay for the service, the federal funds do.   It is not same as hearing person who pays for the service.  For example, pay $60 for 1200 minutes, and if beyond that, then person has to pay additional fees.  There are no obligation on relay user to watch their usage therefore the FCC does not want any unnecessary minutes that may be logged and billed to the federal fund.   Click to the link, you will read additional details on this. 

Now to this new issue.  Before I go into this, it is worthy to note that the Fund for relay service has grown from approx $40 million in 2000 to over $550 million for FY 2007.   Out of that $550, $430 Million is from VRS.   This means about 75%.  Whew….

Now there is a new cost recovery methodology for TTY relay service including Speech-to-Speech which is called "MARS" plan (Multi-State Average Rate Structure).   This methodology simply is use state data to determine the reimbursable rate.   The FCC will collect all costs of relay service of all states, and also collect all minutes generated from each states, then calculate a weighted average rate by dividing total state dollars paid by total conversation minutes. 

Based on MARS, interstate TTY relay service, the reimbursement rate is $1.59 per conversation minute.  This is interesting.  Remember this is interstate relay service.   In Texas, our reimbursement rate is $1.29 per conversation minute. 

MARS gave interstate Speech-to-Speech $1.59 plus $1.13 for outreach costs for total of $2.72.  Historically, persons with speech disabilities are difficult to reach hence this.  I applaude the FCC of this cuz I see great need for that, too.

MARS gave interstate Captioning Telephone Service and IP Captioning Telephone Service $1.62.  This is particularly interesting cuz of IP CTS (Internet) being reimbursed by MARS methodology.

IP Relay at $1.29 (not from MARS methodology)

VRS:  

• If under 50,000 minutes, then $6.77
• If over 50K to 500K, then $6.50
• If over 500K, then $6.30

The VRS tiered rates will be same for 3 years except that each subsequent years ,the reimbursement rates will be reduced by .5%. 

Obviously there is lot more to the FCC report; there are over 100 pages.   Even so, worth reading…

eyes open & thumbs up,

Ed B
RT Admin.