Models:State TRS RFP vs VRS/IP Free Enterprise
12 09 2008All..
This one is a bit long so I will not do a vlog on this one.
There was a lively discussion at a listserve on government models of State TRS Request for Proposal versus "Free Enterprise" of Internet-enabled relay service (IP/VRS). I would like to share some of my musings and see what y’all have to say since there are more of you now (836 subscribers now) - I’ve discussed this before.
Before I belabor on all this, why am I bringing that up? The 10 digit phone number that VRS/IP users will get end of December 31, 2009 – if not sooner – will make it possible to identify originating and terminating points of a relay call. In the past, VRS/IP use Internet Protocol so it was not possible to identify the originating or terminating points if they are at the Internet end of it. So there is no way to know if the Internet-based relay calls are within a state or out of state so federal took the full responsibility to pay for VRS/IP. But because now the VRS/IP calls can be determined if from within state or out of state so that means the FCC can pass responsibility of paying VRS/IP providers on to states. When will that happen? Who knows..maybe soon after the 10 digit phone number is up and running with all bugs fixed?
Now what are these models?
Model #1: State TRS RFP means state releases request for proposal (RFP) and relay providers would submit their proposals. The best proposal – not always necessarily the lowest price reimbursement – would be chosen by state; usually by regulator, or a advisory committee or selected persons to be part of RFP committee. Few states allow state telephone association by joint agreement among telephone companies select a relay provider.
Model #2: "Free Enterprise" of Internet-enabled relay service is done by pre-analyzed reimbursement rates based on the cost breakdown provided by states (using MARS account methodology) and any company can be relay provider providing they met the requirements to be relay provider. Federal decides if vendors qualify or not.
OK?
Now first of all let’s not kid ourselves – both models are govt subsidized – and not paid by customers like most telephone users. We do, however, pay as ratepayers or taxpayers (all of us including hearing persons who may or may not use the service) which in turn subsidize relay service in both models. Telephone companies collect fees from us and then they in turn pay into a fund that pays for relay service; (model #1) states usually by state regulators (PUC, PSC, etc), and (model #2) federal by federal regulator (FCC). Both states and federal basically adopts these financial arrangements.
There is a federal relay law that requires ALL states provide relay service with exception of Internet-enabled relay services. In other words, VRS/IP are not "required", but permitted. There are a few federal relay regulations that list rules of what relay service must comply including Internet-enabled relay service (with some exceptions of some items being waived) to be a relay provider. VRS/IP relay service – even though not required – must adhere to relay regulations to be reimbursed by the federal fund.
That said, let’s muse…
At traditional relay service level, states typically choose one provider with exception of California. On other hand, at the federal level, Internet-enabled relay services (IP and VRS), any company with enough capital can be part of the service as long as they meet certain specifications to be relay provider. Multi-vendors are possible with Internet-enabled relay service while with states, typically only one relay provider is selected. As you can see obvious difference between states and federal.
At the federal mode #2, Interstate relay service (long distance calls made out of states) and Internet-enabled relay services only have to follow federal relay regulation and its bare minimum requirements. States, on other hand, varies from state to state on what is required. A few states merely adopt what federal relay regulation says; in other words minimum regulations. However, most states write their own relay regulations that often surpass what federal relay regs require. An example is Average Speed Answer (ASA – how many calls answered within specified time frame), many states chose the more stringent criteria of 3.3 ASA (average answer time shall not exceed 3.3 seconds) than what federal require which is 85/10 (85% of calls be answered within 10 seconds be answered). States often ask for aggressive outreach to be part of the package. Federal will subsidize only portion of marketing or outreach. IP/VRS model #2 have to compete for customers and outreach is paid mostly by IP/VRS providers while state model #1 and its selected relay provider often partner up and do outreach projects together.
Reimbursement rate from federal is based on – supposedly – the "average" reimbursement rates and costs collected from all states whereas reimbursement rates from states are based on the submitted reimbursement rate by relay providers (RFP process). So smaller states – because of its low call volume – typically pays higher reimbursement rates whereas larger states typically pays lower reimbursement rates. One important note: national reimbursement rate is based on ALL of bid price per minutes of each state and then reimbursement rate are averaged and calculated.
Now you understand why if federal decide to pass subsidization responsibility of Internet-enabled relay services on to states, the reimbursement rates for states will likely be much higher and states will likely choose ONE provider rather than multiple providers to keep reimbursement rates low. If states chose three providers in that state,it means the call volume for EACH provider will be 1/3 lower than state total thus the reimbursement rate likely will be higher. Most state governments are frugal so they will opt for one provider because one call volume for one provider will get lower reimbursement rate.
So we prefer to keep Internet-enabled relay service at federal level to make it possible to have choices of different IP or VRS providers. However, it seems federal is determined to pass the subsidization responsibility on to states. Is there a win-win solution to that? I believe so, and I hope to share with you all what the win-win solution might be. The idea I have is a proposal I believe VRS/IP providers, and deaf/hoh communities will find attractive, but not to federal agency and possibly a few state regulators as well.
For now, any questions/comments on this so far? I hope I am making sense of the difference between the two models. Feel free to ask, agree, oppose, or offer alternative ideas.
eyes open & thumbs up,
Ed
PS: Would you have preferred this to be Vlog even though it may be more than 10 minutes long? Let me know your thoughts…
Interesting reading. I have to digest a little more before offering my thoughts. Okay?
Many thanks, Ed for this blog posting to the attention of the IP and VRS deaf users. I am sure that many of us are truly appreciate your time and effort to write this blog posting.
Many deaf people are still shocked that I NEVER receive a free VRS device from any of the VRS companies. How sad!
Robert L. Mason (RLM)
rlmdeaf@hotmail.com
RLM,
No, it is I who should thank you. I was worried that the blog may be bit too long for general blog, and I’m glad to see you took the time to do that. So thanks! Most certainly I would like to hear ur thoughts.
Why have u not received any video phones? I’m curious. You chose that or on a waiting list that been there forever? ;-] I have a few friends who said they applied for free vp like a year ago and to this date still have not gotten one.
eyes open & thumbs up,
Ed
Ed,
I’d like to offer a correction on the 10 digit deadline. Your post shows December 31, 2009, but it is actually 2008.
As for the models, I have always believed that once a call origination is tracked, then the feds would pass the reimbursement costs on to states whether we want it or not. Anybody can argue that the feds should keep it at their level, but no matter what, 5 years from now it will be at the state level to account for minute expenses and reimbursements.
All I want and hope for is that whatever happens during the transition the features do not get diminished and that it will allow providers room for growth and healthy dose of competition.
Thanks,
Daniel
I understand most of it but it would be great if you could do the vlog so we can get the better picture. Thanks for any help that you can provide us.
David
Just curious – supposedly TRS RFP is passed and then require all of us to have this similar stuff, would we have to pay for long distance call as we did when we used TTY…. or am I misunderstood this purpose ??
To use this long one w/o vblog is good for “educated” but I am just concerned for the others who are not enough educated like us.. that’s 1/2 positive and other is negative…
EYES OPEN & THUMBS UP!!!!
Daniel,
My finger hit 9 instead of 8 so thanks for correcting that.
As for ur other comments. Exactly! The reality of the situation is that states will still have to pay for the services. The win-win proposal I want to share later will show that states will still have to pay for the service, but that federal handle the subsidization process yet be able to still offer multi-vendor networks that we all so enjoy. I am not proposing that the federal fund pay for Internet-based relay calls that originated and terminated within a state; local and intrastate calls. Bear with me, Daniel. I want to read other comments before I share what I think will work.
eyes open & thumbs up,
Ed
May,
Whether traditional TRS uers pay for long distance calls or not will depend on his/her telephone account. If you are talking about Internet-based relay service being handled at the state level (RFP) then likely will depend on the specifics of the Request for Proposal. A few states may want to save $$ by allowing Internet-based relay providers charge for long distance calls. It all depends on how states write their RFPs.
And – thank you for your remark about blog vs vlog. One more question. Do u think 10 or more minutes of vlog – people will view them?
eyes open & thumbs up,
Ed
Ed
California has made a major investment in soliciting and incorporating consumer feedback on relay specifications. I think that the state will not be happy if your proposal does not contain significant consumer protection and quality management beyond ASA and blockage.
Winston
Number one rule: FUNCTIONAL EQUIVALENCY with hearing telephone users.
This means:
-equal cost to customers for telephone service
-freedom of choice.
Conversely:
If cost of service to relay users is higher, then cost of service to hearing people’s use of IP telephones must be raised.
If relay users are restricted to one provider in state, then hearing telelphone users must be restricted also.
In other words what’s good for the hearies is good for the deafies (and not all the hearies are goose and not all the deafies are ganders) to bastardize the expression of:
“what’s good for the goose is good for the ganders!”
Ed,
I love this discourse esp., that I’m into communication access technology. While your wisdom and musings are appreciated, it would increase my understanding if you vlogged this article. And do you have a friend who’s a native signer that could help you?
My best with two thumbs up! Thanks for keeping on track on this note and telling us–readers, fans or friends/colleagues what you’re up to!
Smiles,
S~
Larry,
This functional equivalence sometimes can be a double-edged sword. It could bite back. This is one issue I wanted to raise in the near future of exactly what functional equivalence really means. My beef is that why should we be equal to hearies? Why can’t we be AHEAD of hearies? Instead of “catching up” to the level of hearies? Be on the lookout for that issue in the near future.
eyes open & thumbs up,
Ed
Thought-provoking and there are pros and cons in each model – namely that when I visited the US I was under the impression that many State Relay Administrators insist on a relay center based in their state as part of the tendering and contracting process.
If this is correct then some states will win over others, especially those with scarce interpreting resources – this will put pressure on prospective VRS service center to ‘make do’ with what is available leading to inequalities for deaf people living in that state as opposed to other states with plentiful supply of interpreters. This is one concern – another is that states like wyoming has (I was told) only around 200 ASL signers – how could that state support a fully fledged video relay center?
The above covers the cons.
The pros for me seem to be the accountability side of the VRS to deaf people living in the state for the quality of the service, interpreters and even the supply of videophones. With the present federal system it seem to me (as an outsider) that the ‘accountability’ is very diluted and one has to have strong determination to get their issues addressed and so it means that most will ‘make do’ and move on to a different provider…
Would love to analyse your win/win solution…
Smile
Jeff
SB,
Oh, I’m hurt (not really
. I’m a native signer since I was 3 years old (my hearing parents in their wisdon found a deaf family and their deaf son – same age as me – Race Drake (we were pals) and we got together quite a bit. I grew up at Arkansas School for the Deaf. At my school years (my classmates of Arkies will attest to that) most of our teachers were deaf and strong ASL users. To top it off, we had deaf storytellers (Drake, Palmer, Nichols, etc) that would sign stories 2 to 3 hours in ASL – also, we had deaf preacher (Rev Hirte) who loved to tell 15 to 30 min biblical stories in ASL. Also, I was an actor at both ASD and Gally. Heck, director at Gally – Eastman (God rest his soul) assigned me to teach ASL to a fellow actress that now is a movie star in her own right. So I can sign ASL, but edsalert covers wide subscribers – so I sorta do a PSE (I know that word is no longer used, but that acronym seems to explain so well).
eyes open & thumbs up,
Ed
Jeff,
Good analysis on your part. The idea I have I will share.
+++++++++++++++
As for rest of you who voiced support for vlog. I will try do the vlogs even if bit too long, but will add text for those who do not want to see vlog. From time to time, I will say TB and post text ;-]
[g] eyes open & thumbs up,
Ed
Ed,
I thought more about what you are proposing, and I think I like the federated administration executed at the state level. But let’s see what you’re going to say. Is there a timeline when you’re going to vlog about it?
Daniel
Daniel H.,
I hope to do it by end of next week. I wanted to try a different type of video editor (videowave from Roxio), but am having problem with that. Once I fix that, I want to use that for that..failing that back to MS Moivemaker.
eyes open & thumbs up,
Ed