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	<title>Comments on: NASRA Files Request of Clarification to the FCC on a few VRS Practices</title>
	<atom:link href="http://www.edsalert.com/2008/12/01/nasra-files-request-of-clarification-to-the-fcc-on-a-few-vrs-practices/feed/" rel="self" type="application/rss+xml" />
	<link>http://www.edsalert.com/2008/12/01/nasra-files-request-of-clarification-to-the-fcc-on-a-few-vrs-practices/</link>
	<description>POSTS ALERTS REGARDING TRS &#38; ITS RELATED ISSUES</description>
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		<title>By: edsalert</title>
		<link>http://www.edsalert.com/2008/12/01/nasra-files-request-of-clarification-to-the-fcc-on-a-few-vrs-practices/comment-page-1/#comment-40594</link>
		<dc:creator>edsalert</dc:creator>
		<pubDate>Mon, 05 Jan 2009 18:09:30 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/?p=523#comment-40594</guid>
		<description>Paul,

Maybe you should send comment/complaint to the FCC on this one?  At any rate, I think the issues that the NASRA ex parte for clarification will cover this even though the NASRA did not expressely specify that; the examples were similar.

I hope the FCC will address this issue ASAP.  The more the FCC receives, the more likely they are to address this issue.   

eyes open &amp; thumbs up,

Ed</description>
		<content:encoded><![CDATA[<p>Paul,</p>
<p>Maybe you should send comment/complaint to the FCC on this one?  At any rate, I think the issues that the NASRA ex parte for clarification will cover this even though the NASRA did not expressely specify that; the examples were similar.</p>
<p>I hope the FCC will address this issue ASAP.  The more the FCC receives, the more likely they are to address this issue.   </p>
<p>eyes open &#038; thumbs up,</p>
<p>Ed</p>
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		<title>By: Paul Patrick</title>
		<link>http://www.edsalert.com/2008/12/01/nasra-files-request-of-clarification-to-the-fcc-on-a-few-vrs-practices/comment-page-1/#comment-40587</link>
		<dc:creator>Paul Patrick</dc:creator>
		<pubDate>Mon, 05 Jan 2009 16:22:57 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/?p=523#comment-40587</guid>
		<description>Hello Ed and All:

Hm, I see the practice is still that way with Sorenson itself. My hearing friend has been on hold for 20 minutes thus far. He asked for a hearing number to call for support and told that they only have an email address...  I wonder if and how that can be brought up to Sorenson.

Thanks.

Paul</description>
		<content:encoded><![CDATA[<p>Hello Ed and All:</p>
<p>Hm, I see the practice is still that way with Sorenson itself. My hearing friend has been on hold for 20 minutes thus far. He asked for a hearing number to call for support and told that they only have an email address&#8230;  I wonder if and how that can be brought up to Sorenson.</p>
<p>Thanks.</p>
<p>Paul</p>
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		<title>By: edsalert</title>
		<link>http://www.edsalert.com/2008/12/01/nasra-files-request-of-clarification-to-the-fcc-on-a-few-vrs-practices/comment-page-1/#comment-39011</link>
		<dc:creator>edsalert</dc:creator>
		<pubDate>Mon, 08 Dec 2008 22:26:02 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/?p=523#comment-39011</guid>
		<description>Paul,

This is a good question.   

A few months ago when I was with Texas PUC, I noted that practice from  one of the VRS provider, and I brought it up with its management and inquired.   To the VRS provider&#039;s credit, that VRS provider stopped that practice.   Now to get a technician or support service, it will reach a deaf/hoh staff of the VRS provider.  This implied that VRS provider may have realized that this is not an enthical practice so stopped doing that.   

No, NASRA or SorensonVRS did not address this particular practice.  

eyes open &amp; thumbs up,

Ed</description>
		<content:encoded><![CDATA[<p>Paul,</p>
<p>This is a good question.   </p>
<p>A few months ago when I was with Texas PUC, I noted that practice from  one of the VRS provider, and I brought it up with its management and inquired.   To the VRS provider&#8217;s credit, that VRS provider stopped that practice.   Now to get a technician or support service, it will reach a deaf/hoh staff of the VRS provider.  This implied that VRS provider may have realized that this is not an enthical practice so stopped doing that.   </p>
<p>No, NASRA or SorensonVRS did not address this particular practice.  </p>
<p>eyes open &#038; thumbs up,</p>
<p>Ed</p>
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		<title>By: Paul Murphy</title>
		<link>http://www.edsalert.com/2008/12/01/nasra-files-request-of-clarification-to-the-fcc-on-a-few-vrs-practices/comment-page-1/#comment-39001</link>
		<dc:creator>Paul Murphy</dc:creator>
		<pubDate>Mon, 08 Dec 2008 19:22:46 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/?p=523#comment-39001</guid>
		<description>Hello Ed:

   I see the NASRA request and Sorenson support letter. Do either of them address  question of how VRS providers handle customer/technical support and whether those minutes are billable if through their own VRS service?

   For example, I check out one provider&#039;s list of &quot;contact support&quot; numbers which (besides e-mail) list a VP number and phone number. I dialed the VP number and reached a hearing agent via VRS and had friend call the hearing number who reached a deaf agent via VRS. Are these calls billable? If so, does that mean that the FCC is &quot;paying&quot; for that provider&#039;s technical support department? That would be similar to their arguments about FCC pay for marketing staff.

   I do not know if a deaf caller may reach a deaf agent and whether a hearing caller can reach a hearing agent. It may be good to check it out.

   Thank you.

   Paul</description>
		<content:encoded><![CDATA[<p>Hello Ed:</p>
<p>   I see the NASRA request and Sorenson support letter. Do either of them address  question of how VRS providers handle customer/technical support and whether those minutes are billable if through their own VRS service?</p>
<p>   For example, I check out one provider&#8217;s list of &#8220;contact support&#8221; numbers which (besides e-mail) list a VP number and phone number. I dialed the VP number and reached a hearing agent via VRS and had friend call the hearing number who reached a deaf agent via VRS. Are these calls billable? If so, does that mean that the FCC is &#8220;paying&#8221; for that provider&#8217;s technical support department? That would be similar to their arguments about FCC pay for marketing staff.</p>
<p>   I do not know if a deaf caller may reach a deaf agent and whether a hearing caller can reach a hearing agent. It may be good to check it out.</p>
<p>   Thank you.</p>
<p>   Paul</p>
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		<title>By: edsalert</title>
		<link>http://www.edsalert.com/2008/12/01/nasra-files-request-of-clarification-to-the-fcc-on-a-few-vrs-practices/comment-page-1/#comment-38730</link>
		<dc:creator>edsalert</dc:creator>
		<pubDate>Wed, 03 Dec 2008 14:06:24 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/?p=523#comment-38730</guid>
		<description>IM GoDaddy,

Funny.  Actually, there is a rule in relay regulation where it says if the relay call is focused on the relay agent (or video interpreters), it would not be considered as relay call.   

Well, we&#039;ll find out soon enough (I hope) on what the FCC ultimately rules on this.   

Thank YOU for participating in this.   It is always good to see different sides.

eyes open &amp; thumbs up,

Ed B</description>
		<content:encoded><![CDATA[<p>IM GoDaddy,</p>
<p>Funny.  Actually, there is a rule in relay regulation where it says if the relay call is focused on the relay agent (or video interpreters), it would not be considered as relay call.   </p>
<p>Well, we&#8217;ll find out soon enough (I hope) on what the FCC ultimately rules on this.   </p>
<p>Thank YOU for participating in this.   It is always good to see different sides.</p>
<p>eyes open &#038; thumbs up,</p>
<p>Ed B</p>
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		<title>By: Im GoDaddy</title>
		<link>http://www.edsalert.com/2008/12/01/nasra-files-request-of-clarification-to-the-fcc-on-a-few-vrs-practices/comment-page-1/#comment-38712</link>
		<dc:creator>Im GoDaddy</dc:creator>
		<pubDate>Wed, 03 Dec 2008 04:16:36 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/?p=523#comment-38712</guid>
		<description>Im saying about domains only, not about getting more unnecessary VRS minutes. If one VRS provider sets up &quot;www.sexyvrs.com&quot; with beautiful interpreters, Im sure to choose this VRS provider and enjoy its serivice. Of course it will increase VRS minites legally. :)

Thank for your quick reply. Your blog is VERY GOOD, more interesting!</description>
		<content:encoded><![CDATA[<p>Im saying about domains only, not about getting more unnecessary VRS minutes. If one VRS provider sets up &#8220;www.sexyvrs.com&#8221; with beautiful interpreters, Im sure to choose this VRS provider and enjoy its serivice. Of course it will increase VRS minites legally. <img src='http://www.edsalert.com/wp-includes/images/smilies/icon_smile.gif' alt=':)' class='wp-smiley' /> </p>
<p>Thank for your quick reply. Your blog is VERY GOOD, more interesting!</p>
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		<title>By: edsalert</title>
		<link>http://www.edsalert.com/2008/12/01/nasra-files-request-of-clarification-to-the-fcc-on-a-few-vrs-practices/comment-page-1/#comment-38710</link>
		<dc:creator>edsalert</dc:creator>
		<pubDate>Wed, 03 Dec 2008 04:01:34 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/?p=523#comment-38710</guid>
		<description>IM GoDaddy,

Is GoDaddy reimbursed by federal funds for using VRS?  I think not.  Little different there.  Marketing success is measured or supposed to be measured by success of marketing itself - not by how many VRS minutes.   CSDVRS or any VRS providers that do marketing of its services via VRS can pay for its VRS costs instead of submitting to federal for marketing costs.    NASRA has no objection to marketing practices if the company absorbs the marketing costs.   That&#039;s the theory NASRA is based on.</description>
		<content:encoded><![CDATA[<p>IM GoDaddy,</p>
<p>Is GoDaddy reimbursed by federal funds for using VRS?  I think not.  Little different there.  Marketing success is measured or supposed to be measured by success of marketing itself &#8211; not by how many VRS minutes.   CSDVRS or any VRS providers that do marketing of its services via VRS can pay for its VRS costs instead of submitting to federal for marketing costs.    NASRA has no objection to marketing practices if the company absorbs the marketing costs.   That&#8217;s the theory NASRA is based on.</p>
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		<title>By: Im GoDaddy</title>
		<link>http://www.edsalert.com/2008/12/01/nasra-files-request-of-clarification-to-the-fcc-on-a-few-vrs-practices/comment-page-1/#comment-38709</link>
		<dc:creator>Im GoDaddy</dc:creator>
		<pubDate>Wed, 03 Dec 2008 03:49:12 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/?p=523#comment-38709</guid>
		<description>In fact, It is not illegal that CSDVRS gave many domains to make its market bigger. GoDaddy has many domains (cheap-discount-domain-names.biz, luckyregister.com, www.humdomains.com, and more) to provide different services to different users. It is MARKETING way, not illegal!</description>
		<content:encoded><![CDATA[<p>In fact, It is not illegal that CSDVRS gave many domains to make its market bigger. GoDaddy has many domains (cheap-discount-domain-names.biz, luckyregister.com, <a href="http://www.humdomains.com" rel="nofollow">http://www.humdomains.com</a>, and more) to provide different services to different users. It is MARKETING way, not illegal!</p>
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		<title>By: edsalert</title>
		<link>http://www.edsalert.com/2008/12/01/nasra-files-request-of-clarification-to-the-fcc-on-a-few-vrs-practices/comment-page-1/#comment-38701</link>
		<dc:creator>edsalert</dc:creator>
		<pubDate>Wed, 03 Dec 2008 01:20:03 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/?p=523#comment-38701</guid>
		<description>Bob,

Well, keep in mind that if states do Request For Proposal for IP and VRS, and likely most states will insist on certified interpreters, and will add Outreach requirement.   Also keep in mind, most state relay administrators do have oversight responsibility and very much likely to follow up on any complaints from consumers promptly.   FCC has very little oversight responsibility - they don&#039;t have the manpower to do that especially at the consumer level.   

The disadvantage of RFP is states will choose ONE VRS provider and ONE IP provider.   On other hand, number of VRS providers will close up and number of interpreters would be more available for those VRS providers who win the contracts.   SorensonVRS has the highest call volume, so in theory SorensonVRS will likely be able to underbid if not all, at least most of the VRS providers.   

There are pro and cons to both sides - really.   It is reason why I push for more stringent FCC regulations (more clarifications really), push for federal funding (get funds from states, but let federal handle the fund), and let states have the oversight responsibility.    Can this be done?   I think yes, but will be difficult to get the FCC agree to that system.

eyes open &amp; thumbs up,

Ed B</description>
		<content:encoded><![CDATA[<p>Bob,</p>
<p>Well, keep in mind that if states do Request For Proposal for IP and VRS, and likely most states will insist on certified interpreters, and will add Outreach requirement.   Also keep in mind, most state relay administrators do have oversight responsibility and very much likely to follow up on any complaints from consumers promptly.   FCC has very little oversight responsibility &#8211; they don&#8217;t have the manpower to do that especially at the consumer level.   </p>
<p>The disadvantage of RFP is states will choose ONE VRS provider and ONE IP provider.   On other hand, number of VRS providers will close up and number of interpreters would be more available for those VRS providers who win the contracts.   SorensonVRS has the highest call volume, so in theory SorensonVRS will likely be able to underbid if not all, at least most of the VRS providers.   </p>
<p>There are pro and cons to both sides &#8211; really.   It is reason why I push for more stringent FCC regulations (more clarifications really), push for federal funding (get funds from states, but let federal handle the fund), and let states have the oversight responsibility.    Can this be done?   I think yes, but will be difficult to get the FCC agree to that system.</p>
<p>eyes open &#038; thumbs up,</p>
<p>Ed B</p>
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		<title>By: Bob Segalman</title>
		<link>http://www.edsalert.com/2008/12/01/nasra-files-request-of-clarification-to-the-fcc-on-a-few-vrs-practices/comment-page-1/#comment-38683</link>
		<dc:creator>Bob Segalman</dc:creator>
		<pubDate>Tue, 02 Dec 2008 20:12:40 +0000</pubDate>
		<guid isPermaLink="false">http://www.edsalert.com/?p=523#comment-38683</guid>
		<description>Ed

I see state administration of IP and VRS as bad for consumers and bad for providers.  States will pay much less per minute.  Because of the lower reimbursement I expect that quality of service  as well as outreach will deteriorate. How do you see it?

Bob</description>
		<content:encoded><![CDATA[<p>Ed</p>
<p>I see state administration of IP and VRS as bad for consumers and bad for providers.  States will pay much less per minute.  Because of the lower reimbursement I expect that quality of service  as well as outreach will deteriorate. How do you see it?</p>
<p>Bob</p>
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