All..
National Association for State Relay Administration – NASRA – recently filed a request of clarification to the FCC as to whether a few of VRS practices are legal or not.
Before I belabor on this point, NASRA is dear to my heart as I’m one of the charter members who first formed this prestigious NASRA about 15 years ago. NASRA is clearinghous for state relay administrators and now is represented by 34 states. Since I’m now retired and no longer a state realy administrator, I’m an outsider now.
I miss being with the NASRA members on their annual conferences, they’re very good group.
Ok enuff of this sentiment, back to the issue. One of the main reasons why the NASRA filed this is because state relay administrators knew in the near future that the states will pay for Internet-based relay services (IP Relay and VRS), and they are requesting clarifications on a few of VRS practices are legal or not. Remember, right now the Interstate TRS Fund (federal fund) is paying for IP Relay and VRS now and it is supposed to be temporary. The FCC has been saying that subsidizaiton responsiblity of Internet-based relay services will go to the states in the future.
Ok – now the FCC had passed a rule way back where it says VRS providers are not allowed to do certain relay marketing and call handling priactices. The rules basically said because the federal fund pays for the service, not the IP/VRS users, IP/VRS providers are not allowed a few of marketing practices where the providers "reward" users/organizations for using VRS by offering cash, monthly payment, pay for cable cost or new VP, etc.
I kinda understand this position. Hearing persons who have cell phone have to pay monthly service and are limited to so many minutes a month; if over the limit, they have to pay extra. IP/VRS users do not have such restrictions. Even with VoIP, the users are limited to provider’s equipment, pay for service monthly and sign term agreement (usually 2 years) to get "free" VoIP equipment. IP/VRS users do not have that. So that is not functional equivalent.
So the NASRA members decided to ask the FCC to clarify a few marketing practices and cited a few examples of that. Click to the link and get full story.
NASRA Comments
Here are a few examples that the NASRA is asking the FCC to clarify (read the link as it had more detail, the following is summary):
Example One: Organization/clubs would sign up with a VRS provider to have its own domain name. Like XYZVRS (instead of using VRS provider’s domain name) . In return for marketing the domain name, the VRS provider would pay organization/club an amount of money that varies from month to month – no explanation why the amount varies from month to month. The VRS provider(s) are careful not to say because of "required VRS minutes". They just say "advertise the domain name" only.
NASRA position is that some of the members of the organization/clubs noted that money donations seems to increase when lot of members make VRS calls. Would these be considered "unnecessary VRS Minutes"?
Example Two: VRS provider(s) set up marketing/sales division/dept and hire deaf/hoh as marketers or salesperson. Their job is to use VRS to make telemarketing calls. This increase number of VRS minutes to be submitted to the FCC. More deaf/hoh employed, the higher the VRS minutes. So the cost of sales/marketing is paid by the VRS minutes.
NASRA position is that VRS providers that set up marketing/sales and use deaf/hoh should absorb the cost of VRS since they’re the ones who hired them, not the FCC. Also, NASRA says that generally if persons working in sales/marketing only keep their jobs if they are successful in marketing/sales work. However, by sumitting VRS minutes to the federal, VRS providers do not lose $$ even if they kept those who were not successful.
Example Three: A few independent marketing services sign up with VRS provider with the understanding they will use that VRS provider and in return get so much $$ per minute of VRS minutes ($1 per min for example).
NASRA position is that this may be clarified as an incentive/reward for consumer to place a VRS call (per FCC regulation) therefore illegal?
Example Four: VRS providers encouraging persons to sign up other persons to qualify in getting a free video phone.
NASRA position believes it incurs practice of ramping up unnecessary VRS minutes. NASRA has received reports that in order to get free VP, they need to use the VRS on top of signing up new users. NASRA wants clarification of whether this is legal or not.
Finally…
SorensonVRS responded with a strong support of NASRA ex parte and went on to encourage the FCC to make the clarificaiton as soon as possible to help minimize the cost of VRS. Click to the link and get the details.
SorensonVRS Comment on NASRA Ex Parte
eyes open & thumbs up,
Ed B
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