Petition to the FCC by Group of TRS Providers
30 01 2009All..
You all will find this interesting! Basically 9 TRS providers – ATT, CAC, CSDVRS, GoAmerica, LifeLinks, Snap Telecomm, Soreonson Comm, Sprint NexTel, and Viable have petitioned the FCC to clarify that multiple CAs (Communication Assistants – really same as telephone interpreters) which include video Interpreters, TTY CAs, STS CAs, IP Relay CAs, deaf blind Interpreters, Captioned Telephone Interpreters and multiple services services and technologies (all relay features) should be reimbursable.
For example right now TTY users are not able to communicate with VRS users. STS users not able to communicate with VRS users, Captioned Telephone users not able to communicate with VRS Users, and so on. Petition says that combining TTY and VRS into one service should be reimbursable; in other words, when a TTY user connects to a VRS user (both deaf), petition says the fund should pay for both CA of TTY service and Video Interpreter for VRS.
The petition argues that these are necessary to achieve functionally equivalent telephone services based on their interpretation of relay regulations.
It is obvious that the Relay providers stand to make more money to do these services if approved by the FCC.
Click to this link, and read their rationale why these type of multiple-CA services should be reimbursable.
If the FCC does rule that these type of services are reimbursable; my personal opinion is that I think the FCC needs to be very careful; that is, they need to spell out regulation clearly and have the capacity to enforce regulations against abusing practices because I can see a few vendors would take advantage of that and ramp up the unnecessary minutes to make lot of money. The FCC has not succeeded in clamping down unethical and illegal practices by a few VRS providers (at least so far not yet), so I would wonder how the FCC would handle abuses for the new services if the order is given to reimburse these services.
Also, it also would mean the cost of providing relay service would go up even more, possibly passing the red flag of 1 billion dollar. How would the decision makers (the FCC Commissioners, Congress, or even White House) feel about that? Oh, what about state relay regulators? In times of economic hardship nowadays, most states likely will not support that.
Even so, the petitioners do have a case. I think the eyes will be on the FCC now and the burden will be on them. Personally, I kinda support the petition, but I would want to see the FCC Enforcement Bureau take actions on unethical and illegal practices of relay vendors first before approving that.
Tell me, typically upfront Readers of Edsalert, what you think?
Ed
eyes open & thumbs up,
Hi Ed,
I like your “goatee”
Your new appearance makes you qualified to work as the “enforcer” with the FCC Enforcement Bureau with TRS!
Keep up the good work in keeping us informed
The interoperability issue is an important one and a step in the right direction but as you point out there are obstacles and issues that must be thoroughly discussed and thought out. The cost is a major obstacle given the financial straits currently facing all levels of government. Even with that being the case, there should be an exploration of this issue that results in laying a foundation for moving forward at some time in the future.
Randy,
Thanks for the compliment. It’s a beard, not a goatee [g]
Phil,
Yeah, I think that if the FCC enforces and penalizes (?) regulation breakers, the cost of providing overall TRS would drop signfically, so making the interoperability issue more approachable.
I remember when I was RT Administrator and had several contracts with various vendors/organizations/individuals for outreach work; those I spotted cheating or padding the invoice, I tend not to work with them anymore in the future. I can see same attitude from the FCC or decision makers.
eyes open & thumbs up,
Ed
Is there a way to get around this definition of TRS, which is in Title IV, as it clearly delineates that TRS is to be between deaf/hoh individuals and ‘hearing individual[s].’, not between two deaf people using different technologies?
47 USC 225 (A)(3): “The term “telecommunications relay services” means telephone transmission services that provide the ability for an individual who has a hearing impairment or speech impairment to engage in communication by wire or radio with a hearing individual in a manner that is functionally equivalent to the ability of an individual who does not have a hearing impairment or speech impairment to communicate using voice communication services by wire or radio. Such term includes services that enable two-way communication between an individual who uses a TDD or other nonvoice terminal device and an individual who does not use such a device.
CNW,
You are right on this.
Remember that there are precedents that allow VCO users to communicate with TTY users; that STS users can communicate with TTY users, and similar past approved practices – these are disabled person communicating with other disabled person. VCO user could be deaf/hoh and so can TTY user. The petitioners are basing their case on this as well as “functionally equivalent” in the telephone network as stipulated in the relay regulation.
Whether the FCC agrees that past approved precents apply to their petition remains to be seen.
You raised good point.
Ed
Traditionally, the intent of relay is to link TTY or VRS users to voice callers. One of the two parties must be a voice caller.
Other than voice callers, it will be interesting to see comments that will be made to FCC regarding the need for VRS users to connect with the other party that use a TTY, VCO, Captel, etc. I believe that TRS users are very marginal in the relay market and States should absorb intrastate VRS costs that involve the other party that uses TTY, VCO, Captel, etc.
Continue with your vlogs.
Claudia Foy
My biggest concern is the interconnection between deaf/hard of hearing/hearing people AND deafblind people. Before the vp days, deafblind people were able to communicate with deaf people using TTYs and with hearing people thru TRS. Today, deaf people are discarding TTYs which create a severe separation from deafblind people.
The question is: should we have dual relay services for all, regardless of their abilities, disabilities and choices…or…limited dual relay services to ensure accessibility based on one’s ability such as those who couldnt benefit from VRS due to blindness or inability to sign regardless of ones hearing loss (oralists, late deafened adults, etc)? If so, who should be authorized to “certify” those who qualify for dual relay services?
Sonny
Ed, I second your request for better enforcement. We are entering a “new era” in the American economy – both at state and federal levels. The state legislature just transfered $8 million out of the TRS fund.
I think we can expect the US Congress to look at all spending; and we can expect all taxpayers to look at their phone bills and begin to question the interstate and intrastate taxes they are paying to support.
We cannot afford to pay for ANY fraud or abuse. Effective enforcement should come before expansion of services. My two cents …
(jk-II)
Wow – hadn’t thought of TTY-to-VRS calls. As Sonny says, the emergence of VRS calls and discarding of TTYs has certainly created unique challenges for people who are deafblind.
Not only that, but in some places (many) where there are no videophones, only TTYs (i.e., airports) – it’d be handy to have access to a TTY that can connect with a videophone user in case my pager isn’t working and I’m stranded for whatever reason. Given that most people in my family are deaf, it’d be difficult for me to contact my family if my pager didn’t work, and there was only a TTY. Worst case scenario, I’d have to ask some hearing person to call for me.
While we’re talking about your beard…I vote that you keep growing that beard until every relay provider is 100% satisfied with FCC. That way, we can have you qualify for the world’s longest beard.
Trudy,
[ha ha] – Before I go into that. The next several years are gonna be challenging for the relay providers and the FCC. I know it is technology possible for VRS providers to add TTY baudot to their video phones, but there is no money in that so unlikely they will adopt that. It is also technology possible to add text messaging to video phone as I believe Sweden did and Europe may start adopting that. I can go on and on, but the bottom line is will this make money for the company? I don’t even have to answer that for the answer is all too obvious.
Now on beard, no no. The beard will be to the ground and still relay providers will find a way to disagree with FCC. Regulators and companies rarely agree 100% with each other. So no, I won’t do that [g]
eyes open & thumbs up,
Ed
JK-II,
No argument with you! Hope the FCC reads your post and wake up!
Ed
Imagine you are Deaf and you work for a VRS company. Imagine every week you are required to sit for 5 different conference calls that last 1 hour.
Imagine- 14 participants, 14 there on the conference call, then they all sit for 20-30 minutes before they start. This call will last for total of 1 hour.
14 x $6.00 x 60 min = This call will generate $ 5,040.00.
If you figure labor at 1/4 of the revenue, $90.00 for that hour (obviously very generous, no interpreters earn $90 per hour) $90 x 14 = $1260.00 in interpreting costs.
14 participants, installer probably earning $25.00 per hour for sitting on the call, $ 350.00 in labor costs there.
5,040.00
-1,260.00
– 350.00
$ 3430.00 left.
Now do this 5x per week. $17,000 per week in profits from these calls.
You can see where VRS companies are becoming very rich doing this.