FCC Oversight Needed On Marketing by VRS Providers?
12 03 2009Folks..
This is just a speculative musing with a suggestion for the FCC.
As the VRS industry grows, and we’re seeing VRS industry testing FCC on some uncharted areas of sales, marketing and telemarketing within VRS providers. The relay regulations, for most part, are ambiguous on what relay services can be used for. The original relay regulations seem to imply that relay services (all of them) is intended for relay users only (individuals who have communicative disabilities), and not for the relay providers to use themselves to make money.
A couple or so of the VRS providers seems to be taking advantage of the implied allowance of marketing and taking it to the extreme that these VRS providers are making money off the marketing by utilizing many deaf/HOH employees. These VRS providers to best of my assessment either make most money out of marketing or at least sizable percentage of overall profit, not from VRS users outside of VRS employment. Whether deaf/HOH staffs succeed in their works or not seem not to matter cuz they are building up VRS minutes.
That, to me, seems questionable or maybe even unethical? Theoretically speaking VRS providers should make most profit out of VRS users utilizing VRS for their personal and personal business uses, not from using their own employees to ramp up VRS minutes.
On other hand, there are remarks from decision makers that encourage relay service providers to let public know of their services (outreach and marketing). So what if a few or many of VRS employees are deaf and they need to use VRS to do marketing/outreach for VRS providers?
If FCC prevents VRS from doing telemarketing, then that is not fair to deaf/HOH who may lose the jobs working for VRS providers. On other hand, allowing marketing opens the door for possible abuses by VRS providers.
Looks like a catch-22 situation. What to do?
Generally speaking, people who work in sales, telemarketing or marketing have to earn their keep; in other words, their work has to produce results for their companies – make money or achieve objectives. If not, they lose the job.
With this underlying concept; I have one suggestion.
If VRS providers use their own people or contract out to do sales, marketing, or telemarketing services, the deaf/HOH can use VRS. However, at the break-even cost, not at the regular reimbursement rates. Any VRS minutes from deaf/HOH staff incurred from within VRS providers or telemarketeers who specifically use VRS providers that they contracted with, VRS providers should submit VRS minutes to the FCC at break-even reimbursement rates – not at $6.64 per min, but at break-even rates whatever that might be.
In other words, VRS providers will NOT make money out of using deaf/HOH based on VRS minutes only. That means deaf/HOH persons would have to "earn" their keep by doing their work successfully.
This effectively will not discriminate against deaf/HOH working within or who may have contract with VRS providers doing marketing work. At the same time VRS providers do not lose lot of money or earn obscene amounts by ramping up VRS minutes at regular reimbursement rates. Deaf/HOH persons in sales, marketing, or telemarketing would have to "earn" their salaries by achieving objectives for VRS providers.
This, to me, seems a win-win solution between VRS providers and FCC.
I want to see VRS industry succeed in a clean and ethical way, not dictated by greed and at the same time provide job opportunities for deaf/HOH to do work in sales, marketing or telemarketing.
Readers, let us know if you think this is fair or not. If not, your rationale being?
eyes open & thumbs up,
Ed
Very interesting concept of charging VRS rates at the break-even point for marketing purpose. However, I do see one problem. Each company has its own break-even point which depends on the amount of money they have invested in technology, manpower, and so forth. If FCC is to determine a specific break-even point for all companies, the companies that have invested the most may be harmed by this, while the companies that have invested the least may stand to profit from this. Usually, but not always, the companies that invest the least do not care about quality of their services, which could be troubling.
I think there is a more simple solution than trying to figure out what the break even cost is. Just force the VRS company doing the telemarketing to use a VRS service other than their own. Sure the company would throw a fit about having to use someone elses VRS but it is a surefire way to make sure they are not abusing the system. If all the VRS companies are doing this then the minutes should get spread around evenly.
I haven’t heard of VRS companies doing this and I can’t imagine what they are selling since they would have to be calling a hearing person to use VRS. Not saying it doesn’t happen but what is a VRS company going to try and sell a hearing person? Are they being contracted to sell or market for other companies?
Transplanted Texas,
Yeah – accounting accountability is a tough one and not easy. I guess that is why the FCC outscores account work to NECA (National Exchange Carrier Assoc). Presumably (?), they’ll come up with fair break-even rates if they are so ordered by the FCC.
CR,
I am surprised you haven’t heard about VRS providers hiring lot of deaf/HOH to do sales, outreach, education, and marketing and using VRS to do that – a few of them contract out to telemarketers who hire deaf/HOH to do the work. I noticed a few of VRS providers have backed out of that; not all, though. I am guessing that the word is out that FCC is finally looking at these practices.
Now, a few of them had bona fide and honest goal of really to market with purpose of achieving objectives. The issue is are they making money off accomplished objectives, or just ramping up VRS minutes, or hit two birds with one stone? Latter probably…so it becomes real sticky. I’m glad I’m not a federal regulator. It is a tough issue. Damned if one does and damned if one does not.
eyes open & thumbs up,
Ed
eyes open & thumbs up,
Ed
Just a different wrinkle to the above concern which is valid I want to make it known that there are deaf who use VRS for their Multi-Level Marketing / Network Marketing endeavors and this includes tele-seminars related to personal and business development plus various MLM / NM company-sponsored training. These calls usually last 60 minutes and takes place at the about 7:00 p.m. to 11:00 p.m. Eastern Time range.
Because of the very severe shortage of deaf with “business acumen” there are hearing business leaders affiliated with MLM / NM companies who have to provide content through tele-seminars. As one who’s diversified in learning from stuff in general (schools, etc.) I’m far more stimulated by learning from a variety of people–deaf or hearing. Please keep that in mind while I go on.
If the new FCC administration consider clamping down on this issue or the Video Interpreters give deaf attitude about having to do hard work as these calls require just imagine the uproar that will happen and the deaf cause for success in business endeavors might be compromised.
In similar fashion to registration for 10-digit numbers sincerely hope every deaf in MLM / NM will be required to register with FCC-enlisted governing agency that way VRS and their VI will detect through a coding system and provide service accordingly and with respect to quality.
It really angers me when regardless which VRS the VI performs rather poorly during above calls. Some even ask to switch even in midst of listing points made during the call! How can one take note like this? Such cavalier treatments are unwarranted. Yes, I know from various VRS that some VI went to the trouble of discreetly hanging up on their customers in a fashion giving customers the false impression the other end disconnected or the customers froze.
Deaf tele-marketers employed by VRS should be required to further register with the FCC too!
Separate “Outreach” from services.
The FCC (or the states) can set up completely separate contracts for “Relay Outreach”. The agency doing outreach describes all TRS/VRS services independent of provider.
The contract stipulates that IF the contractor hires Deaf/HOH employees, those employees must distribute their minutes equally across all providers.
Then the FCC modifies the provider rules to CLEARLY state that they are not allowed to do “Outreach”, period.
The federal government and/or state governments do have a responsibility to inform the public – both hearing and Deaf/HoH about services that are available. This is outreach and should include an explanation of the differences between different types of Relay including instructions to businesses how to avoid IP Relay fraud while still complying with ADA access requirements.
However, the neither the federal government nor state governments should be paying for marketing that will increase minutes of use for any one specific provider.
Some states have already taken this approach; those contracts could be used a models for the FCC to execute a single nationwide Outreach contract completely separated from individual providers.
C’mon…You can’t just make these statements and not name names. Who are these VRS companies that have or had their deaf/hoh employees to ramp up VRS minutes?
That’s why I read your site Ed. To learn more on subject matter. It seems like I learn something new every post you do. I was aware that they were doing some outreach and marketing to Deaf people via VP tp VP which does not involve VRS but I was not aware that they were also contacting hearing people. If they were just doing this through VP to deaf and not VRS then obviously the issue would be moot but since they are involving VRS and making money off of the minutes I can see where there is a big issue especially considering that the cost of VRS is on its way to hitting the 1 billion dollar mark.
jk-II wrote:
“The contract stipulates that IF the contractor hires Deaf/HOH employees, those employees must distribute their minutes equally across all providers.”
I am in agreement of making a rule like this. I believe if you force the VRS providers Deaf and HOH employees to use other VRS then it will force the VRS companies to be results oriented rather than just racking up minutes and opening the system to abuse. I think this rule would be more fair than trying to determine a break-even rate.
As someone who is starting a business, I am nervous about this type of discussion. If marketing calls by VRS were to be limited in some way, it could have a rollover effect on my business, cutting it off in mid-growth.
Any regulations designed to limit VRS scope in promoting their own businesses should be designed carefully so it does not impact the deaf consumer and his equal access rights to the telephone.
Dianrez,
The way I understand it your business should not be affected by this issue. It only pertains to VRS companies that hire Deaf/HoH eployees to do marketing and outreach not individual businesses that have no financial stake in the VRS companies themselves. Someone please correct me if I am wrong.
Robert Alfred Hawkins,
Phone online education is another issue as well. Maybe I will do a vlog on this one as well. TRS is NOT intended for phone online education according to the relay regulation, but then again many hearing persons do use phone to learn new trade, tactic, etc. Teleseminars provide that. TRS rule says must be two way conversation.
I understand where u are coming from, though. I have not used teleseminiars simply because as a regulator (an ex one at any rate), I knew that this may be in violation of the TRS regulation. Folks at teleseminars will not pay for phone interpretation so what to do?
I have often wondered about FCC forcing not only telephone companies, but ALL businesses to contribute to TRS fund, then by doing that would be “permitted”. That would require congress act to do that, though.
We deaf/HOH/speech-disabled folks often are caught in catch-22 situation.
As rest of your remarks, they’re good points.
Ed
CR and Dianrez,
Any deaf/HOH who have their own telemarketer business, but have no “ties” to any VRS providers need not to worry. Those that do, then this becomes sticky issue. I strongly suggest that if ure in that situation, do a petition of clarification to the FCC on this very issue. NASRA did petition something similar; presumably the FCC regulators are looking at that. Hopefully, they will let us know where they stand.
I agree with you, Dianrez, that the FCC needs to be very careful in ruling this.
Ed
JK-II,
Looks like u’ve been around ;-] Your remarks simply show that there are solvable solutions.
Ed
C’mon,
Yeah, I can. To do so may open up for lawsuits or blacklashes.
Just ask around especially folks who follow VRS industry closely. You’ll get eyefuls of info ;-]
You yourself signed on as an anonymous commentator, so I am pretty sure you’ll understand where I’m coming from…
Cautious Ed
>> Dianrez (10:04:59) :
>> As someone who is starting a business,
To clarify: the discussion here is about VRS companies using VRS marketing to inflate their own VRS minutes. Unless you are getting into the VRS business, the recommendations here would not affect you.
TRS (and by extension, VRS) is a ratepayer paid service designed to give Deaf/HoH equal access to the telephone. Nothing more.
As originally envisioned in Title IV, the phone companies were to add TRS access to their existing operator centers as a cost of doing business. The individual state PUC/PRCs then allowed those phone companies to add small surtax to every phone line to pay for the in-state TRS service and another surtax was added to long-distance calls to pay for inter-state TRS calls.
Times have changed. The Republican dominated FCC turned VRS into a profit making business completely separated from the phone companies.
What Ed – and others – are trying to suggest is that we take the profit out of VRS and make VRS an equal access service as intended by Congress when they wrote Title IV.
TRS/VRS was never intended to be an “full employment for the Deaf” program.
TRS/VRS should give us equal access so we can work where hearing people work: as a stock broker, as a lawyer, etc. TRS/VRS should give us (and you) the opportunity to start a business selling soap, jewelry, books, or Afghan hounds.
But VRS funding should not be used to create an entirely new business selling VRS.
In my humble opinion: TRS/VRS should create about 50 “marketing” jobs around the country: One position in each state to do Outreach and Education – independent of the Service Providers.
(And, in many states, a second job position to manage the function of the relay services available in that state.)
Then the Service Providers provide Service – and only Service – and they provide that service “at cost”.
Leaving open all the other questions: What about development of new equipment and new technologies? What about providing video phones and TTYs to people who need them but cannot afford them? What about paying for Broadband for people who cannot afford it or for people out in the country where the only option is K-band satellite at $130 or $180 per month?
Hey Ed, want to start a new page about the “best” way to pay for new equipment and new technologies, distribution programs, Broadband access, that is fair to the Deaf/HoH and fair to the Ratepayers?
Not just “Marketing” purpose that FCC should be concerned, but several companies have been “racking up” minutes by perfoming installations.
For example- a deaf technican would come to your house, install your vp, then sets up an account with the company using the VRS, rather than use vp to vp.
Often, while making the call, we’re on hold for at least 10-15 mins with the accounts rep. I assume that is to cover the cost to have the installer to come to our house.
Ed,
Since you mentioned two-way conversation is required to justify a relay call this begs a question: what about functional equivalency which relay users are entitled? This question includes receiving voicemail and attending tele-seminars for business purposes. Sorry if I missed a point there.
Jk-II,
You correctly interpreted original TRS regulaitons. Are we seeing a shift of paradigm in this respect? You correctly identified it as a party-line mission which I believe it is. I do think TRS providers are entitled to a reasonable profit; just not obsecene profit. I believe NECA, its Fund Council, and FCC are looking at the issues of what the Fund Council can do or cannot do in becoming more involved in regulating TRS industry. If the Fund Council are given more oversight responsibilities, then lot of sticky issues would be addressed and dealt with.
Your suggestion for new page is tempting, but for sure will create uproar ;-] I’ll wait for now…
Steve,
Ah, that is another example of “abuse” of deliberately ramping up VRS minutes. Thank you for pointing that out.
Ed
Robert,
Answering machine is not same as tele-seminars. There is an historical note on this. Believe it or not, at one time answering machines were not part of TRS. Regulators – both at state and federal level – quickly corrected that. Regulators were aware of tele-seminars, and they have not modified the regulation to include tele-seminars. That does not mean it is forbidden; just that ruling has not been made (to best of my knowledge). However, FCC has commented that students using VRS or any relay services in classroom is forbidden. Isn’t that similar to tele-seminar? Seems so.
>> Robert Alfred Hawkins (10:47:18) : wrote
“Since you mentioned two-way conversation is required to justify a relay call this begs a question: what about functional equivalency which relay users are entitled? This question includes receiving voicemail and attending tele-seminars for business purposes.”
ADA “rights” are not absolute and there are many gaps and exclusions.
You can read Title IV at http://www.fcc.gov/cgb/dro/title4.html which says ” 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.”
Note that the terms “Tele-seminar” and “conference call” do not appear in the statute.
Then read Title III which requires “places of public accommodation” to provide access.
Then we need a lawsuit and a Supreme Court determination of where Tele-seminars fit into the ADA.
Of course, the risk here is that the Court rules the Tele-seminar is not a “PLACE of public accommodation” (under Title III) and that the Tele-seminar is also not an “individual” under Title IV. Under that ruling – which is one possible interpretation of the statutory language – Deaf would not have any statutory “right” to access to the Tele-seminar….
Ed wrote:
“… NECA, its Fund Council, and FCC are looking at the issues of what the Fund Council can do or cannot do in becoming more involved in regulating TRS industry”
Let’s send a big “Hello There!” to the FCC staff who read these pages!
Picture this scenario:
Homer and Marge are both Associates in a MLM/NM endeavor. Homer is deaf and Margie is hearing. Both needs to upkeep through training. Marge picks up the phone and call in to the tele-seminar. Tell me how Homer can be entitled to the same provisions as Marge’s without needing to take the time to navigate this and that barrier?
Why can’t Homer simply pick up the phone and call in through the relay service and be on par with Marge in name of functional equivalency? Would it be too embarrassing for both of them to explain to their uplines how things are done according to the FCC? This is counterproductive.
If FCC bans tele-seminars I bet hearing upline Associates (especially top ones making millions) will look down at this situation and feel less inclined to make further accommodations to coach, educate and support the deaf in MLM/NM endeavors. If not for the relay service I know many deaf wouldn’t have any chance to succeed in MLM/NM endeavors. Deaf leaders alone can’t do everything in their power to do this and that. Some MLM/NM endeavors requires deaf to reach certain “pin” levels in order to be authorized to educate the deaf through vlogs and so forth.
I understand about academic courses from colleges or equivalent offered through phone but don’t forget that hearing students call-in using their own provisions so should the deaf too through the VRS.
Perhaps, it’s time to create newer classes of relay services: business class (one for corporate level and another for MLM/NM or sole-proprietorships), academic and so forth and charge a minimum fee and satisfaction will be commonplace.
Lastly, but not the least importantly, I have to admit that I know some laws, policies and what not on various levels (local upwards to federal) pertaining to the deaf were written with known premises that the deaf won’t need this and that. I guess it’s another reason why Audism exists.
to Robert Alfred Hawkins
You wrote: “Picture this scenario …”
Exactly. Laws written in 1990 could not fully anticipate the technology available in 2009. In 1990, Ted Harkin, et. al. could not picture the scenario you suggest.
Federal agencies write RULES to implement STATUTES written by Congress.
What Ed is questioning here is this: Do today’s FCC Rules correct interpret the intent of Congress in 1990? If Congress had anticipated VRS, would Congress have written a statute that allowed a private for-profit VRS provider to inflate their minutes by using Deaf/HoH marketing representatives to call Hearing individuals and businesses?
I suspect the answer is “no”.
Your question is: If Congress had anticipated VRS in 1990, would they have written a statute that specifically included Tele-seminars under Title IV for telecommunications access? My question modifying your question is: If the Congress had anticipated today’s business climate (too expensive to travel for training) would Congress have specifically included Tele-seminars under the Title III list of public accommodations?
The answer to both questions is: We don’t know until either a.) the Supreme Court rules on a specific lawsuit or b.) Congress revisits the statute and changes the language to include today’s businesses and today’s technologies.
A question Ed could be asking here is this: In lieu of additional funding or additional clarification from Congress, what should we – the VRS users – lobby for with the FCC? Do we want VRS minutes to pass One Billion Dollars per year and include marketing programs that guarantee full-employment for the Deaf and HoH? -Or – Do we want the FCC to regulate VRS marketing to keep the total annual reimbursement at a level that does not cause a backlash ending VRS?
Remember that VRS is not mandated in the statute, and is not required by any state government. There is nothing in any statute that “guarantees” our “right” to VRS. The FCC initiated VRS as a trial of new technologies. The FCC – with a new Commissioner – can END VRS with a single vote requiring agreement from only three commissioners.
The FCC could – for example – define VRS as a “standard and required” TRS service and toss it back to the individual states to contract and regulate. Or they could end the “new technology trial”, approve VRS but not require VRS, leaving it up to individual states.
So, now, back to the original question: Should we – the Deaf/HoH VRS users – ask the FCC to regulate VRS marketing that inflates VRS minutes beyond the use intended by Congress in 1990?
PS. I love this website because Ed’s comments always start an intelligent conversation – sometimes a debate – about the current state and the future of TRS/VRS services. Thanks, Ed!
Ed, what happened? I thought you were champion for function equivalent? Now you against it and want double standard, one for deaf and one for hearing?
Examples from this week only.
1. You support CSDVRS proposal limit equipment portability. Hearing can get equipment easy at any store. Deaf must wait long time on wait list. You think okay for deaf to wait.
2. You against teleseminar through VRS. Okay for hearing to do that but not for deaf.
3. We all know not enough interpreters. VRS will say “deaf employee get less rate—better hire hearing people so interpreter available for other deaf customers so get full rate payment.” Regular Phone Companys let employees makes calls without worrying about that. You want VRS to say “better hire hearing than deaf so get full rate” and end up deaf jobs suffer. That is not function equivalent.
Three examples you brought up this week that deaf people different standard than hearing people. I am sad. I want you go back support 100% function equivalent no matter what cost. There should be no price limit on function equivalent. I am not expert on ADA but I looked at ADA law and I saw no cost limit on function equivalent relay?
I desire you go back to leader of function equivalent. For example, push FCC to pay for more videophone so deaf don’t have to wait for long time or to beg for videophone while hearing can get cheap one at walmart immediately. Another for example, push that FCC pay for interpreter training and certification because deaf people tired of lousy interpreter and not enough interpreter resulting in long wait. Another: push for VRS to hire more deaf people in management and authority. Another: push for FCC to pay for broadband access so broadband access same cost as cheap phone line for hearing people?
Please go back to push for function equivalent requirement and how we can use funds to make deaf equal to hearing—instead of thinking of ways to limit deaf access to equipment, education and jobs.
Jan,
Believe me I am all for functional equivalence and have fought for it. What I’m outlining in my blogs/vlogs is exactly what Jk-II is trying to say. I offer interpretations of relay regulations as I understand it. It does not necessarily mean I agree with relay regulations. Tele-seminar is very good example of that. My personal belief is yes we should have that. It is just that the laws seem not to allow that. We need to let the FCC and at the worst situation, Congress know of our thoughts. I’m happy to say that there are several staff from FCC who subscribes this website.
By alerting the deaf/HOH of the limitations of relay regulations, I’m helping them become aware of the limitations and hopefully – will get them to take actions. If you look at my past vlogs/blogs, I would offer how you all can file reports/comments/expartes/etc to the FCC. I prob will do that again soon – worth repeating.
I’m with you, Jan. I won’t do it pretending that everything is all roses. Thorns go with roses and we need to remove the thorns.
As for other issues, I do talk with VRS providers and with FCC folks and also the movers and shakers who deal with FCC and federal agencies on regular basis (nice to live in DC for that reason), and I have made a few significant changes to these folk’s decision here and there. The whole purpose is to increase functional equivalence to the very top. That takes time. In the meantime, we need to be aware of our limitations, etc. so we can work from that.
Thank you, Jan, for bringing this up. I appreciate it.
eyes open & thumbs up,
Ed
I am currently a representative at a VRS company – Everyday, I witness their unethical practices designed to ramp up thousands of unnecessary minutes.
Reps would call potential customers, ask them to join in a bridged conference call so they would talk to each other via video interpreters. Then the rep would call a contracted call answering service to ask the customer a few questions, much like a survey before completing the dictated steps required by the company in order to “qualify” for compensation.
Not only that, this company would have daily conference calls 4-5 times a day with a moderator and reps. While requiring them to use this specific VRS provider.
Not only that, there’s a group of deaf people in this area that was offered positions with a specific VRS provider to call anyone/anywhere for whatsoever reasons or even no reason at all. An hour of doing that would earn them $25.
This kind of practice is pretty much everywhere which concerns me because we are close to topping a billion dollars. Surely the congress is gonna notice that not too long from now.
Yes, it is a catch 22 scenario. If we were to figure out an appropriate “break even” formula, that may open can of worms. Considering that it may FCC show what it takes for a VRS company to run on.
For example, when FCC sees that it costs $3 a minute for a company to break even, they may even impose that on all VRS providers.
Ethics is a sticky game.
Anonymous,
Thanks for sharing that. I’ve heard these stories as well. Ah, yes, ethics is a sticky game.
On the catch-22, I’m afraid you’re right. As I’ve often the last few times, the year 2009 is gonna be an interesting one albeit maybe an explosive and chaotic one.
Ed
Ed, you’re the dad of these explosive VRS industry growth! Whatcha gonna do about it?
Become a whistleblower for every VRS providers that comes in the picture of engaging in illegal practices that you come across? Or you’re gonna shut up and let FCC figure this out? Perhaps encourage reps to report this to FCC and hopefully the rep will still keep his/her job?
Nobody’s talking.
Hmmm! I agree with Jan and I also am for functional equivalence. I was taken aback when I noticed the change of your tone. I know how difficult it is these days and how the system is adapting.
Everyone is out to make a buck here or there. It is called a free enterprise. The definition is like this: “Business governed by the laws of supply and demand, not restrained by government interference, regulation or subsidy. also called free market.” from dictionary.com.
It would be nice to see it run its course. If there are abuses that hurt or undermine the goals, we can use laws as teeth to make things proper and above the table.
Considering the one who is hogging the system, it needs to adapt its system and be fair with other competitors.
After all, the concept was started by deaf and the hearing tends to abuse it. We need to tell them to back off and let us use the system the way we see it.
Figure this – with deaf contractors/employees, it helps wean them off the public funds. They pay taxes on earnings and put money back in the system. It seems like a win-win situation. Just a thought.
After all, we are chugging along as it is still in learning process.
Cheers!
Anonymous,
VRS is dear to my heart.
You’re right that FCC needs to take action, but often it is people who initiate changes. Whistleblower? I don’t work for any of VRS providers, but whistleblowing in itself is not necessarily bad as they often raised illegal issues that should be exposed.
No body’s talking? Oh, lot of people are talking about many issues and many of them are reporting to the FCC.
I strongly believe it is our responsibility to raise issues that we may be concerned about. Not to do that would be enabling VRS providers to do even more worse. Otherwise how can they clean up their acts if we don’t raise issues.
Also, the folks from Congress – like it or not – are looking at VRS. I want them to see a clean cut, ethical VRS industry operating and be proud of it.
Let the VRS take its course? Just like Gov’t did with businesses, and see what mess it got us into. No, if there are issues, VRS users and Video Interpreters and leaders need to raise them and VRS industry needs to be aware of them.
eyes open & thumbs up,
Ed
Just a thought for deaf advocate – you say that the VRS companies are helping deaf people by weaning them off of government assistance?
Many deaf contractors who work for VRS companies are not making enough money to support their families. There is no guarantee of how much they will be paid because it depends on how many customers they are able to recruit or install. That means many of them still rely on the government for assistance.
Are the VRS companies really providing the deaf community with good jobs and future potential if they are being hired only as contractors and are not provided with any benefits or guarantees of income?
Anonymous,
That is a good question. I don’t have answer for that as this is corporate decision.
If the federal gov’t decide to clamp down on several of “questionable” practices, it is possible many of these deaf persons may lose jobs. I worry about them.
It is like should gov’t clamp down on illegal drug market? To do so will cause many of poor Colombia families (farmers) who raise these plants lose their earnings that feed their families.
Tough situation to be sure. Before you flame me, I know it is not a very fair analogy. The point I’m trying to say if any, I mean not just in VRS but any companies that practice illegal actions, they should be stopped even at the cost of “grassroots” persons losing their jobs.
In VRS industry, it is not as easy because some of the practices “look” okay and seems to be functional equivalent when they are not. Relay regulations are “grey” and, often is hard to interpret.
I’ve said that many times before, FCC need to do better job of oversight. If any of these practices are “ok”, then FCC needs to come out and say so or not. Too many of us deaf/HOH as well as VRS providers are left hanging in the air and instead depend on corporate lawyers tell us whether this is ok or not. Obviously, most (not all) corporate lawyers are biased.
As I said, tough situation to be sure. It would be nice if VRS industry has a “backup” plan for these deaf/HOH persons who lose jobs because of federal ruling, and offer them alternative positions so they will not lose their livelhood?
eyes open & thumbs up,
Ed
To Deaf Advocate, a Question:
A business is not “free-enterprise” if the government is paying for it’s services. All TRS/VRS are paid for by the government through surtaxes on local and long distance phone bills.
Look at your own definition: “… not restrained by government interference, regulation or SUBSIDY.”
True free enterprise would be if there were no subsidy, that is: if the USERS were paying for the service, not the government.
Are you advocating that the government stop paying for TRS/VRS and that those companies require a credit card from us before they place our calls?
(jk)
On teleseminars…
People calling in to teleseminars that are actually wanting to learn the information and have no other similarly easy access to the information is fine. As a VI, it is frustrating to have calls to recordings that sometimes even announce that the script is available online.
It is frustrating to have the company I work for have a subdivision that is recruiting people specifically to ‘train’ them. This training entails 7-8 hours a day of recorded calls that of course use our company’s VRS service to interpret. They have conference calls where they direct their recruiters to overbook their VP stations because they need the VP up and running all the time.
They are having many ‘clients’ call in to all of the same recorded calls. If this is a required training for all clients, wouldn’t it make better sense to hire a skilled interpreter to video an interpretation of the recording and play the videotape for the ‘clients’ as a group. It’s frustrating when my co-workers are in the cubical next to me and we are interpreting the exact same recording for different people who are all sitting in the same room on different VPs. This means all the VI’s are on hour (or more) long calls with no breaks in between recordings.
It’s not frustrating to do the interpreting (though it does get exhausting sometimes), it’s the flagrant misuse of the VRS services.
We as VI’s should not be excited when we get a ‘real’ call. They should all be ‘real’ calls.
I completely understand your point of view by not naming the VRS providers or you would face backlashed – even facing lawsuit! I dont blame you at all for not naming these VRS providers…
I can share my experience with you…
1. Before FCC’s ruling on rate per minute, I could make a direct call to the VRS provider’s technical support agent but now I have to make a call via VRS provider before my complaint about the equipment and something like that..
Is that fair?? To my point of view – it’s a big NO!
2. I know a hearing person who made some calls via VRS (unnmamed) provider so that way VRS provider can earn a rate of minutes – just for chatting! Is that fair to deaf/HOH clients? NO!
It is something we deaf/HOH clients have to be very careful how to judge which VRS providers are honest….
I know it’s so hard and very sticky issue to think about rather than hurting us, deaf and HOH clients who use VRS providers daily!
How can we solve this and for the FCC to identify the “fraud” and eliminate the “fraud” by enforcing new ruling or something like that huh????? (SIGH)
Cheers!
Anonymous VI,
I appreciate your comments and suggestions.
I have heard the same thing as well from other VIs who do not want their names become public. A few of them said they already resigned solely because of that. They said essentially the same thing you said – do not mind interpreting “real VRS calls”; that is, deaf/HOH individual making “regular” VRS calls.
eyes open,
Ed
May,
Yeah – the abuses continue.
Hopefully the FCC will release public notice of clarificaiton on many of the actions by the VRS industry on whether they qualifies as bona fide VRS call or not; I hope the FCC does that soon.
Cheers..
Ed
May wrote: “How can we solve this and for the FCC to identify the “fraud” and eliminate the “fraud” by enforcing new ruling or something like that huh?”
Require all internet based relay calls to come from a registered LN.
Require all applicants for LN’s to document their hearing or speech disability the same way we document our disabilities for the state TTY programs.
This will eliminate fraudulent IP relay calls from overseas and will eliminate hearing people from making VRS calls to other hearing people.
The FCC will have to find a way to make the LN’s mobile so Deafies can use their registered LN to make a VRS or IP Relay call from their computer or their 4G cell phone when not at home … (and find a way to prevent an unethical person from “loaning” their registered LN to a non-disabled user.)
Then, the FCC should clarify the rules that VRS/TRS is for communication by one individual to another individual as the law is written (Title IV). VI’s could be instructed to disconnect from any recording that is longer than a standard answering machine message, setting a limit of 60 seconds – for example.
We did not object to registration and certification to get our free TTYs from state programs. We should not object to registration and certification to protect our VRS and IP relay services from abuse.
Anonymous VI on Teleseminars:
Please do realize non-live versions calls are offered in audio but there are times where there’s not even any archival offerings of audio. They make people come live. Credibility is part of the urgency to receive information live. This is the presenter’s viewpoint especially amid lots of the doubtful feelings flooding in the MLM / NM industry. One way or other text offerings are rare.
Simply put, audio is not accessible for the deaf and hard of hearing. Period. In all my several years in solicitation of information via phone as is essential to my business needs I never been told of any scripts being available in text. How about IP-based relay? No way, I was told it’s so slow. The sometimes paid folks who share the information are justifiably very protective about their works and they make sure solicitors get on the phone to dynamically receive information.
Again, doing presentations live adds to credibility of presenters. In some cases the live calls are readily archived in audio but requirements apply in order just to get it. Some calls require one having previously registered and paid for such calls. All of this leaves deaf and hard of hearing people out.
Automatic audio-to-text technology in name of quality isn’t here just yet. FCC has to create newer relay provisions even if it require a whole new order within the relay industry to further the deaf and hard of hearing’s demand for true functional equivalency in information acquisition by above means. VIs are hired supposedly with that prior knowledge. It’s a given in the industry. VI shouldn’t be surprised and complain about this and that.
The bottom line remains as is–when it comes to teleseminars and similar processes the deaf and hard of hearing are inconvenienced while the hearing isn’t. What’s your solution to this one dilemma involving solutions feasible for presenters of information? Where’s win-win scenarios?