Docketed Comment
7 07 2009All..
After the anonymous comment, I think it is only fair you know where I stand with VRS pricing.
Here is my docketed comment.
This is my frank and honest apprisal of the VRS situation.
eyes open & thumbs up,
Ed B
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I completely agree with your comment to the FCC chairman.
My sister and I made several attempts to remove Sorenson’s phone number but we failed!
I was told that it would be impossible to remove Sorenson’s phone number and then we choose which VRS we want to use as our primary VRS..
I found out that my sister and I were not only people who made several attempts and I now begin to wonder if Sorenson tries its best to play monoply (spell?) by making reports to FCC.
If so, how can we solve this problem?
Should we make a report to FCC or what?
Reason for me to make a comment like this is that I dont want to “jump into the conclusion” – just want to go thru the proper channel..
Thank you for all you can do for me and I do sincerely wish you and your co owners best luck to start your new business (smiling)
Read your comments to the FCC. Agree on many points but disagree on the basic premise.
A critical government funded service should not be subject to open free market competition which – by definition – delivers minimal acceptable service quality at the highest profit to the provider. Translation: consumers and tax payers get S****ED.
Critical public services – police, fire, relay – should all be contracted by government agencies based on a bid system whereby the awarding agency can first assure quality services and secondly provide the tax-payer with the most reasonable long term cost.
Um, Ed, a question: All those years you were the Relay Texas Administrator: Did you open Relay Texas up to wild west anyone can make a buck at any price free market competition? Or did you maintain a government procurement process that assured quality first and controlled costs over the long term?
Point taken?
Ed, that was a well reasoned and clearly explained position paper on VRS reimbursement. It makes a lot of sense and explains delay problems that I had seen with use of the VRS.
What I also would like to see is a separate type of reimbursement that gives VRS companies an incentive to upgrade their offerings.
For example, addition of services designed for on the road devices such as Blackberry and p3 and MVPs, Deaf business services, fax capability, and child friendly services. Perhaps this funding could also pay for focus groups of deaf consumers to study improvements in the system.
Thanks for staying involved and looking for ways to improve the service structure.
Retired State Regulator,
Point taken. It still may happen if FCC has its way and pass on the oversight responsibility of VRS to states.
Actually, Texas did look at multi-vendors approach in Texas, but could not find a way to make the overall cost lower than single vendor. So stayed with RFP for one vendor. New features only happen when RFP rolls around; a competitive environment, new features comes out right away. So there is pro and cons to both sides.
eyes open & thumbs up…
In California, Deaf and Disabled Telecommunications Program (DDTP) and California Public Utilities Commission had a multi-vendor relay program.
I would like to point out the pros:
- Promotion of competition between vendors which led to greater marketing efforts.
- A greater desire on vendors’ part to ensure the quality of service would be high enough.
- Different rates to 3 vendors based on their bid price.
The downsides were:
- The RFP was about 400 pages thick and that meant an incredible amount of oversight had to be executed in order to justify the RFP’s requirements. This meant a consulting firm was hired for this job along with DDTP’s staff members – additional costs were placed to CPUC and its taxpayers.
- Inability on the vendors’ part to be creative or innovative. Because RFP was generally restrictive, it did not make any business sense to develop any products or services which will be subject to approval (this means several months). To CPUC’s credit, they actually had a points system for innovation but… this meant oversight.
Robin
May,
This is one of ongoing issue about LN and video phone and who is the primary VRS provider. Right now it has not been worked out where a person can use – say – vp-200 and make CSDVRS the primary VRS provider. One can use vp-200 and accept SVRS as the primary VRS provider, but you can add other VRS providers to the address book and make VRS calls through that.
eyes open & thumbs up
Ed,
My only concern is that you seem to feel that terps are over paid. I wanted to let you know that I happen to work in a state where interpreters pay has not changed in about 10 years. For us, the fact that vrs companies are willing to pay more for quality terps has made many terps finally feel validated and respected.
Interpreters are the only professional field that are often not viewed as professionals. We are looked down on by doctors, lawyers and professors. Yet often we must have more knowledge and schooling then all of those fields combined.
I agree that changes must be made, but I do not feel that interps are overpaid.
nic terp,
I think once that frauds are eliminated, the call volume will reduce drastically – maybe as much as 30% or more of the overall total minutes. A couple of VRS providers earn their revenue from frauds as high as 80%; that is, manufactured minutes. So they can afford to pay high salaries for interpreters. So with frauds eliminated, the market realities will set in and video interpreters will earn decent and reasonable wages. Oh, I don’t expect Video Interpreters to be making in low $30K; no, they’re too far valuable for low salaries; I also do not expect them to make six figures either. For those of you interpreters who know me, know I have nothing but highest respect for quality interpreters; they’re symboites. I was going to say locked in the hip, but may give wrong impression (ha ha). Seriously, video interpreters are very much integral part of VRS scenario and demands the highest respect.
Thank you Ed for the clarification. Your support and respect is very much appreciated.
Ed, Again a well thought document but there is one element that is lacking if we are to avoid further docking of the VRS minute rate – the functional equivalency which should show a standard call made through VRS being at least four to five times faster than that for a TRS or IP-TRS – and this coupled with the wider efficiency savings for the deaf person PLUS the hearing person totalled together would show that the VRS rate is actually a bargain.
All the best
Jeff
Jeff,
Good point of which I used in the early days of VRS in Texas with my supervisors.
Ed-
Your FCC comment really nailed it. Like you, I want the VRS industry to be a sustainable endeavor that will still be there for us 5, 10, 15, or 30 years down the road. All of this VRS misuse, whether fraudulent or not, jeopardizes that.
Here’s the money quote; The USTA Comment had this: “For the upcoming 2009-10 Fund Year, the National Exchange Carrier Association (NECA) projects VRS demand upwards of 123.8 million minutes, with a weighted average rate per minute of $6.2972.15″
For the sake of argument, the size of the ASL-using community isn’t that huge. Let’s say 100,000 people at the most. People may quibble with this number. Dividing 123.8 million minutes by 100K ASL-using Deafies comes out to 1,238 minutes consumed per person per year, or 20.6 hours worth. While I am a VRS user, I cannot recall ever using more than 2-3 hours worth, if you were to aggregate all the minutes I’ve used in a given year.
The sheer numbers suggest that there’s misuse in VRS services, and such activities need to be curtailed if there’s to be a sustainable VRS industry.