Restrictions on VRS Features
20 01 2010Hello everyone
Quick disclaimer. I own edsalert and also a co-founder of Convo. So accept my vlog for what it is.
I want to share with you all of a disturbing trend that the FCC had adopted restrictions of certain VRS features without actually releasing Public Notices that restrict these features for VRS industry.
FCC is now giving directives to National Exchange Carrier Association (NECA) – NECA is the contracted account administrator who reimburses VRS providers - anyway NECA is not to reimburse any minutes by VRS providers that are processed for these following features:
- conference calls between deaf/hoh (those who do NOT work for VRS providers) and hearing persons
- Customer support services (for pagers, cell phones, etc from ATT, Sprint, Verizon, etc)
These two, in my opinion, are legitimate calls. Conference calls by non-VRS employees – just regular deaf/hoh to hearing persons should be permitted, not forbidden.
The telephone support services that deaf/hoh calls to get technical help likewise should be permitted.
The largest VRS providers are able to absorb the cost of these features so they do not submit these minutes to the NECA whereas smaller VRS providers who need every minutes are forced to block these features as they cannot afford to absorb these costs. So who gets hurt are the start ups or small VRS providers.
Other non-reimbursable features are:
Podcast
online education (this one there is a FCC public notice forbidding that but specifically to “class room” situation)
some cases webinars
These three are debatable and controversial. Title III of ADA Act or Section 255 of Telecomm Access may apply on some of these “non-reimbursable” minutes.
However, I agree with not allowing class room as it really is the responsibility of educational institution to provide access for the deaf/hoh.
Strongly suggest that if you feel strongly about these non-reimbursable minutes, let FCC know. If you want to file complaint, use this link. Be sure to fill out both sections. Looks complicated, but when you read them, not too bad.
Remember FCC will typically do not act on issues unless enough deaf/hoh complains. So complain away…
eyes open & thumbs up,
Ed B
long link:
https://esupport.fcc.gov/sform2000/formC!input.action?form_page=2000C
Ed,
The customer support calls can be very broad to calling, say, Hoover for a defective vacuum. Hence my question: Do you have links to these directives that may explain what defines a customer service call and what defines a conference call between deaf/hoh and hearing people.
This is not good. I know of several deaf/hoh professionals who work from home and call into work, just like ANY OTHER HEARING professionals working from home do. We all have had to make customer service calls at one time or another for our electronic devices.
Boy, this isn’t good.
Todd
*disappointed* I definitely will share my concerns with FCC.
I’m just thinking here.. While this decision is in effect to spin this around in our favor, perhaps VRS users should use the smaller VRS providers (i.e. BISVRS, Convo, and others) in making VRS calls and flood the larger VRS providers with the calls of which NECA would not reimburse (conference calls by people outside of VRS & customer support hotlines).
This way the smaller providers would conduct billable calls & be reimbursed without burdening them to do either; (1) reject our calls (2) suffer undue financial hardship. Finally, I have no concerns for the bigger providers being flooded with VRS calls that are not reimbursable for two reasons; (1) I don’t support them (2) We, the VRS users & the community, have not benefited from the dollars they have profited from.
In short, here’s exactly what I will do. Use my preferred provider, Convo, to make all calls except the conference calls including calls to customer support. I’ll use Sorenson for those type of calls knowingly they will not be reimbursed. The power is in our hands..literally
I was unable to view your video since it was set as private?
Hello Ed,
I tried to open your Video Vlog related to VIU or VRS Providers with FCC, for some reason, it would not open for me to view it. Just thought that I’d let you know that you or I may have a problem with this but as in the past, this is the first time for me to experience this.
Best,
Jea
Hi Ed –
I think we should make clear that a critical consequence of the trend is that several VRS companies have started to decline handling categories of calls which they are not being compensated for.
I also want to express my strong disagreement with your view that distance learning or remote training are not a legitimate use of VRS. The FCC has never decided that these calls are not a permissible use of relay. The ADA is not a statute which provides for specific and exclusive coverage for our access to services, and has been clearly interpreted as permitting several separte provisions to apply to a suituation. For example, in the case where a private entity presents on a certain topic to a company’s employees, the DOJ has stated that the ADA poses a dual responsibility under TItle 1 for the company and under Title 3 for the private entity to provide an interpreter for the company’s deaf employees. Federal regulations provide employees of state governments with coverage under both Titles 1 and 2 of the ADA. If we take your logic to the extreme, then deaf students or employees could never make school or work related relay calls as they are entitled to under Title 4, but always need to get an interpreter from their school or employer under Titles 1 and 3. The ADA doesnt work that way. And our real world experience doesnt work that way given the enormous economic/budget crunches that have caused eduicational institutions and employers to cut corners including the provision of accommodations to deaf people.
I do agree that the FCC should stop trying to legislate policy through the reimbursement process and issue a notice of rulemaking which allows stakeholders to provide them with their comments about what consitutes legitimate use of VRS.
-Jeff
Sorry folks. My mistake. I made vlog “private”. It is now accessible.
eyes open & thumbs up..
Jeff,
I very much appreciate what you are saying. The truth is I agree with functional equivalence concept and your underlying interpretation, but I do remember seeing a statement from FCC that classroom (University) is not permitted for VRS – that one, I think is right. You’re referring to other circumstances. Oh, boy what tangled web the FCC regulation and lawyers (no offense intended) has woven.
Ed
Todd,
I think customer support service is limited to telephone companies that have VRS as part of their services – but am not absolutely sure, though.
eyes open & thumbs up..
Ed –
We are not talking about deaf students being in the same room as the instructor, that would not be a permissible use of VRS and would be characterized as VRI for which the educational institution is responsible for the cost.
We are talking about deaf students accessing their classes through distance learning, which is a rapidly growing trend for the public in using their phones to access classes and encouraged by educational institutions to give people more access to educational opportunity and reduce their “bricks and mortar” costs. To deny deaf students the same opportunity to access those classes through VRS is not only wrong, it is illegal under Title 4 of the ADA.
-Jeff
for Classroom- it should be billed per hour Min $35 per hour. not $6 per mins… That will prevent FRAUD!!!! It’s all about per mins. I hope FCC will set a flat fee per hour for conference calls, classroom, etc…
so.. I cannot do my job as a blackberry specialist at my place of employment ? most days I can fix,repair and solve almost any issues, some time some issues require a more serious solution, and it requires me to call sprint, and we work together to get it up and going, or transfer phone numbers to new cell, or other things that I cannot do at my end, and these calls end to run 15 minutes or even more, due to the fact of a few things
1. high demand, thus, on hold for a few minutes or more
2. highly technical phone calls, which requires me to use a specific VRS provider because that provider has on screen texts for account number verification which tends to very long ie: A9900005940593, PIN: 30a94ef which sometimes are confusing for F = 9, and etc.
and now the VRS company wont be reimbursed for this ?
I feel I was using VRS as an legitimate use of the ideal of VRS.. guess its back to email and wait hours to get my issues resolved/or lose my part of this job to someone who can hear/speak on the phone (hearing person) which does not really sit well with me at this moment.
Lately, I’ve been trying to switch over to a VRS company that is for us, by us – but I’m afraid they will say “I’m sorry we cannot do this call for you..” etc
btw, make the Complaint Form font bigger/bolder so everyone else can just scan down your post and find it quicker.
Thanks..
You mentioned that conference calls between deaf and hoh are forbidden for those NOT with VRS companies. Does that mean that VRS companies can do it, or are they already forbidden by a previous policy.
Pat
Pat,
FCC is very strong on not allowing VRS employees to make conference calls. So yes they are forbidden as well.
So regular VRS users and VRS employees are in same boat.
Remember some of the VRS providers will process conference calls for regular deaf/hoh but will not submit the minutes to the FCC for reimbursement.
eyes open & thumbs up..
Ed – I may miss the discussion of FCC statement on this matter. Are you stating this has officially now started? The reason I asked was because I had a friend telling me about ConvoRelay decided to not pick up any recording messages from Customer Services and/or Technical Support Department. My friend was disappointed in ConvoRelay for this kind of service that offers now. When I was contacted by this issue, I was puzzled because that clearly violates his rights to function equivalency as outlined by the ADA. Is this a true statement ED? As I stated I may overlooked this issue that now is starting to be a problem. If that is the case, that surely does not warrant function equivalency. This need now ATTENTION to get this prevented.
THanks!
-james
James,
Good question. No official announcement yet. The minutes that Convo and other VRS providers were not reimbursed for these features (they say pending review) so what does that tell you?
Agreee absolutely that this needs attention NOW.
eyes open & thumbs up..
[...] read informatoin from Ed Boson Ed’s Telecom Alert Restrictions on VRS Features Hello everyone Quick disclaimer. I own edsalert and also a co-founder of Convo. So accept my vlog [...]
Makes me wonder why the FCC issued these directives to NECA in the first place. First off, some questions…
Would conference calls involving just ONE deaf person be reimurseable by NECA? I mean, it’s just like a regular phone call, except that there’s several hearing parties involved. For example, if I have a legal case in Tampa, FL, and the opposing counsel is in Orlando, FL, and the judge wanted a telephone conference. Would I be able to participate, being the sole Deaf caller?
BTW, these were just rhetorical questions; no need to answer. However, it does illustrate the urgent need for public comment in a formal rule-making process.
Also, I found it curious that NECA would not reimburse VRS providers for technical support calls involving messaging pagers and smartphones. What would be FCC’s rationale in deying reimbursement for these calls? Have they uncovered recent fraud along those lines and decided to take reactive action? So many unanswered questions, and we need the benefit of transparency in a formal comment and rule-making process on this issue and many others.
Thank you for spreading the news regarding FCC’s ad hoc policy initiatives affecting the VRS industry.
Are you sure abou the customer support to other phone companies not being reimbursed? I think this issue may be confused with not allowing VRS companies to bill for customer service calls internally – meaning that VRS providers can’t connect their deaf customers to a hearing phone operator for technical support.
Related to this is my blog on a company refusing to take an order because I used a relay service and/or gave a relay number as my phone number.
As you suggested I have communicated my displeasure to FCC about access to technical support services by relay. This threatens my technically-oriented business and I DO have feelings about that restriction!
Following is the text of my FCC complaint:
>>According to information received on the internet today, it appears that I cannot use the relay services to obtain technical support for the dozens of electronic equipment that I use in my business. I have used many of these support services by relay successfully and depend on them to maintain my business. Please do not rule out payment for this type of telephone access for deaf people. I truly would be out of luck and my business at a standstill if I could not obtain technical support by relay.<<
For educational institutions and employment situations, is it needed to do this through Video Relay Service? Couldn’t these educational institutions contract with a VRI provider to provide these services as a reasonable accommodation. It certainly is more efficient and a lot cheaper.
Legally, is it appropriate for an educational institution to avoid meeting its obligations under the ADA by passing on the costs of the reasonable accommodations to the Interstate TRS Fund?
While there are clear cut situations, I recognize that there are situations where everything isn’t so clear. However, the ADA place the obligations of providing reasonable accommodations on certain parties in certain situations, where the relationship between two parties are stronger such as employer-employee (Title I) or paid providers of service which include education, government activity, etc. (Title II). Yes, the legal obligation to provide an accommodation is there and I am not saying that such requests should be denied, but the question is exactly who is responsible for covering the costs?
I believe that the FCC is acting this way to ensure that certain parties (under Titles I and II) are meeting their ADA obligations and to prevent TRS from being overtaxed. As to the question of whether they’re overstepping their boundaries, I don’t know.
With that all said, if the FCC is refusing to review this again, perhaps legal action is needed to resolve these issues if you and/or other providers believe further action is necessary.
Vinny: why should VRS use be encouraged in situations such as these? Does the use of VRS mean that the effective communication requirement has been met on behalf of the government through the courts?
Also, are you okay with the courts saying, hey, let’s save some money and call VRS every time a deaf defendant appears before the court?
Or you would prefer interpreters with certification in legal interpreting among other credentials? If so, having an interpreter in person or thru VRI would ensure that the ADA mandate is being met. And honestly, I don’t think Congress intended TRS to be used in every situation we encounter in our daily lives.
Hello, CNW-
IIRC, you’re also an attorney, right? Then you should know about ‘virtual law practices’. (For the unitiated, check out ABA’s coverage on this topic.) I’m thinking of setting one up, providing legal services statewide in Florida. Technology, especially VRS technology is essential if I am to have a successful practice. There’s a lot of hurdles to overcome first, though, and I’m not currently practicing law now.
And in the above example, I forgot to mention that I’m in Miami, FL. So… a teleconference is an ideal method in that situation. I see no reason why it should not be reimburseable as it would be treated as a regular VRS call involving only one VI agent. Obviously, if I am to appear in court, I would require that they provide a reasonable accommodation.
The fact we’re having a debate here in Ed’s Alert is proof enough that the FCC should open this issue and other issues germane to VRS reform for public comment and formal rule-making. No more ad hoc approaches in reforming the VRS industry.
Ed,
Thanks so much for your awesome vlogs! You are right on the money (most of the time).
I think these “pending” issues will be resolved soon. Time will tell. Maybe I am wrong. “Word on the street” is that the FCC got wind of some practices that they did not like. For example, some companies were encouraging “Deaf Chats”. Various Deaf persons would call in to a conference line thru a VRS provider. They would all chat about whatever they wanted (nothing serious!). There were no HEARING people in the conference. It was all interpreters interpreting for Deaf people. The FCC says there has to be hearing and Deaf on the line.
The other issue about customer support services is like the post above. The FCC doesn’t want to encourage “in-house” customer support going thru VRS. Can you imagine it? Have many hearing technicians and force Deaf people to call thru VRS to get their VP working again. Why not create a “bug” in our VP and keep your tech line and video interpreters working 24/7?? Ha Ha
Ed,
Thank you for the vlog.
I read your perspective as well as Jeff Rosen’s on distance learning. I agree with Jeff that using VRS for remote training or distance learning could save a lot of money especially in today’s economy and it will enhance the participation of deaf people in education and technical training. This will have a positive impact on the economy because once they get an education or acquire new skills, they will enter the workforce to make income (and pay taxes which will generate new revenue for the government). We need to recognize that the barriers we are facing still exist and using VRS is an alternative way to overcome such barriers for those who strive for better education or job.
Functional equivalence is another issue and I agree that we must ensure that what’s provided to hearing people must be the same for us, deaf people. I am currently an Ed.D student and I take online courses. Occasionally, I have an audio-based discussion online and it’s totally inaccessible for me. It is extremely difficult to get an interpreter because an audio-based discussion is requested in a last-minute notice or the pool of available interpreters is so scarce. To address this issue, VRS would be a good alternative. I agree with Jeff that this is a matter of functional equivalence and they (FCC) need to acknowledge that there are problems with communication access in the educational world and some of them can be resolved by using VRS.
Again, I don’t think that FCC realizes how the use of VRS would have a positive impact on the economy and too bad there’s no organization/agency (unless I am mistaken) that complies data to support that.
Filed a complaint even if I am not sure what the FCC’s definition of a conference or technical support call is.
I didn’t like how they did not issue a public notice, that’s unacceptable.
I can understand that the Viable mess has the FCC worried about abuses, but they need to involve the community in making these kinds of decisions even if they are footing the bill.
Awesome comments, folks! You do me proud! That is the stuff that movers and shakers and decision-makers need to see.
And, of course, the important audience which is you deaf/hoh people need to be aware of the hidden activities that are not always publicized. Pros and cons are extremely helpful for us to better understand the circumstances.
Keep the comments a-coming! By the way, FCC folks do read edsalert ;-]
eyes open & thumbs up…
If this is true, this is going to cause a major backfire(s) on the deaf/hoh community. Here is why.
If FCC doesn’t consider conference call “a legitimate call”, then VRS companies are not obligated to process the call. Business perspective….. Why would the VRS companies bother with the conference call if that is wasted money? In due time, all VRS may stop offering conference calls. If that is the case, this will affect the careers of the deaf/hoh people who use conference calls. Functional equivalent is out the door.
Another perspective….
Also, I feel encouraged to call the larger VRS companies and let them pay the price. This action is to preserve the smaller and newer VRS companies. Remember, this is America…. a free capitalist country and FCC should endorse this philosophy.
Many of the distance learning programs like Phoenix and Kaplan are not lecture based and do not require that much VRS to keep up. If a student contacted a professor by phone during “virtual” office hours, I don’t see how the FCC could prevent that conversation from taking place.
Most online college materials are text based so they can be accessed at any time of the day or night.
This post made me think about why the FCC made theses decisions in the first place. Clearly, the FCC feels that they are being ripped off by VRS companies making illegitimate calls. For example, a VRS company can host an unnecessary and made up conference call between hearing and deaf people, just to earn extra money. I have heard of several VRS companies doing this.
As for classes, I agree that the Universities should be responsible for providing accommodations, however, the reality is that everybody “passes the buck,” saying that someone else should be responsible, and the fight goes round and round. I’d hate to have to approach my professor and say “sorry, but you’ll have to caption all of your audio information.” It’d be much easier if we could have as much accommodation as possible.
I am also keeping in mind that VRS companies can still process these calls, but they won’t be reimbursed for it.
I agree with those who said conference calls should be a legitimate call. I can’t see why FCC would ban these types of calls if hearing people have access to it.
On the subject of tech support calls to the mentioned phone companies, I can see where FCC is coming from. If I have a Sprint phone I should be able to use Sprintrelay to call in for tech support and they can provide the service without charging the NECA fund. It would be no different than asking them to provide an interpreter at their expense. There are a couple of problems with this.
If I have a Verizon phone which relay do I use. I’ve never heard of Verizon Relay. They may be affiliated with another VRS company but as a deaf person I might not be aware of that. Will Sorenson tell which relay provider I need to call to get tech support? I highly doubt it. Why risk losing a customer to the competitor?
What if Sprintrelay won’t take the call even if I have a Sprint phone because they know they wont be reimbursed? Unless there is some law or policy forcing them to take the call there is nothing stopping them from refusing it. I would be out of luck since other VRS companies will not be reimbursed.
Another point I would like to bring up. Those of you who are saying that they will use the larger companies to make these kind of calls because they can absorb the cost…well, there is nothing stopping them from refusing to take the call other than the risk of losing loyal customers. My bet is that most will adopt a policy of not taking these kind of calls in the near future.
Last year Sorenson adopted a policy of not taking calls from text relay (ei a deaf person uses TTY to call a deaf person on VP) even though they probably could afford to absorb the cost.
Conference calls – that is a real tough one for the FCC as I used to work in a company that carries out many conference calls and the main issue here is that they often ask their managers (us) in the same building to join in a conference call rather than book a meeting room for us to meet face to face as it is more efficient to do this to discuss a single issue or task. This proves difficult for regulators to accept as valid or regulate….
I had a full time assistant who interprets for me so it was not an issue then but if I did not then I would certainly be much disadvantaged if I was unable to use a VRS service to the extent that it would affect my position and status within that company….
So the blanket decision need to be reviewed and adapted for certain situations like this and those already highlighted above…
Webinars? I use webinar lot. Lot of businesses are moving into this direction.
Classroom? VRS? I am an grad student taking online. VRS is a must.
I am going to file a complaint now.
Thanks for sharing.
An application that I had not thought of before would have been handy when I was taking courses in a hearing college. Much of the material was posted online as uncaptioned Internet video tutorials. How could I understand talking heads or voice-overs explaining technical procedures?
Suppose I had used video relay to hook into these videos and thus obtained material for my course…would that have worked, let alone allowed?
Since this goes into a gray area between telephone access, internet access and educational access, this may be a moot question. However, it illustrates the no man’s land that we Deaf frequently find ourselves in.
Ed -
First, I wanted to thank you for providing us with your informative blog – it’s actually helping me with my job, I didn’t have a copy of the CSDVRS Ex Parte letter to the FCC from Jeff… That’s going to help me draft a letter that Jeff asked me to help him on!
Second, I have NO DOUBT that I’m the first, and certainly not the last person who wants to thank you for helping the VRS industry get a start in Texas. Before I started working for Jeff, I knew very little on this matter and didn’t realize how much it impacts my life…
Last, but not least… My roommate has a job interning for the Navy, and at her work another deaf employee recently was hired. They both do not have videophones to use at work, and would love to have one. I believe security was an issue that her boss brought up… Do you know of any similar cases (and I’m certainly going to talk to Jeff about this, if he doesn’t read my comment first! He’s got a busy day so I’m just waiting til things slow down a tiny bit) where a deaf federal employee had to fight to get access to a videophone?
Again, many thanks for a wonderful blog!
These persons who filed complaints to the FCC are making an impact. Those of you who are “thinking about it”, please file complaints now. Recently learned that Interstate TRS Fund Council is now concerned and trying to find out facts.
So file away…and make an impact!
eyes open & thumbs up…
Wonder is allowed for VRS to do reimbursed call for owner/employee of VRS company call their own VRS???
DeafCat,
These minutes have been withheld by the NECA for that reason.
I have submitted a suggestion to the FCC where if VRS staff uses its own VRS, the minutes should be reimbursed at the video interpreter’s salary plus little over head costs. It will not be $6.43 per min; probably less than a dollar per min. No decision made by the FCC at this time.
Strictly speaking – TRS regulation does not forbid that. However, because of the abuse by a few VRS providers – FCC has decided to “withhold” these minutes pending review…
eyes open & thumbs up…
Ed.. are you telling me that the interpreter’s salary and overhead costs amount to less than $1 a min?
I’m dumbfounded, seriously… where does the other $5.50 go? So the actual cost for providing VRS is like $60 an hour, so what does the other $330 go towards? Marketing? Executive compensation? Bad business decisions?
This may explain howr Viable was able to give out $2-$3 per minute to its cronies for doing these calls and yet still have a lot of $ leftover.
On a related note, I was checking out VRI rates and they’re like $50-$75 an hour with last minute requests at like $100 an hour with extra charges for credentials like legal interpreting, etc. If the set up is basically the same as VRS, I still have a hard time understanding why VRS costs the TRS Fund $390 a hour if essentially the same service would cost me like $60 an hour if I asked for it myself? I understand the rules that would push the VRS costs upwards such as 24/7 service, speed of answer requirements, etc. but I don’t understand how those requirements would push the cost of a $60/hour service to $390/hour.
Can you please help me out? You’ve argued for transparency in the rates, so can someone spell out what exactly is being paid for with the $6.50 a min rate?
CNW..
Very good questions. It is probably reason why I am not an accountant. That was my “educated” guess.
Managing a VRS is lot more complicated. For example, to run a call center requires horde of equipment, technical platform, high speed internet to support number of stations (video interpreters), etc. of all which can exceed a million dollars. To say nothing of the administration people who are needed to monitor various aspects of VRS. Let’s not forget marketing and sales work.
It is reason why I said salary plus overhead costs for reimbursement of VRS conference calls by VRS staff. Salaries of video interpreters varies a lot. My guess of the national average is probably around $35 an hour. 35 divided by 60 = .59 so about 60 cents per min. Let’s not forget the building, equipment, high speed, etc. then to divide them by number of stations would give you approx overhead. So with my wild guess, I would say $2 per min for conference calls made by VRS employee would be reasonable (?).
FCC or NECA are in much better position to calculate that as they know all costs in managing VRS as they receive these vital information from all VRS providers.
Now to help VRS providers make money. Keep in mind that right now only one company has about 80% of the market – we should not look to that company for good reimbursement rate as that company makes money out of high call volume and high call volume is easier to make the system more efficient. The current reimbursement rates probably could stand to be little bit lower, but not much. It really is expensive to run a VRS as I’ve discovered. The tiered rate plan for VRS seems to be a good idea except for a few issues. I have submitted an ex parte letter to the FCC regarding this very issue.
Hope this info will help you better understand the expenses of managing VRS.
eyes open & thumbs up…
Another consideration in the reimbursement of conference calls is that they require more than one interpreter–a team. So those resources are utilized but company is only reimbursed for one interpreter’s work, not two.
Ed,
Would it be possible for you to post the ex parte letter you just sent to FCC regarding the VRS costs on the Ed’s Alert website?
KJT,
Try this link:
http://fjallfoss.fcc.gov/ecfs/document/view?id=6520221125
eyes open & thumbs up…
Betty: I understand that for these conference calls, each employee would call into a bridge (800 #) using their own VRS interpreter. So, all of the interpreters’ work are reimbursed. Very much inefficient if you ask me, but a very good cash generator.
On a serious note, the very fact that the employer provided an 800 number for its deaf employees to use for work purposes clearly makes this a Title I issue.
But again, FCC is only prohibiting conference calls where there are NO HEARING PEOPLE involved at all. As I understand, the FCC will reimburse for any conference calls that involves at least one non-VRS user.
Ed, thanks for your answers. Yeah, Sorenson is like the Wal-Mart of the VRS industry–highly efficient, high volumes, huge economies of scale, etc.
Playing devil’s advocate here: as you know that the ADA’s public interest with TRS is to ensure that the deaf are able to access the telecommunication networks, would it be entirely justifiable for the FCC to decide that to make things efficient (which is an ADA mandate), only there will be only one provider? Since one company can do it a lot cheaper than everyone else, so what would be the point of ‘wasting’ $ on VRS providers without high call volumes?
As you know, the FCC can completely rewrite its regulations as long as it justifies its decisions via the Administrative Procedures Act. Title IV only has a few statutory requirements (confidentiality, efficient, etc.) and the rest are just regulations from the FCC. FCC’s responsibility is to ensure that the deaf are able to access the telecommunication networks–exactly how that would be done would be completely at their discretion. In fact, competition is not mentioned at all in Title IV.
Of course, I’m playing devil’s advocate with a lot of hypotheticals, and this certainly won’t happen, but I’m just saying that the FCC has a lot of leeway here in terms of what to do, as long as its justifications are reasonable.
CNW,
One slight correction: FCC is giving directives to the NECA to hold back lot of conference calls that were between deaf AND hearing persons.
On ur playing devil’s advocate: as matter of fact, I believe one VRS provider idea is one of the items that the FCC is considering. Incentive and new features would be minimized big time. Something I have observed the difference between RFP and competitive market. With RFP, new features only happen with new proposals while with competitive market new features and innovations constantly are happening.
Ah, competition is mentioned in Title IV – just not the word. If you read Title IV carefully, it prefers that ALL telephone companies of state provide relay service – in that itself is obviously competitive. That’s the first choice. Then as if after-thought it allows alternatives which is what all but one state adopted; via RFP – one provider. It is interesting how this works out.
For you historical buffs, a few states opted not to release RFP – what happened? State Telephone Association would release RFP – usually one to several pages (average RFP from most state gov’t is about 75 to 100 pages) so state association can choose one instead of having all telephone companies provide relay service.
eyes open & thumbs up..
CNW,
Add to the first paragraph – it is between non-VRS deaf employee and hearing persons.
I don’t mind sharing what probably should be considered proprietary info: Convo processed .003 of conference calls by Convo staff; and rest of conference calls – 6% of all Convo calls – were done by deaf outside of Convo. Keep in mind ALL of these conference calls involved hearing persons (two or more hearing persons). These were not allowed by the NECA/FCC for reimbursement.
eyes open & thumbs up…
Just one additional comment… Say there are five employees getting together for an hour meeting. One of the employees is Deaf and uses a sign language interpreter or one person is not deaf and uses the interpreter. Five employees each making $35.00 dollars per hour in a one hour meeting costs the company $175.00 plus+ (unseen costs such as time drawing up the agenda, office machines, use of the conference room, etc) One sign language interpreter at $35.00 per that same hour or even a 2 hour minimum at $70.00 per hour. How is it that the complaint is the expense of the Sign Language interpreter? In looking at cost. The interpreter cost is minimal in consideration of total cost…. and we have not even considered the cost of hiring alternate personnel to cover work while the five individuals are away from their desk in a meeting…. I am weary of defending the cost of interpreters being such a huge obstacle. In relation to the cost of business, the general cost of personnel, interpreter services are a great value!!
Is there a similarity between the Supreme Court’s recent 5-4 decision by allowing the rich manipulate the elections and the FCC’s unilateral restrictions that promotes monopoly?