FCC Comments on Health of VRS

10 05 2010

Folks..

FCC asked me to post this message to you all and I am happy to do that.  For anyone who knows TRS, Karen Strauss is a well known advocate for "functional equivalence" for deaf/hoh.   Joel Gruin clearly is a top dog in TRS issues.  So read the message and know VRS will not collapse.  

eyes open & thumbs up,

Ed

"A Message from the FCC’s Consumer and Governmental Affairs Bureau to the VRS Community
 
You may have seen claims that the video relay service (VRS) program is threatened.  This is not true.  The FCC is committed to ensuring the provision of high quality VRS to all individuals who need this service.  The Americans with Disabilities Act (ADA) requires telecommunications access that is functionally equivalent to voice telephone services for people who are deaf, hard of hearing, or have speech disabilities.  The FCC continues to believe that VRS is the most functionally equivalent form of relay for people who communicate using American Sign Language (ASL).  We stand ready to meet our obligation to preserve and protect the VRS program so that ASL users and hearing people can communicate with each other over distances.  This was the goal of Congress in passing the ADA and it continues to be our goal.
 
Here are the facts:  On April 30th, the FCC released a Public Notice (DA-10-761A1.doc) asking the general public for feedback on what VRS providers should be paid to handle VRS calls for the next year.  The Public Notice seeks comment on reimbursing providers based on the actual costs that VRS providers themselves claim to have incurred over the past few years to provide VRS.  The only way to safeguard the VRS program is to adopt reasonable rates for all forms of relay services.  Thus, it is our goal to adopt rates that are rationally based on the reasonable costs of actually providing VRS.  We welcome all comments on our Public Notice, and will take all feedback into account to determine the next VRS rates.  The VRS program will continue to provide the excellent communication service that you need.
 
Joel Gurin, Bureau Chief
Karen Peltz Strauss, Deputy Bureau Chief
"
 


Actions

Informations

122 responses to “FCC Comments on Health of VRS”

10 05 2010
Anon (19:01:23) :

Kudos to FCC. Especially after the tough year they have had to go thru cleaning up the VRS industry, it’s good to see that they’re trying to make VRS right – qualified service that is functionally equivalent and full of innovation as well.

10 05 2010
Dave (19:09:30) :

Well, I’m disappointed FCC didn’t point finger @ one of VRS for starting this madness scare tactic. I’ve been paged and emailed by many people; I explained it’s not true.

Hopefully FCC will summon that VRS provider and give him a nice spanking for being naughty.

10 05 2010
Diana Herron (19:25:46) :

Ed, first of all, thanks for publishing this comment from FCC.

I was wondering what the FCC really is attempting to do with the VRS. I am thrilled to see that they believe that VRS is the most functionally equivalent to voice telephone service that we have today. I am also thrilled to hear that they are committed to ensuring the highest quality of VRS to deaf and hard of hearing consumers.

I would like to have a better understanding of what FCC sees as a true functionally equivalent to voice telephone service. As a VRS consumer, I hardly see the VRS as it is today having achieved a “true” functional equivalency to voice telephone service. We are far, far from having reached functionally equivalency. I would like to understand how does reducing the rate helps our effort to become truly functionally equivalent to voice telephone service? If they wish to promote functionally equivalent to voice telephone service then wouldn’t it make sense to at least keep the rate as it is for now?

My concern that the FCC seems to be buffing up their muscles in an attempt to take control over the much needed regulation of VRS but is inadvertently causing a serious damage to our current level of service and technology and impeding the much needed growth towards being truly functionally equivalent to voice telephone service. FCC….please wake up and smell the coffee!

Diana Herron

10 05 2010
Betty Boop (19:40:17) :

So which is not true? FCC planning on cutting rate of biggest company by 40% while reducing smaller companies 1-2%. Or big company saying we cannot continue to provide same level of service at that rate and will be forced into bankruptcy? First is on FCCs website. 2nd is opinion of company that it informed its employees and FCC based on their knowledge of their business.
Now i am confused. Both are so, but FCC say not so. Maybe they try to scare company by saying cut rate HUGE amount. Wait and see. Dusting off TTY.

10 05 2010
Tousi (19:45:06) :

Diana Herron, I see what you are saying but in a nutshell, let me say that perhaps when something is free, what can ya do?

Betty Boop, if you look at the three-tiered rates carefully, you will see FCC’s rationale.

10 05 2010
wd (20:02:38) :

I read both sides of the issue.

What is NOT being addressed – reduced rates at the expense of tech support.

This is an area of concern since without tech support there can be no better developments along the way to deliver individualized preferences.

10 05 2010
Diana (20:19:35) :

Betty Boop, (I like your name!)

Anyway, what do you mean by “when something is free, what can you do?” No…that’s not true! We, deaf people, do not have to settle for less just because it’s free! ADA spells out clearly that we have the right to functionally equivalent telephone services that hearing people now enjoy. We need to demand that our rights be preserved — free or not!

I do not see FCC’s rationale with cutting the rate. It is not about whether it is one, two, three, or more tiers of rates. Bottom line, we all loose when there’s a rate cut. All VRS providers will suffer either immediately or eventually. FCC says that VRS industry will not die…we don’t know that! What we DO know is if there is a rate cut then the quality of service goes down and technology innovations stop.

Stand up and demand for what is rightfully yours!

Diana

10 05 2010
Diana (20:24:39) :

Oops…sorry, I meant Tousi, not Betty Boop, who was referring to “when something is free, what you can do?”

10 05 2010
Ricky Dockter (22:53:29) :

Hi Ed, I am starting to wonder after some long issues related to cost, expense, how much per min etc…. (that is not first time). Do we the taxpayers have the right to know how the VRS companies spend their money, especially the payrolls in higher rank personnels like CEO? I believe the misuse of payroll in higher ranks of staffs do have effect on their budgets. For example, see what happened to wall street and others. There is obviously difference in between being well paid and excessive paid.

Thanks!
Ricky D

11 05 2010
anon (04:26:36) :

Ed

Thanks for posting this message as I was sure FCC would make a statement on this. I was quite impressed how they responded quickly stop the spread of misleading. How can Sorenson Communication do that to their own consumers. This is not my position to state this but the person, Ron Burdnet of Sorenson Communication who started the VLog to all the consumers NEED TO GO! We do not need another problem again.

Thanks for the post!

11 05 2010
jncutt (04:29:50) :

I have read the post stated by FCC and glad they did it in time. Great to re-post it here on your site. I do get calls from consumers asking me for clarifications. it sure helps to “quickly put the fire down”.

Thanks

J

11 05 2010
Nick Vera (04:52:34) :

Hi Ed- Good Morning! Double Thumb-Up! Thank you for sharing with us for the clarification and truth from FCC. I certainly hope VRS companies will continue to empower their customers to maintain the essential communication through ASL convenience. Cheers!

Nick

11 05 2010
arpy (04:54:40) :

Good for FCC for responding to scare tactics and hysteria! And I agree with Tousi, it can’t both be “free” and unlimited, not when the true costs are approaching a billion dollars a year. What we need now from VRS industry is leadership, not temper tantrums.

And isn’t this a sad trend in corporate America– profits are private but losses are public.

11 05 2010
Sonny (05:21:03) :

First of all, the FCC is to be applauded for asking the public for input! The NAD, in its recent two-part vlogs, appears to be in the right direction by recommending that we look into issues rather than the rates per se.

As I see it, the VRS industry appears to be cost-ineffective and inefficient.

I am hopeful that the public comments and replies due by May 21st will help the FCC, with its excellent current personnel, develop policies that will meet the needs of the consumers rather than the industry ASAP.

11 05 2010
deafsource.com (06:16:58) :

Ed’s Telecom Alert » FCC Comments on Health of VRS…

FCC asked me to post this message to you all and I am happy to do that.  For anyone who knows TRS, Karen Strauss is a well known advocate for “functional equivalence” for deaf/hoh.   Joel Gruin clearly is a top dog in TRS issues. …

11 05 2010
Kitkat (06:19:57) :

One thing I would like to point out, is that the FCC is looking to cut rates, not because they do not want the service to continue, i think thats very important to them….and to develop it further as well…BUT

what they really want and need to do is to stop the profiting of one large VRS provider from taking any more of the general public’s money through the TRS Fund! This LARGE VRS provider, was bought by private equity a few years ago, they put in $250 million of equity then, and have since taken A BILLION out in dividends. This money is because the rates were set too high, while the true costs of providing the service is much lower, published by NECA.

oh, and did i mention that this large provider denied an audit by KPMG, commissioned by the FCC……if you have nothing to hide, why deny the audit ???? now some of the other smaller VRS providers allowed the audit, and FCC/KPMG found they overbilled minutes…..

11 05 2010
Warren Smith (06:40:49) :

Since Sorenson is 70%-80% of marketing, Soreson might need to focus on providing services instead of focus on products. I got a video mail message from Sorenson, Ron Burdett…I condisder Sorenson to be Spam or Junk harassing calls… I had called Sorenson Tech Suppt that I do not want any video messages from Sorenson’s news other than hearing people who I gave my numbers for them to reach and leave a message.

I do support NECA/FCC rates which are for Sorenson. I cant say much about other small VRS providers as I do not know how much minutes they earned per month but I have no problem with Sorenson who earns more than 500k minutes per month.

Warren

11 05 2010
observer (07:12:47) :

Sorenson should be ashamed of how they handled the potential rate cut with their scare tactics. I am happy that the FCC has released this message and that I’m not the only one who sees these scare tactics.

If a business can’t survive while being subsidized by our tax dollars at that rate of $3.89+/per minute (that’s over $233/hr) then they shouldn’t be in business, period! Especially when in the beginning they were being paid $15/min ($900/hour)!!!!!

If the FCC lowers their rate then maybe VRS companies will have to make some changes (less profit, less pay for interpreters) that will benefit Deaf people. Just one example would be this: VRS companies are taking all the best interpreters out of scenarios where they are the most valuable to Deaf, (like schools, hospitals, court system) because of the high pay.

VRS is not going away. Anyone who tries to tell you it will doesn’t understand the facts or works for one of these companies. Again, if a company can’t survive while being subsidized hundreds of dollars and hour then they probably shouldn’t be in business.

11 05 2010
DeafWarrior (07:25:13) :

Thanks Ed for posting the FCC correpondence. Again as I read the postings, many of us (Deaf and HOH) complaint and want to play the part of the victim. Stop being a victim and start by looking at these VRS providers. Their management spend a large amount of money on themselves and their hearing staff. Go and see for yourself, do a bit of research into them. It is easier than what you think. I am glad that the FCC is finally starting to get tougher on them, after all, we all pay taxes and those funds should be used correctly. Not to pay for the lavish lifestyle of some of these “Top Talented Executives”. Or have we forgotten already what these “Top Talent” did to wall street. Keep the information comming. Lets get these VRS providers back down to earth.

11 05 2010
DeafWarrior (07:33:15) :

I do have an idea, how about all these VRS providers get together and present a plan that will provide for the goverment to have eyes on them? Stop the greed and stop the scare tactics. Truly if youa re doing the right thing then you have nothing to hide. The fact is that they all want the same, to control the market, to keep the deaf and hoh in the dark and to make them dependable of their equipment and “services”. What the FCC should do is to hire some auditors and go without notice to each provider, evaluate their process, look at their payrolls, sit at a a board meeting and then impose whatever they see fit based on the facts that they find. I can assure you that the findings would be to say the least interesting.

11 05 2010
Jed (09:23:12) :

I read the FCC comment and hope they will make a smart decision. But as I read it I see one flaw in the comment that I am concerned about.

“The Public Notice seeks comment on reimbursing providers based on the actual costs that VRS providers themselves claim to have incurred over the past few years to provide VRS. The only way to safeguard the VRS program is to adopt reasonable rates for all forms of relay services. Thus, it is our goal to adopt rates that are rationally based on the reasonable costs of actually providing VRS.”

This statement focuses on providing VRS but does not mention the inovation that goes into the industry. The industry is so young and if it were to remain young it would be out dated in a few years. What about the mobile devices or the interpreter training to provide better service. Many VRS companies invest in their interpreters with training and other resources to make our call more successful. I hope that a company will have the funding to provide VPs with better nick nacks and faster service. I want the mobile device!

With rate cuts the companies then move to only “providing VRS” and we don’t move past where we are now. Why not work to improve the industry. There is more involved than just providing VRS to run a good company. I believe the scare is real! It may not happen tomorrow but it could come when our VP’s become outdated. It could happen when we need help with a tech issue and we have no one to call…have you ever tried to ask an interpreter how to fix something; they don’t know!

There is more to VRS than just the interpreters we see on the screen. So much money goes into research and development, interpreter training, tech support, and places the interpreter work. “Providing VRS” is only part of the expense for the VRS companies as they look to make our lives better. The goal is functional equivalence but we still have a ways to go until I will feel satisfied with equivalence.

11 05 2010
Anon (09:31:59) :

I work for one of the largest (not going to say which one) VRS providers, and I’ll tell you right now, that the top level executives aren’t making tens of millions of dollars in salarys. some of them aren’t even making 6 figures. but that’s just at my company, I can’t speak for the rest. The notion that all of the money is going into the pockets of the management is completely unsupported by facts, and is made on complete assumption and an “us vs. them” mentality.

The FCC knows exactly how much everyone at my company makes every two weeks, how much vacation gets paid out, how much we pay our janitors, how much we invest in tech support, R&D, professional development. The problem is, the FCC only wants to pay for the most basic level of service. I hope deaf consumers hate progress and inovation, because they surely won’t be getting any of that with these proposed rates!

11 05 2010
Andy (10:06:41) :

Ed,

Come on! Just tell us the truth… you were cutting your hair when you first learned about the VRS rate cut… is it how your haircut has gone bad from jerk reaction? Kidding…

Those scare tactics from that company is starting to annoy and it has making me more determined not to use their service again. Tell you the truth, their quality isn’t as good as other VRS providers lately. I am still experiencing interoperativity and ten-digit issues when I use VP-200 while I don’t with my ZVRS and Purple products. They are just scared of loosing their investors when they see their HUGE profit margin being cut. It is acceptable to have 10-20% profit margin… not 50% margin or so.

11 05 2010
Jeff (11:03:49) :

I am amazed at all this! Technology and innovations will not be affected because every VRS company knows that its bottom line is dependant on its own market share and if it neglects its own technological development then the risk of its customers deserting it to a competiting VRS service that has maintained its technology and innovation development. If a VRS company neglect innovation, it will stagnate and its customers will desert it. It deserve to shrivel and die. Pure and simple.

Jeff

11 05 2010
CNW (11:24:18) :

Here is an idea. Start charging the VRS users for the services not covered by the rates. After all, its permissible under the ADA. The only limitation is that TRS users are to be charged at a rate no greater than those for equivalent non-TRS service(s).

For those who cannot afford it, there are alternative avenues to get the $. The TRS Fund shouldn’t be viewed as entirely responsible for the costs of ensuring access if there are existing options out there.

But there’s one dirty little secret: the providers do not want to pay for their own calls.

11 05 2010
Sharon/Jerome Berlowitz (11:41:47) :

Whom it may concern;
I often find the Video Relay Service very useful for my personal concerns. making appointments, as well as keeping in touch with my deaf and hearing families. It is very important that we keep in touch with our Deaf Community in order to live with our communication needs and skills! Vrs- Great for me to express my emotional and smooth converstation than tty-frustraded! (even hearing people hate TTY’s relay service..when they knew deaf calling and they didn’t bother to answer or avoid answer them.)
Thank you,
Sharon and Jerome Berlowitz

11 05 2010
Tousi (12:24:13) :

CNW, about that”dirty little secret”, I would have thought that the providers’ business related calls would be paid for but if not, then I’d assume that those calls would be a legitimate expense come tax time.

11 05 2010
Bill Millios (12:32:08) :

I posted this over in Paul Rutowski’s Facebook posting of “This is an in-house memo from our CEO, Sean Belanger – ZVRS”, available at:

http://www.facebook.com/note.php?note_id=390029804302

…but nobody answered. Kind of amazing, considering that several of the people on that page who are supposed to be following all the comments are high-ups in VRS companies. Sean himself didn’t even answer.

—–

Maybe somebody can clear something up for me.

I used to work for AT&T when TRS (Telecommunications Relay Service) was spreading throughout the country….

At that time, AT&T (a union company) was break-even offering service at $1.10 / minute. Note that this was with Communication Assistants earning (on average) $25/30K / year. (Non-union companies such as Sprint and MCI were offering service at 85-90 cents a minute because their labor costs were much cheaper.)

Ok, that was 1990, or thereabouts. Let’s double that, accounting for inflation – so an equivalent service could be offered today for $2.20/minute?

All other costs between TRS and VRS are comparable. Some might say there is an exception of bandwidth speed – but the cost of high speed internet today is comparable to the cost of 56K speed in 1990, so it’s a wash.

Others might point to the cost of the video devices – but CAs in 1990 were using computers, so again, it’s comparable.

If you increase the salary of the worker (CA / operator / interpreter) to $60K (an increase of $30,000 / year, or $15/hour, or 25 cents a minute … that drives your costs up to about $2.45 / minute. Let’s be generous, and say they should make a profit (they are in business, after all), and round it up to $3.00 / minute, which is a little over 18% profit margin (nothing to sneeze at, especially in this economy).

Yet here we are at $6/minute? Over 118% profit margin? Am I missing something?

11 05 2010
Adam (12:37:52) :

@ Jeff

Unfortunately, the FCC isn’t taking the cost of R&D, tech support, innovation, outreach into account. That’s the big issue here. They only see the absolute minimum as a legitimate cost, but unfortunately, their “minimum” doesn’t allow for companies to maintain their competitive edge, or invest in their employees or services for their consumers. These rates won’t allow for further growth for any of the companies here. The FCC needs to invest in the future of VRS, not the bare minimum of operations.

11 05 2010
Adam (12:40:25) :

@ tousi & CNW

If a deaf employee makes a call using their company’s VRS service, the company is not reimbursed for those minutes. It is a legitimate cost of doing business, just like in every other industry in this country.

Plus, that practice leads to rampant fraud.

11 05 2010
ELMAR (13:21:14) :

What some of you have mentioned……” What is NOT being addressed – reduced rates at the expense of tech support ??? OR “FCC planning on cutting rate of biggest company by 40% while reducing smaller companies 1-2%. and the big company saying we cannot continue to provide same level of service at that rate and will be forced cease to exist?” This is the gist of the concern of VRS providers NOT that FCC will shut us down per se. Nobody has answered, :”What is NOT addressed….”

11 05 2010
Spencer (13:53:06) :

Sorenson’s top administrators are paid LESS than the administrators at Purple, CSDVRS, and ZVRS. I don’t know about SnapVRS or other VRS companies.

11 05 2010
Anonymous (13:54:02) :

This is a letter sent out to the public and the FCC from Sorenson.

The FCC’s Bureau of Consumer and Governmental Affairs recently issued a statement stating that the FCC supports VRS and that VRS is not threatened by the FCC’s Public Notice proposing rates for VRS. This statement from the FCC has also appeared on numerous websites.

Sorenson Communications is not at all surprised to hear that the FCC supports the mandate in the Americans with Disabilities Act (ADA) to provide functionally equivalent telecommunications for the deaf. But the FCC fails to mention that in addition to “functional equivalent telecommunications for the deaf,” the ADA also requires nationwide access and improvements in technology and efficiency. The FCC is completely incorrect to say that VRS as we know it today is not threatened by its April 30 VRS rate proposal.

Sorenson provides the vast majority of VRS to the deaf community. Sorenson has provided VRS access to more deaf individuals than any other provider and continues to be the frontrunner in providing access and support to deaf individuals who have never before used VRS service. Sorenson developed the first deaf-centric videophone offering the most functionally- equivalent communication service available. And Sorenson has done all of this efficiently, as we continue to develop next generation solutions that the deaf community has been greatly anticipating.

The rates that the FCC is endorsing will drive Sorenson, the leading provider of VRS, into bankruptcy. The FCC’s proposed compensation to Sorenson is $3.89 per minute. Sorenson’s true and audited costs are over $5 per minute. The FCC is incorrect in their assessment of what would happen if its proposal were adopted. Sorenson understands completely the impact the proposed rate would have on its business. It would be disastrous for consumers. If Sorenson is unable to sustain their business at $3.89 per minute, how can the FCC suggest that any other provider would be able to service Sorenson’s users at such a low rate?

Sorenson continues to strongly urge everyone who relies on VRS to communicate to tell the FCC the facts: The FCC’s proposed rate will force Sorenson into bankruptcy and will end VRS as we know it today. The FCC Chairman and Commissioners must be made to understand that any rate proposal that resembles the April 30 Public Notice, will be a death blow to VRS and to the ADA’s mandate to provide functionally equivalent telecommunications service, national access, technology improvements and efficiency for deaf telecommunication.

Michael D. Maddix
Director of Government and Regulatory Affairs
Sorenson Communications, Inc.

11 05 2010
CJ (14:26:10) :

Wow, watching the games on both sides, I’m not deaf as modern medicen has made it so I no longer need hearing aids

Here’s are some fact the FCC isn’t telling you
1. Not all companies will be paid the same (from under $4 to over $6)
2. Their costs do not include things like IT, interpreter training, or even R&D for new products or even make the service cheaper. Not even the device you use VRS for that you get for free is covered!

Yet they claim it is cost plus . . . .

There needs to be a system in place that will drive further development and will rewards those who find how to be more efficient.

11 05 2010
VRS Engineer (15:01:47) :

If you can sift through all of the Sorenson induced noise in ECFS (alphabetical filings in large batches at the same time… seriously?), you stumble on this filing yesterday from CSDVRS:

http://fjallfoss.fcc.gov/ecfs/comment/view?id=6015599520

A very rational take on return on investment, and a number of good suggestions.

11 05 2010
Diana (15:59:01) :

Sonny….a big AMEN to your comment “As I see it, the VRS industry appears to be cost-ineffective and inefficient.” This is a result of lack of appropriate oversight by the FCC for years until this past summer when the VRS fraud became exposed. I am sure it was a wake up call for them and truly embarrassing but that’s over. Now the FCC has a chance to do this right without having a new issue blow up in their face because they rush through the new rate schedule. The agency needs to first define what is truly functional equivalent before they can even begin to consider appropriate rate to meet the fucntional equivalency test.

11 05 2010
Foxtrot (16:23:52) :

I would like to point out the implications of the tiered rates the FCC is using, and how that affects VRS companies (and how it affects this issue directly).

For most call center related businesses, a company can consolidate their resources into just a few locations, and save quite a bit of money by doing so. In the VRS world, there isn’t so much of a luxury, as there is a limited population of interpreters in a given area. To make sure there are always enough interpreters available to answer a VRS call, the VRS companies must expand into dozens (upon dozens) of areas and open the same number of call centers.

Because of this, the idea of “bulk” rates for reimbursement becomes invalid. The more interpreters a VRS company has, the _more_ money (per minute) it costs to support them

(Note: there are some areas that can make costs lower, and the higher costs per interpreter is not individually huge but it does add up in the end, and does cost more).

Now, you may notice that the “big company” that is referred to in the comments here is in the higher tier that gets the lowest reimbursements from the FCC. As the rates stand now, it seems as though they are able to maintain a functioning and profitable business. Based on past budgeting and financial information, I am sure they know how much it costs them to run their business. When they see that their already low rates (compared to their competition) are going to be cut by 40%, there is indeed reason to panic. This is 40% of ALL the money they bring in. Any company (or individual for that matter) that finds that their income will be cut almost in half will panic. Since the income has been cut, then services must be cut to compensate and stay in business.

40% less income means 40% less product that can be produced. VRS may be the biggest income generating product for them (IP Relay services, etc help as well), but other areas will definitely suffer, and I think the areas that will suffer will be in customer service (tech support, etc), and research and development. R&D being one service I personally don’t want to see go away – Just think of the new technologies that are probably in the works right now that may be cut because a company can no longer afford it! (Think mobile, HD, better video compression technologies, etc)

Another problem is that of competition. The middle tier (in the FCC’s recommendation) gives the highest return for a VRS company. This means that any company that falls in to this tier has no reason to get any bigger, or be any better than they already are, because they won’t be able to afford to support their own product if they ever happen to fall into the highest tier.

Can you imagine what could happen to service if a middle tier company gets close to the edge of crossing into the high tier? Will they just stop accepting calls for the rest of the month? Who knows? I don’t.

One last point. The “Big Company” talks about bankruptcy, if these rates were to be accepted. It may not be a “shutdown the company” kind of bankruptcy, but scaling back may be required, or other more drastic measures. Can the company’s competitors pick up the slack if needed? I am not sure, but I don’t think any VRS company out there is equipped to take a sudden surge like what may be required. Of course it’s speculation, because i don’t have any real numbers to compare or cite on the matter.

All in all, I think the whole tiered reimbursement structure the FCC is using has consequences, which are accelerated by the new recommended rates. I think the deaf community is directly affected by these rates, and is apparent if the consequences are broken down into what it really means. It’s not as black and white as both sides of the argument want it to appear. Personally, I am taking the side of keeping the rates higher (they wont be as high as they used to be, but a 40% cut is way too much), in hopes that better products and services will be available. I will be submitting my opinions on the matter to the FCC, and I hope everyone else does as well.

-Foxtrot

11 05 2010
Confused (16:44:31) :

http://www.sorensonvrs.com/fcc_response

Website says:
Sorenson’s true and audited costs are over $5 per minute.

Either SVRS is telling the truth or they are not. It’s as simply as that, folks! I have to admitt that it’s pretty brazen to post this if it’s not true. But I just don’t know!

11 05 2010
Joseph (17:36:36) :

After the FCC announced the recently statement in regarding the VRS rate cut, the VRS will not collapse but I do not understand why VRS are misleading that it will take VRS away. That is unpropfessional. We need honest and accurate information.

I think it’s the best for all VRS companies to back off and do not promote about FCC because it will scare deaf customers away, I would rather a deaf neutral organization target for VRS/TRS so that way there won’t be any biased or hiding information that all we do not know.

Sorenson claimed $3.89 a minute would wipe them out or file for chapter 11. That is their problem because they have been trying to take over the VRS world. So much misleading and try to take over the VRS market, at least 70%.

I want to see every VRS to be equal and provide the service that everyone should have. I am tired of fraud, misleading, unprofessional service and liars. I want honest, top quailty VRS that we should get. Is there any one? Maybe one or two.

I do support VRS but they need to it properly. I hope FCC will be more tougher on VRS and make sure that VRS is doing right job. I do not need to hear Viable part 2. I had enough. All my tax money has been abused.

I am glad that Ed is doing his job to inform deaf community what is happening between VRS, Deaf Community and FCC. Keep the good work.

11 05 2010
SorensonGuy (17:56:11) :

@Joseph et al

I understand where your view is coming from : “Sorenson is so big, why is it a problem to cut their rates?”

I do not want to get in to a discussion on the size of the company compared to others, as it will spawn a whole other thread that can be saved for another day.

But when it comes down to it, Sorenson has stated publicly that they spend about $5 per minute to service a call. If the rates were to be reduced to $3.89 as suggested, basic math comes in to play. The company will only be able to survive for so long before they have no more money to operate. Sorenson and its competitors ( and any other company if you think about it) are in business to make money, pure and simple. If there is no money to be made, then there is no reason to stay in business.

Sorenson talks of bankruptcy because it very well may be the only option. Obviously every other option will be tried before coming to this, but it is still out there, and for those directly affected by it (employees and customers), it needs to be realized that decisions made now can and will dramatically affect the future of VRS.

11 05 2010
Spencer (18:02:18) :

Sorenson is not trying to take over the VRS “world.” They started the VRS world. If not for Sorenson, there would be NO VRS world. If anything, Sorenson allowed other VRS companies to “steal” their business and grow.

Warren Smith: You don’t have to view the videos sent out by Sorenson. You did not need to watch Ron Burdett’s video. You could have simply deleted it. Sorenson was not cramming anything down your throat.

11 05 2010
Joseph (18:36:58) :

SorensonGuy,

I understand your point. This is the reason, Sorenson has been a proven, a BIG VRS company, why? High rate, borrowing so much money from Investors, many real estate business, Media, and many more. Sorenson thinks they are the best. Want my truth? Nope.

Sorenson is paying back investors $735 Million. How they made that money? That is my question. How Sorenson can afford so fancy buildings, high paying staffs, and sponsor so many events.

Sorenson needs to focus on customers FIRST not the company who is making so much money. Have you realized that Sorenson itself generated over 100 million minutes. So at this current point, FCC current rate is $6.28 muplity 100 million minutes equal what? $628 Million.

Where the hell Sorenson spend $628 Million with? There you go, high paying staff and all these fancy buildings they own and so forth. Sorenson cannot hide even if it’s a private company. NECA will provide that information since it’s a public document, you cannot stop us. It’s our taxpayers dollars you are abusing. I hate this, I do not need this crap. This is the reason I developed my site to provide ACCURATE and TRUTH information what is happening with the VRS world.

I am against any misleading or false informaton. Why Ron himself labled saying in his vlog that says VRS will end. My godness. Where did Ron get that word? Sorenson did scared deaf community because Sorenson knows they are making so much money and thinks we are your slave. I want to tell you something.

Again, you need to check FCC’s public document and I was amazed I found over 1,000 complaints againt Sorenson mostly are poor mismanaged VI’s and terrible customer service. Had these been fixed? No. Why? It’s proven there Sorenson doesn’t know how to fix it.

Lastly, of Sorenson says $3.89/ minute will bring them into bankruptcy, so be it. Let it happen and I hope the CEO will learn a lesson.

Thank you.

11 05 2010
Patrick Boudreault (18:44:24) :

@ Spencer, Sorenson did not come to the VRS industry first, they may the first company to distribute in-house VP (sharing with with D-Link product) along with Sorenson video media software division. BUT it is Ed Bosson is the father of VRS and he made it happen in Texas. I recall myself clearly in 1999-2000, I used VRS in austin… So please give our Deaf people some due respect and recognition. Thanks!

11 05 2010
CfromSorenson (19:01:07) :

Interesting when you read the fine print below from the FCC message. Notice how the FCC says that only VRS is their obligation. Hearing and deaf people? Great. But what about deaf to deaf calls? I don’t see them anywhere mentioned. in fact, I don’t see funding for them mentioned anywhere on the FCC’s documents.

Do they consider deaf to deaf calls as part of VRS? No. Then how is Sorenson paying for system infrastructure for this service for Deaf people to use it? How are they paying for deaf to deaf Signmail in the future? And other features? Is VRS the only functional equivalence service the FCC is thinking about?

At the proposed $3.89 per minute VRS rate, is the FCC announcing that they are planning to remove funding for deaf-to-deaf calls and functions on a videophone devices eventually? VRS companies have been paying for these services and functions with the extra money VRS provides. I see the FCC continuing to pay only for VRS calls in the future by driving down the rate over time and because there is no formal payment plan for the deaf to deaf calls. VRS companies will potentially will not be able to pay for development of any new features that don’t directly support VRS. They will be strapped financially. They will not be investing in making cool new features for Videophones. They might not be able to maintain the systems, there not paid for either. Look closely at the recent FCC proposal from CSD they mentioned it in their report to the FCC spelled out as a big concern. Sorenson is saying they might have to potentially cut services. They provide a huge infrastructure to support it. R&D is where deaf to deaf calling technologies come from it takes a lot of money.

So the trend on the VRS rate is down, down, down and down on the money going for the deaf communication services. The FCC only pays for VRS minutes at a bottom rate now because it is their only obligation. Do the research. The FCC has comments and this would be a great question to ask them. How long can this greatest deaf service all deaf depend on last without funding and the FCC cutting VRS to the bone which pays for it? Can they guarantee the service everyone loves? What will be next an idea charging two phone bills for deaf to deaf? One for the internet and one for deaf to deaf? Pay by the minute? Flat rates with long distance? It’s not functional equivalent but without money to pay for it, who knows. With your help, there is a chance to make a stand to continue the service everyone loves, please help do it. Ask the FCC what’s up with this.

Deaf need the VRS rate to stay up high enough until these problems are worked out. We need to save VRS and deaf to deaf calling. The FCC comment deadline is 5/14/2010.

11 05 2010
edsalert (19:42:28) :

CfromSorenson,

Just a clarification; VRS and video (deaf) to video (deaf) has to do with “ancillary service” whereby if a service is provided, then “all around” type of service is expected to be provided. Traditional TTY relay service is not problematic because TRS providers do not distribute TTYs. If they had provided TTYs, FCC or rather telephone regulations would expect them to provide deaf to deaf with TTYs.

Also, remember the early reimbursement rates were out of the moon – $17 per min and Sorenson was the first one to take advantage of that. Easy to give free VPs with that much money. Now rates go down, not so easy anymore.

Finally, FCC has repeatedly said video phones costs cannot be factored into reimbursement rates. What FCC is doing is estimate the cost of VRS rates based on cost breakdown without video phones or “installers”.

So there has to be a balance somewhere, and it is where the FCC and its decision makers have to draw line on what is the neutral and right balance. I most certainly do not envy them to come out with what they perceive to be right rates. It is gonna be real tough for them.

eyes open & thumbs up..

11 05 2010
Something Stinks Here (19:52:12) :

When I read this a red flag rose immediately for me. I wonder if anyone else noticed. Karen Peltz Strauss co-signed this memo. As you all may recall she was working for CSD/ZVRS only a few short months ago. If Karen is actively defending this memo, what potential hand did she have in setting the agenda, tone, strategies and rates associated with the current proposals?

For those of you not in the know, NECA proposes what the FCC wants them to say in terms of proposed rates, generally to “soften up” VRS providers prior to rate setting. NECA has extensive discussions with the FCC prior to publishing their proposal each rate setting period and only publishes FCC-approved information for public consumption. If you think these proposed rates were independently derived by NECA without FCC guidance you are up in the night. There are literally hundreds of different ways one could interpret the numbers that are submitted by VRS providers, you’re looking at the ones that the FCC wants you to see.

To continue, I find it even more curious that Karen, as a recent employee of the 3rd (possibly 2nd given Purple’s ridiculous/unethical behavior of late) largest VRS provider that draws the bulk of it’s compensation from the 2nd tier, somehow seems involved with a proposal whereby the 2nd tier’s rates magically rose to higher than the first tier. Hmm… So you pay the two providers that draw out of the 2nd tier (CSD, Purple) more while paying the 1st tier less to decrease competition from the likes of honest new entrants like Convo and then you suggest a rate drop of greater than 40% for Tier 3 (Sorenson), with any luck driving them out of business. Hopefully the 2nd tier rate “gift” that’s being floated here makes up for the 15-40% drop in revenues associated with all of the employee-generated minutes that CSD & Purple lost when the FCC figured out that required e-to-e calls were quite likely part of their business plans.

Something smells here. Shouldn’t Karen Peltz Strauss’ legal ethics training courses have taught her that she should have recused herself from any VRS rate-related work with the FCC on the grounds that she was recently on CSD’s payroll and therefore she could have an obvious conflict of interest? I find it interesting that now her name pops up on a statement defending NECA’s proposed rates and basically attacking CSD’s largest competitor (if you could call CSD competition for Sorenson).

Perhaps I’m reading too much into this but in Karen’s quest for glory and self-importance, to show just how much of a valiant leader of the deaf she is, perhaps she overplayed her hand and provided a little bit of insight as to what’s really going on. A classic strategy for a competitor who can’t win in the marketplace is to attempt to win through legislation, to change the rules of the game.

Things that make you go hmmm….

I leave you with this, the law of unintended consequences will be in full effect should the FCC manage to set these rates. I will laugh heartily watching Sorenson’s competitors try to run a VRS business at the proposed rates if Sorenson’s users allows Sorenson to be legislated out of business. It will be like watching a Three Stooges re-run. Actually, I guess it’d be the Two Stooges. I consider Convo, from what I’ve seen, to be a league above CSD/Purple although you’re looking a bit like ‘Curly’ these days, Ed :)

11 05 2010
Confused (20:27:23) :

Bill Millios,
I don’t know ANY interpreter who gets paid $15/hour…it’s at least double that! So, Yeah, your math is a little off…sorry man!

11 05 2010
Gina (20:34:26) :

To Cfrom Sorenson

You are right point to point calls (deaf to deaf) aren’t covered under the ADA law. (to Diana Herron) and that is why “deaf telephone services” are not on par with hearing telephone services because the FCC is not required to ensure that functional equivalency; only Deaf to hearing and vice-versa functional equivalency via relay services are enforceable. P2P is optional.

Sorenson chose to make point to point available through their infrastructure free of charge just as they chose to give out the devices for free. It was a business strategy they adopted to increase their market power; and increase their market power they did.

I do not know if the decision-makers at Sorenson took into account the long-term psychosocial implications of their business tactics on Deaf consumers… I am guessing they didn’t and if they did, it was intended to enslave the minds of deaf people for their self-serving purposes… Their intentional or unintentional near-sightedness is their own fault.

Sorenson supposedly has about 80% of the market share; it is estimated that 8.2MM minutes are submitted a month for payment. At 80%, Sorenson bills roughly 6.6MM minutes a month for payment. 6.6MM @ $3.89 equals to $25-$26MM a month or $306MM a year. If Sorenson doesn’t know how to stretch their $$$ appropriately and responsibly that is not the FCC’s fault but their own.

These proposed rates will level the playing field for a lot of the other providers; and unfortunately also force them to be creative in the way they choose to provide point to point access to their consumers.

I like how ZVRS offers hearing customers a 10 digit number for a small monthly fee in order for us to make P2P calls to Deaf folks using 10 digit numbers. Unfortnately it is a closed network and therefore restricted. It is high time that hearing and deaf consumers of P2P video phone products and services create a demand (be willing to pay$$) that will lead to the creation of a “PSTN” for videophone products in order to enable top quality products and services as well as open, unrestricted access; that we create our own functionally equivalent p2p services and not expect the government to do that for us. On the one hand we want the free market model in VRS, yet on the other we also expect socialized services…

So long as we buy into the rationale of Sorenson and others with similar views, we will never move past the mediocrity of P2P services or its perpetual near-extinction.

11 05 2010
Grains (21:19:25) :

Ed,

If Videophones costs cannot be factored into reimbursement rates, then how do you propose for any company to come up with a new and innovative videophone technology when there’s no money to be made from it? Does Sorenson have to start charging people for the costs of VP product or its service?

The ISPs are already charging us enough for their services and I simply do not like the idea of another potential cost of having the service of VRS providers.

I honestly believe that all VRS providers need more time and money to perfecting their products and making them more interoperability with each other in order to achieve a true “functionality equivalent.”

When there is more money to be spent, the new and better VP technology will come sooner. Less money, our progress toward that will be impacted. Same is true for pretty much anything else such as military technologies and scientific researches.

Also not to mention the costs of interpreters training to improve the quality of our VP experience through them. I’m sure a lot of money is being spent on that. I’m sure we all can agree that they are not cheap.

If Sorenson is claiming that they cannot afford this and goes into bankruptcy, then I doubt any other VRS providers would be able to afford to absorb such large deaf consumers coming at them in tidal waves from Sorenson base; because last time I checked, they all still need to meet the requirement of 3 minutes of holding time for VRS in order to be reimbursed by NECA. All of those smaller VRS providers may not be able to meet 3 minutes holding time. So, there’s a potential domino effect from that.

Do we want to take that chance? I know this might make me sound a little biased for Sorenson, but I’m thinking of VRS industry wide and would like for all of them to continue developing more of new and innovative VP technology to meet tomorrow’s challenges. Because the hearing world are moving fast and we need to keep up with it or we might miss the train if VRS reimbursement rates keep going down and down.

11 05 2010
Adam (23:07:26) :

I see plenty of people doing math to figure out how much Sorenson may or may not be making, but I see exactly ZERO facts as to what actual costs they are incurring. All I see are people guessing and making wild assumptions.

12 05 2010
arpy (05:30:55) :

SorensonGuy,

Thank you for walking back Sorenson’s apocolyptic predictions of doom and gloom. May have to go bankrupt is a much better way of saying it. And of course, it would be a last resort–meaning Sorenson will consider other options.

Sorenson does not need to be as big as it is (or to spend $5/hr) to provide the quality of service it does. The management structure, for example, could be thinned considerably at very little cost to quality. In some cases, less management might even improve the quality. Many of us scratched our heads in amazement at the rapid and reckless expansion of the company over the last few years. “To meet the demand” is the reason given. “To dilute the quality and maximize the profit” is the result seen. That Sorenson might no longer be able to do as it pleases without government oversight is not at all the same thing as the imminent demise of the service.

Thank you for making Sorenson sound more sensible and less hysterical, and for clearly declaring that Sorenson and VRS are separate entities. What is good for one is not necessarily good for the other.

12 05 2010
edsalert (07:45:46) :

Grains,

Quite a few pundits, many persons, two federal agencies (if my memory serves me right), and a few national organizations/associations have said “sell video phones” as functionally equivalent to what hearing persons have to do. As Sonny is fond of mentioning in few of his comments, remember the AT&T breakup separating service and products to stop the monopoly? Larry has repeatedly said empower deaf/hoh of their choices to purchase and do away with “welfare mentality”? This probably will resolve three to five unused video phones in the closet and only use one? Very doubtful if deaf/hoh will purchase all of them. Right now they get them free. So if free, and only one is used, is that not a massive waste of $$ if federal subsidizes video phones?

Clearly there are pro and cons on this explosive issue.

Maybe I will make this a post later when things settle down and get feedback from y’all on this one. Bet it will be a controversial issue!

eyes open & thumbs up..

12 05 2010
Adam (08:21:20) :

Arpy – ” The management structure, for example, could be thinned considerably at very little cost to quality. In some cases, less management might even improve the quality. ”

What evidence do you have to back this up? What specifically do you know about the management structure that qualifies you to comment on how/why it should be thinned considerably?

Or is this just more speculation?

12 05 2010
Diana (09:03:06) :

Hi everyone,

I read everyone’s comment with great interest. What baffles me is why are we even discussing rates when we do not have access to any of the company’s financial books. We have no idea what it really cost to operate. Frankly, I don’t think that NECA should have even asked for feedback on the rates without giving us the full data to help us engage in a meaningful debates and input to FCC. Here’s what we can do…We can talk about what we need to become functionally equivalent to voice telephone users!

Ed, I would love for you to open up a blog discussion specifically what type of technology or service we need to become functionally equivalent to voice telephone users. Let’s list….make a huge list! Send them over to FCC to seek input from those of us who must use VRS to live and work each day. Will you please do this, Ed?

Diana

12 05 2010
arpy (10:19:26) :

Adam,

Fair question. I speak from intimate and regular contact since 2003 with management both at Sorenson and at other VRS companies.

Thanks for asking.

12 05 2010
Adam (10:32:59) :

Arpy,

Thanks for the reply. There is a lot of speculation happening all around, and it’s beginning to drown out any real debate or conversation on this topic. Glad to know you weren’t taking a stab in the dark as so many others seem to be doing.

I can’t speak for other VRS companies, but as I work for Sorenson, I would say that yes, some fat could be trimmed, but “thinned considerably” would not add to the efficiency and progress of our business at all.

12 05 2010
arpy (10:58:50) :

Adam,

Nice chatting with you. Yes, there has been much misinformation spread on both sides of this issue. I think the problem is lack of transparency. It would be relatively easy for Sorenson to prove their case, but they choose not to. That’s their decision. The consequence is lack of clarity and lack of credibility at a time when both are in short suppy.

12 05 2010
Sharlyn Chong (11:34:50) :

I really keep VRS, I’m full deaf, using ASL. I clear understand VRS explain from somewhere than TDD or TTY is hard explain and don’t understand. Hope KEEP VRS.. I understand about FCC.. PRAYER ……

12 05 2010
C. (13:13:52) :

I agree with Diana’s comments recently mentioned. On top of my comments in Ed’s alert next to this blog, I think FCC should enter a separate contract with an expert to do an economic feasibility study of NECA rates and tell us what NECA had done was right and what they did was wrong.

Indeed, the VRS industry is not operating in the most cost effective way like Sonny had said. VRS industry should focusing on providing VRS service as mandated by FCC and make their services interoperable. Right now, I can use only two VRS providers because they are interoperable with my system without having to download a software.

C.

12 05 2010
KJT (13:23:52) :

Just wondering …..

Would it be much simpler for FCC to impose just one flat rate of $6.00/min. That would be a flat competition among all VRS providers. No more political B.S.

12 05 2010
Steven Irwin (13:56:14) :

I had to say something here after reading so many comments posted on this section. I don’t think many of you realized how NECA came up with their figures. They made a list of items what was acceptable and based their figures on that list. Now, that list does not cover ALL of the cost necessary to operate VRS industries. One big example is that NECA do not consider the cost to acquire and maintain hardware/software that is necessary to satisfy FCC’s regulations. One good example: prioritizing 911 calls above other “non-emergency” calls so that all emergency calls are answered quickly as possible. Because NECA does not see this as an acceptable cost of operation, this requires each VRS industries to make substantial investments on their part.

Now, because we are getting close to “functionally equivalency,” there’s still much more improvements needed. VRS industries can expect to see more rules and regulations added by FCC and will require them to update their systems in order to satisfy FCC’s regulations. As you can imagine, a budget to handle system upgrades and maintenance is a huge chunk of budget from the actual cost of running VRS industries. So, the question is, is the rate proposed by NECA fair? If you don’t know anything about running a business that depends heavily on technologies and etc. Let me save you the headache. The answer is absolutely NOT!

For details about NECA methodology, please see my comments to FCC: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020455441

12 05 2010
Terpgirl (14:40:35) :

Would it be much simpler for FCC to impose just one flat rate of $6.00/min.

Yes

12 05 2010
DeafWarrior (14:48:48) :

Now this is funny. Every VRS provider (large and small) will come out with all kinds of numbers. The facts are simple, technology and innovation will not stop being developed. Take for instance the VP-200, has it really changed in the last few years? It looks the same and the connection (hardware) is the same, always going to the router. The so called Z340, or Zojo, the 340 is nice but it was marketed as a portable device, many of us fell for that and ended up returning them. Not to smart as far as the company when we can return it at any time for a refund. I found that move to say the least very risky. However on that piece of equipment, I can do everything I need witha $300 laptop/netbook. The Zojo, other than the color it is still the same as snap ojo. I personally use other venues of communication. I will not be told what to use. One thing we all should be very weary of is that data (numbers) can be manipulated. Interpreters get paid rahter well and lets face it not all of them are that professional. The FCC is cutting back, have they not heard that the economy is in shambles, how many of us are out of work. Anyone can say that the VRS providers are not making that much money, but again, check the companies behavior.
Many of the executives claim that they have our best interest in mind, really!! When was the last time any of them did something truly benefitial for the deaf community. Check the pay structures of many of their deaf employees, you will be surprised at what those pay scales are. I thin we all should be interested in this as it is our tax dollars also. I think that the FCC should not tier the rates and just come up with one flat rate. This will force all VRS providers to truly apply innovation and search for technology that will bring them into the 21st century. Stop the scare tactics, move on and perform!!

12 05 2010
Spencer (17:00:30) :

DeafWarrior–Over the past two years, alot of features have been added to the VP-200. You can now receive messages, akin to voice mail. You can now save more contact list numbers. You can now put one person on hold while you talk to another person. Those features were not possible two years ago, but have been added to vp-200. Don’t say VP-200 has not changed.

Also, from my personal observation, Deaf people earn as much as, if not MORE, than their hearing counterparts–at Sorenson and at Purple. Where are you getting your information from?

12 05 2010
Betty Boop (18:57:48) :

I keep reading about how Sorenson so greedy, only want make more money. But forget to talk about market size and labor pool. VRS is a small market when you consider the size of the Deaf user pool compared to hearing user pool. Also interpreters small labor pool spread all over the country. Text relay can set up a few centers and fill them with CAs because they don’t need to specialized skills, only can read, hear and type fast. VRS has to locate near interpreter “pool.” Most of those centers have very few workers. And interpreters get higher pay because of specialized skills, have fluency 2 or 3 languages. VRS pays those interpreters for all their time whether they are interpreting or on break or waiting for call or teaming, only about half that time is billed to FCC. VRS companies can’t bill for minutes interpreted for their own deaf employees, but still pay their interpreters for that time. All those things that FCC don’t pay for but VRS companies do, profits pay for those things. The profits that FCC wants to cut by 40% if the company is really big and operates very efficiently so they can serve the most customers with least cost, now is also least profitable. Tell me again how those cuts won’t affect VRS quality! Profits are used to pay for all the things the company does that can’t be billed for. Customer service, tech support, interpreter training. All reputable VRS companies work hard to be best service for deaf and best employer of interpreters so they can serve their customers and build their business.

12 05 2010
nascarfreak (19:48:48) :

(modified by editor to take out cuss word): hey hey …. remember this …… ZVRS and PURPLE has products to sell like P3 or OJO so that can back up their rates so u see why they arent hollering for help with the low rates …while sorenson has nothing to sell and all they do is give out vp200 to deaf household with no charges….i think its fair that sorenson deserved something better while other vrs has inferior product to sell which it actually doesnt work right at times …..

12 05 2010
Terpgirl (20:39:11) :

Tell me again how those cuts won’t affect VRS quality!

I can’t. Ur right. And even the suggestion of $3.89 is a slap in the face. I fear the companies may be forced to relocate to the Philipines.

12 05 2010
Grains (20:44:05) :

Wasn’t choosing one “default” VRS provider supposed do away the multiple VP products that you might have?

But yeah, I see your point. Here’s an idea, perhaps these pundits could educate themselves by not using any type of phones that they are so accustomed to and try to use TTY for a day to redefine their view of “functionality equivalent?”

12 05 2010
Terpgirl (20:46:36) :

$17 per min and Sorenson was the first one to take advantage of that.

Not CSD? Hamilton? HOVRS?

12 05 2010
Bill Millios (20:53:47) :

Confused,

Yes, you are confused. I didn’t say interpreters made $15/hour. I said that the difference between $30K/year and $60K a year is $30K – which is equivalent to $15/hour.

Actual figures for interpreters working for VRS are within the $30/hour to $45/hour range, depending on where they are. (That equates to $60K-90K / year.)

Even if they make $100K (which would be $50/hour, or almost a dollar a minute, that still doesn’t go over $3.00/minute for total costs.

I also notice that NOBODY that works for a VRS company is disputing my numbers. That alone speaks volumes.

12 05 2010
Spencer (20:58:09) :

Bill, my dear, interpreters don’t make that much–at least not at Sorenson.

12 05 2010
Adam (23:57:19) :

Bill –

“Even if they make $100K (which would be $50/hour, or almost a dollar a minute, that still doesn’t go over $3.00/minute for total costs.”

How many hours are you figuring an average Interpreter is working? I certainly hope it isn’t 40. More like 15-29/week. FT Interpreters make less per hour, but are compensated in other ways (benefits). How many interpreters are you figuring it takes to handle the average call volume of any given VRS service at any given time?

What else are you figuring into the costs? Payroll taxes? L&I costs? Administrative costs? Management? The cost of running a 24/7 network? Tech support? Cost per center for Internet access? Rent? Software Licensing? Advertising? Outreach? Server maintanence? Database administration? The costs to implement things like E911?

How did you calculate all of these costs? How did you source the information?

Did you factor in any costs like R&D?

13 05 2010
JRR (01:05:58) :

I don’t understand how folks can go on blabbering, when its truly simple on the view points from the FCC.

http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-296497A1.pdf

“The Telecommunications Relay Service Fund was established to support exactly that kind of communication. But the Fund can’t be used to support practices that are designed only to increase payments to VRS providers, rather than providing a necessary service for people who need it. We’re taking a strong first step today to stop these practices and ensure that the Fund is always used to benefit the deaf and hard-of-hearing consumers it was designed to help.”

Moderate Clarification – TRS is to support a kind of communication, that benefits the deaf and hard-of-hearing consumers, not practices that are designed only to increase payments to a certain VRS provider.

Simple Clarification – TRS is to support a translation/interpreter between a deaf and hearing caller.

13 05 2010
CR (09:28:58) :

FCC just wants to pay the cost of running a call center and nothing else. Sorenson wants FCC to include the cost of providing VPs and tech support. That is where the discrepency in audited break even costs come from.

If the new rates take affect don’t expect the quality of VRS calls to suffer, rather expect to be buying your own VP and paying for tech support. If you are against the idea of buying and maintaining your own VP then you should probably be nervous about the new rates.

I don’t have a problem buying and maintaining my own VP as long at the cost are similar to a hearing person purchasing and maintaining a regular phone.

I think the only people that will suffer from the new rates are the people that will not be able to afford purchasing their own VP. If VPs are as expensive as VRS companies claim they are (most claim a retail value of $500.00 or more for a VP) then that may be a large portion of the deaf community. It’s true that you can probably access VRS through a webcam on your laptop or computer but computers still cost more than 300 dollars and many of the older deaf population are not computer literate.

13 05 2010
CNW (09:44:14) :

Then it is our job as productive members of the Deaf community (and society at large) to contribute to the development of the VRS industry. I am more than willing to pay on a monthly basis for the elements of the VRS service not covered by the TRS Fund. The monthly payments by the VRS users will go for R/D, taxes, and the like. Why is this a problem?

13 05 2010
CNW (10:06:52) :

Terpgirl (20:46:36) :

$17 per min and Sorenson was the first one to take advantage of that.

Not CSD? Hamilton? HOVRS?

Terpgirl:

This reminds me of Deaf Way 2. CSDVRS had a large presence, and they were promoting their service. They offered a free webcam, and the lines were very long… I was intrigued so I got in line. Ended up that everyone had to make 3 calls before getting the webcam. I wonder how much they earned that week with the rates at $17/min.

13 05 2010
CR (10:08:16) :

I don’t think it is a problem. Like I said I am more than willing to pay for VP if the costs are comparable to what a hearing person pays to use their own phone.

In fact I think it would be very empowering for the deaf community to start paying for their own phones.

The problem is if I am paying 500 dollars for a phone and 100 dollars a month for internet service and ability to use a VP and my hearing friend is paying 20 dollars for their phone and 30 dollars a month for phone service.

In other words I think many of us deaf people are more than willing to pay for the use of a VP but the costs have to be reasonable.

13 05 2010
edsalert (10:16:33) :

Bill M,

Let’s focus on Video Interpreters and their working times. If VI works non-stop for even 30 hours, they’ll die of it – I promise you that this is not an exaggeration (well, “die” is exaggeration, but “dead-tired” is not). So comes the occupancy percentage. Definition of occupancy for VI varies among VRS providers, but let’s assume reimbursable times as being equal to occupancy times. Because of ASA, there needs to be enough interpreters to answer 80% of VRS calls less than 120 seconds. Means some down times for VIs are necessary – to wait for the next call to be answered to quickly meet the ASA. Now VI has to respond, set up, and then connect. Once connect to third party, that’s reimbursable time. The average of occupancy percentage varies from low of 30% up to high of 60%. The average being 40% to 45%. It is not unlike Free Lance interpreters if more than an hour, have two to do the work. So for FL it is actually 50%, not full 100%. Anyway for VI, “down times” to meet the ASA plus 45% actually makes VI much more expensive. To say nothing of exorbitant cost of health care benefits and other related costs that add up to the tally cost of VI.

There are more to it, but I think this explanation hopefully gives y’all a better picture of the total cost for VI.

eyes open & thumbs up…

13 05 2010
anon WorkingVI (11:37:00) :

Ed,
Thanks for this forum, especially now. And thanks for your description of VI workloads. One clarification I’d like to offer.

You comment: “It (VRS Interpreting) is not unlike Free Lance interpreters if more than an hour, have two to do the work.”

Oh, boy, this would be nice! For VIs to have teams after one hour… After all VRS work is infinitely more complex and taxing than community work. Shouldn’t the same quality assured in community interpreting be available in VRS? Indeed, shouldn’t that be the minimum quality expectation?

Ed, this describes an ideal working environment for an interpreter! Research on efficacy in interpretation is clear on the need for team interpreters for work lasting longer than an hour. There is some very convincing work by Moser-Mercer that shows that optimum quality in video interpreting is only sustainable for 15-18 minutes before it starts to degrade considerably. Hence the 20-on, 20-off norm.

However, team interpreting as such is not available in most VRS settings today. In many places teaming is openly discouraged. The company can only bill for one of us. They are unwilling to trade unrealized earning potential for quality assurance in interpreting. It’s a bottom-line thing.

More to the point, many VRS interpreters work in circumstances where 20-on/20-off is reserved only for conference calls; and in settings where a pre-determined 10 minute “break” may or may not happen, and if it does happen, it might come with the requirement to execute other-duties-as-assigned. On a “break. . .”

I’d be surprised if the average break time wasn’t well below 10 minutes per hour for the entire workforce at one company. Interpreters there know they can cash in break and in/out shift time to improve their stats. Given that future work depends on current stats, it can get pretty cut-throat. When you see a VI that’s frazzled, it could be a lot of things. But likely as not, it’s an interpreter taking any hours she can get now. Especially if she’s experienced and expensive. It’s a bottom-line thing.

But please, Ed, tell me that at Convo Vis all team after their first hour!! This is much closer to the international norms for video interpreting, and will be a real hallmark of quality, since the interpreters working in those circumstances are less likely to be fried and more likely to be fresh and energized. That’s another bottom-line thing.

13 05 2010
arpy (12:15:28) :

Does anyone have information on how much VRS costs in countries like Sweden and South Korea? How will they pay for it in Canada, where I believe it was supposed to start this summer? It would be very useful to know how other countries offer this service.

The point here is that there are other models of VRS service provision than leaving it entirely to the private sector. Does the FCC consider the cost structures of VRS in other countries? Is the FCC interested in exploring alternative approaches?

13 05 2010
Scott H (12:15:43) :

Don’t forget to factor in the cost of Worker’s Compensation insurance as part of VI costs. They can be sky high if VI works for 40 hours a week, so trim down the number of hours to about 30 hours and the Worker’s Compensation cost will come down significantly.

Remember, California has the most strictest labor laws in the USA. It is moot to blame VRS providers when figuring out the VI work hours.

13 05 2010
Robin Horwitz (13:03:01) :

Regarding Bill M’s comment, Adam is right – there’s so much areas to be factored into the full cost breakdown.

We do throughout analysis of our cost breakdown on frequent basis and I can say that we’re nowhere close to the numbers that are being thrown out there. Granted, we’re a small provider thus our costs are higher. The greater your volume is, the less $$ you will have to spend on some fixed and semi-variable costs. The variable costs will always be there regardless of the volume.

Robin

13 05 2010
Sharon Hayes (14:15:31) :

Ed…you do great service by providing a forum for many of us to read and learn from regarding VRS….thank you!

Robin H. You say the greater their volume the less $$ they would spend on variable costs. But what about for VRS companies that develop video phones….their costs would be, indeed higher, because of research & development that goes into making VP available to us.

CR…..70% of deaf people in NC cannot find work, 50% of deaf people in NC do not have access to high speed internet or cable, let alone afford them. I don’t think buying a VP would solve the problem.

Sharon

13 05 2010
Terpgirl (14:23:05) :

I wonder how much they earned that week with the rates at $17/min.

Enough to buy Camp Lakodia

13 05 2010
edsalert (16:26:24) :

CNW,

My apologies for giving you wrong info. My addled memory did not serve me right on this one. Sorenson was NOT the first one to take advantage of $17. Sorenson joined when it was around $7 something. CSDVRS (not the ZVRS – but the old one) was one of the first.

Glad u questioned that.

eyes open & thumbs up…

13 05 2010
KJT (16:34:17) :

Dear nascarfreak (19:48:48) :

You said that Purple is not hollering about FCC Rate Cut.

If I remember correctly, Purple owes FCC a lot of money for unbillable calls last February. Purple and FCC made a deal in which FCC would allow Purple to stay in the VRS business and to pay the debt monthly spreading over 6 months. In exchange, Purple terminated the ligitation against FCC and cannot challenge FCC on the FCC Declaratory Ruling.

That might explain why Purple is staying on sideline quietly with tail between the legs.

As for ZVRS, it already lodged complaint against the FCC Rate cut due to 10% reduction.

13 05 2010
Robin Horwitz (16:42:12) :

Sharon -

FCC has made it clear that the reimbursable rate is for the service itself, not the product.

Using Convo as an example, what we have done is for certain areas that is considered not reimbursable by FCC, we’ve used our profit to be re-invested into those areas.

Robin

13 05 2010
Terpgirl (16:48:47) :

I don’t think buying a VP would solve the problem.

I agree. If the FCC can’t afford this, how can citizens? Plus Deaf folk pay hi $ for internet. This is not a handout.

13 05 2010
Robin Horwitz (16:58:20) :

Talking about VP and the equipment itself, it’s been a good discussion for the past few weeks.

Let’s look at some successful models – especially in states of Texas and California (Granted, I have limited knowledge of all states’ equipment distribution program but … :D )

Texas has a voucher system where they would give you a voucher to get equipment of your choice (This means 1 piece of equipment).

California has an equipment distribution program where they would provide you with 1 part of equipment of your choice (There’s a tremendous amount of choices).

Going back to the VP equipment, if there are products out there and all of them are interoperable – looking at a voucher system (less manpower to handle all the inventory) might be a great solution in managing the costs, rather than building the costs into reimbursable rate.

By building the cost into the reimbursable rate, you are looking at reimbursing X number of providers with their specific devices. Might get a bit too expensive.

CSDVRS provided some background into this by saying that they believe it is about .31 cents of a minute for each device out there ($300 value per device).

I have to applaud them for providing a greater insight into that area.

Robin

13 05 2010
Terpgirl (17:06:57) :

You said that Purple is not hollering about FCC Rate Cut.

FCC is RAISING tier 2 rate. Well, no. I mean making tier 2 highest rate in 2 scenarios. Why holler?

13 05 2010
Terpgirl (17:14:17) :

You comment: “It (VRS Interpreting) is not unlike Free Lance interpreters if more than an hour, have two to do the work.”

Oh, boy, this would be nice!

Amen, hallelujah and praise the Lord! (And I’m not religious.) I wish!

13 05 2010
g l (22:32:13) :

if the fcc doesnt want to pay for add-ons such as video mail, then consumers will have to pay for it. simple as that. if sorenson wants to survive on $3.89/minute, it would mean people who choose to stay with sorenson would need to accept a free and stripped service or opt-in for paid subscription… that’s fine with me. i will gladly pay a monthly subscription fee for features. only it won’t be with sorenson.

bill millios did his calculations and, of course, no one is going to reply to it. simply no comparison between the costs of running a text relay call center and a vrs call center, and although labor cost is a big part of it, they enjoy far different economic realities. with text relay, you have state contracts and that means minimal marketing overhead… you just employ one outreach specialist and stick that person around the state (or several states) and call it a wrap. you also have a nationwide customer service rep that take care of complaints. with vrs, however, there is a lot more manpower involved in marketing, sales and tech support, and it’s because customer loyalty is dead in america that customer retention is an ever-present business reality.

this brings us to a question someone asked of sweden and canada. i don’t know about canada yet because i don’t think the vrs deployed there in the western parts is anywhere close to what we have in the U.S., but in Sweden VRS is not available 24/7 and is run by the government. this absence of choice is consistent with the country’s socialist governance but may nonetheless be feasible because Sweden is a country of only 9 million, or equal to a fourth of California.

14 05 2010
X-files (01:19:12) :

I suggest and I am speaking of a possible solution.

State offers deaf people special vocher to buy VP from computer or store. E.i. low end phone have no feature.. no answer machine, etc.. to high end phone have fancy like answer machine, hold call, line transfer, etc. VP costs more than Phone, but TTY costs even more than VP!

All VRS has to worry about service quality not hardware! I think rate $4.00 is very profitable for VRS industries than if they have to do it both service and technical support; R&D, etc.. for VP.

For example, ATT, Verizon, and others.. are focus on wireless service. While Apple sells iphone, Google for android, etc. Make sense?

Now, suppose Deaf people can’t afford VP, then VRS can offer VP at reduce fees or even free with 1 or 2 years contract.

Main bottom is that all VRS are not create equal, even 100% exact same hardware, etc.. but boiled down is service offering such as quality interpreters, speed response, etc. As long it’s apart from VP technology.

ultratec is company sells TTY and accessories. Company is NOT dead. Why would VRS started to worry about end of world? That puzzled me. :)

14 05 2010
Adam (09:37:53) :

g l – I replied to Bill, and his calculations didn’t account for any of the real costs (even when you throw out R&D, advertising, and marketing). It is very expensive to run a network capable of compressing that much video data and be able to offer high quality video on a consistant basis. There is a lot of technology, fees, taxes, servers and manpower needed to make that happen. And (oh my gosh!) there needs to be management in place to make sure it all happens like it should. To figure in just the cost to pay an interpreter is ridiculous. What about the software they are using to place the call, and track the call session? What about the computer and equiptment the VI is using? This industry is using very high end technology to make VRS a service that is high quality and reliable. And it takes skilled workers to make it all happen. These are part of the minimum costs of doing business in this field, but the FCC isn’t looking at all of them.

14 05 2010
KJT (10:01:33) :

Wow, what a frenzy we had.

If I recall correctly, Sorenson started with the idea of selling VP-100 to some oldest VRS companies. They turned the VP-100 down because the though of using VP-100 with a TV as communication tool for the deaf is unacceptable (at this time, the flat TV was not in high volume as today). They preferred to use webcam with computer. So Sorenson decided to become a VRS provider. And the rest is history.

Back to the FCC Rate Cut, I would like to see a small drop in the rate so as to allow all VRS providers to continue their higher quality of service and maximum innovation. All of the VRS providers are still under 10 yrs old; some are less than 5 years old. Give them more time to mature.

History: Remember that the Weitbrecht TTY was introduced in around 1964. It took an evolution for the TTY technology to change from a bigh ugly monster machine to a simpler and smaller light tty device. Noticing that I used the “evolution” word in the previous sentence indicated the slow technology ramp-up. That is not what we need today. We need to keep the VRS/VP ramp-up as “Technology Revolutionary”.

Lastly, I recommend one-flat rate of $6.00/minute for four years.

14 05 2010
CR (10:08:35) :

Sharon Hayes said: “70% of deaf people in NC cannot find work, 50% of deaf people in NC do not have access to high speed internet or cable, let alone afford them. I don’t think buying a VP would solve the problem.”

I understand that. Those numbers are very similar to the numbers where I live. Hearing people who are unemployed are expected to pay for their own phones and phone bills. The same should be expected of us. I have friends on SSI and they don’t seem to be having any problem paying for thier blackberries and internet service.

I think we should be buying our own Videophones. I do NOT think we should be paying hundreds of dollars for a VP. If my hearing peers can buy a basic phone for 20 dollars the deaf people have the right to be able to buy a basic videophone for a similar price. If this means a voucher program funded by NECA to make this happen then that’s what needs to be done.

My crystal ball tells me that VRS rates will be around 3 dollars a minute in the future and FCC will be paying for VPs like they are doing with TTYs now. In other words there will be two seperate funds….One for VRS and one for subsidizing VPs. Paying for VPs through the VRS fund is the main reason why many deaf people have 5 Videophones.

Think about all the ways that buying your own VP empowers you..

-VP manufacturers will be forced to make their phones interoperable or nobody will buy them.

-New features will be based on what the deaf consumer wants and not on what the FCC mandates or will pay for.

-You will no longer be held hostage to your “default provider”. If you pay for your phone you can use the VRS provider of your choice without the risk of losing features. If the VP manufacturer requires me to use a specific VRS provider then I will buy a phone that does not have that requirement.

I am sure there are many other reasons.

14 05 2010
Adam (10:21:29) :

CR, I agree with your ideas on VP innovation, though every VRS provider will have to invest $$$ in the software to make that happen. I would love to see it happen, but will it if these proposed rate cuts go through?

14 05 2010
DeafWarrior (12:51:06) :

WOW!!!! So many responses. Congrats Ed!!! I have to say that this has been one of the most educational postings I have seen.
I agree with CR, why can we just pay for our VP’s? Like I have stated in the past, I do not use any particular one. I kind of like the idea of being mobile (truly mobile), and I can accomplish this with my very inexpensive and very portable laptop. I do use several software packages. Again, if it is about equality, then why are we any different than our hearing counterparts. It is not like they made us deaf. As for the rates, the FCC should drop them down as far as they see fit. It is time that the VRS providers join the lines of many out there, with deep cuts comes innovations, out of the box thinking and maybe, just maybe they start appreciating their employees and their ideas. I am sure many of us here on this posting (as I have read) have some wonderful Ideas. We might not agree in our points of view, but one thing is for sure, we can make the changes and we will adapt to them, we will always survive. I am kind of curious on how do other countries tackle this issue. I know of contries that do nothing to empowered their people. Technology has come a long ways and it will continue to evolve. Look for ways that will liberate you from some of these so called Deaf friendly providers, stop listening to their executives and break away from under them.
I think that the writing is on the wall for all the major VRS providers, only those that will take proactive measures now will endure. Out with the old and in wth the new!!
Thanks Ed!!!!!!!!!!!

14 05 2010
arpy (13:38:08) :

DeafWarrior,

I’m with you 100% on this. Enough of the hand-wringing and fighting against the inevitable tide of change. There are many other ways of providing VRS service than they way it is done here in the US. Right now we have, in some ways, state of the art Cadillac service. But it is TOO EXPENSIVE and TOO WASTEFUL. The government (we the people) has every right to decide how much we will pay for this service. Companies that cannot or will not work within those constraints should leave the playing field to those willing to engage in innovation in real-world conditions, not conditions that are artificially propped up by government price-protections.

Funny, one company recently announced that they were cutting the pay of many of their most experienced and veteran interpreters. In other words, the interpreters were being punished for their efficiency. Now the FCC comes along and says they are cutting the pay of the most experienced and efficient company. Now the shoe is on the other foot and all of a sudden being punished for efficiency becomes a terrible thing. Go figure.

14 05 2010
Bill Millios (20:15:37) :

I don’t know if I’m not communicating clearly, or if people simply are not reading what I am typing.

For the original state contracts for TRS in 1990/91/92 – AT&T was able to offer break-even service (zero profit on operations) for about $1.05-$1.10/minute. Sprint and MCI could do it for $.85-$.90/minute.

That included all operations costs, including network, computers, training, outreach, blah blah blah. Technology, fees, taxes, servers and manpower, and oh-my-gosh, even management… everything it costs to run a TRS center, covered by that $1.10/minute.

I then DOUBLED that number as a base rate for what it would cost today. The cost of a high-speed network today is comparable (if not LESS) than what it cost in 1991 to run a full-blown LAN/WAN (across state lines) to handle the nationwide TRS traffic that AT&T handled. We had T1s in every center handling the data, plus a full PBX system handling the voice calls … Big guns, very expensive in 1990.

The ONLY significant difference in costs between then and now is the cost of the actual “operator” – (back then, “Communications Assistant” – now, “interpreter”.) People may have been misled by my annual salary numbers – but the cost/hour is accurate, if not a little on the high side – which makes my numbers lean towards the high side, which makes the $3.00/minute estimate somewhat liberal.

It does occur to me that AT&T lost quite a bit of money trying to OBTAIN the state contracts (marketing, outreach, lobbying costs, etc.), and that the R&D costs associated with developing the nationwide TRS center LAN/WAN platform ($millions) were absorbed by the company, and written off. The operations costs, however, were calculated to be break-even at the numbers I posted above.

Is there enough R&D to justify DOUBLING the rate from a comfortable, covers-your-costs $3.00 / minute to $6.00/minute? I don’t know. It seems pretty definite that the FCC is not willing to let companies bury device R&D in the rate. This kind of makes sense. The downside is that it means no more free lunch – and we’ll have to pay for our devices at fair market value.

14 05 2010
Terpgirl (21:08:13) :

The ONLY significant difference in costs between then and now is the cost of the actual “operator” –

management also costs way more

15 05 2010
X-files (01:28:37) :

Hey.. speaking of metaphor. Take look at this link.. http://money.cnn.com/2010/05/14/news/companies/atm_fees/index.htm

I can’t image if FCC decided to go ahead with rate cut with 3 tiers, I wondering what happened to deaf people working at VRS? will they be layoff? even a FEW layoff could be huge different!

If VRS keep saying that.. VRS rate will cut.. will not impact VRS. Think again! The problem is that it never occurred until it actually happened! That’s ONLY THEIR opinion– just words.. nothing more. I’m almost 90% pretty certain that what VRS are saying stuff about SorensonVRS is entirely inaccurately.

Here is a theory.. IF fcc adapted to use 3 tiers plans. my first thought is that it could be insider related to VRS industries and one of NECA and FCC.. who knows.. could be one that is pressing to cut deep on tier 3.. thus will give money on the run to smaller VRS. If they indeed did it.. I think it won’t solved problem by reducing SorensonVRS monopoly shift to smaller VRS. It won’t work! and more likely lead to lawsuit– predictable if 3 tiers is underway. It’s like giving a lot of bananas to 3 or 4 small monkeys and FEWER banana to A gorilla. I know it’s ugly picture.

Then, i guess maybe we have to figure out what FCC next move.. I’m looking forward to see that.

15 05 2010
John (08:29:54) :

Why is everyone only focused on the back-end (R&D, testing etc) aspects of video phones? The software involved in running these companies is (as it should be) constantly evolving and improving. It is needed to provide things like E-911, 10 digit numbering, be able to track the session/conversation minutes, be used to identify fraud, monitor staffing to make sure the company is meeting the required ASA and that they have an adequate amount of interpreters on the phone. This is an extremely young industry, and to impose these low rates now won’t encourage growth. Scale it down by .5-1% every year over the next few years, but make the rate predictable for the next 5-10 years so business can plan and invest accordingly.

15 05 2010
Diana (08:55:11) :

Bill Millios, I believe that the government, both Fed and State, would only want to fund the relay service at a minimum and not support R&D. They are passing the responsibility of functional equivalency on the relay service providers without providing them with the necessary support and revenue to meet the responsibility. In the TRS field (in the 1990′s) when we had a single provider per state, the state’s RFP called for minimum requirements but it became the TRS providers’ maximum provision. There was a lot of finger pointing at who was responsible for the growth in technology. As a result and thankfully, the era of TTY is close to obsolete.

I really like the opportunities I see today that encourage competition among VRS providers. The problem with the competition today is that the providers are limited to a single form of revenue from FCC to survive (inspite of marketing their devices…which is a very limited revenue opportunity considering majority of deaf people cannot afford to keep buying device to keep up with growth in VP/VRS technology) and unlike the TRS days when the states contracted with large telecommunication companies that had several sources of revenue to fund their R&D’s and growth. We all need to step back and understand what funding model we need to help us to become, like FCC put it, functionally equivalent to voice telephone services. We need to hold FCC accountable in adhering to the ADA mandate and to play fair with all VRS providers.

This is off the point and since I am still on the soap box, I’d like for the public to really take their eyes off the VRS providers and glare at FCC. It is a great shame that they would open up a public notice on rates. I don’t believe I’ve ever seen any government agency open up a public notice on rates except for tax rates. The public notice is usually about regulations or government agencies defending their proposed budgets. The postal stamp rates change without any public notice because they have an independent agency that reviews and determines the rates. FCC single-handedly created all this confusing debates among the consumers of VRS and unecessarily riling up all VRS providers. And funny thing is that the VRS providers are coming out with their own “facts” and deaf advocacy organizations calling attention to what they believe are the “facts” and lastly, FCC came out with a letter of their “facts.” There are NO facts! It has everything to do with what we believe in and each person or company or organization is simply stating what the facts that are based on their vision, their interpretation of the ADA and their operational needs. With this being said, I believe this debate that has taken us on a wild ride has been an education for us all. Hopefully, FCC will be more mindful in the future when releasing public notices that are focused on gathering information to determine the functional equivalency issues.

16 05 2010
Betty Boop (17:50:03) :

Arpy,
You stated that interpreter rates at specific company were cut for most experienced, thereby punishing most efficient. Are you equating highest pay with highest efficiency? That is not necessarily the case. Can you clarify?

17 05 2010
Truthmaster (09:21:06) :

There is a LOT of confusion and misunderstanding exhibited by these comments. Much of this arises from a lack of understanding about business and finance.

I find Sorenson’s scare tactics to be extremely devious, and their wording to be quiet sneaky. They say their “costs” are over $5 per minute and FCC’s proposed rate would “end VRS as we know it”. This is true. What Sorenson doesn’t tell you is this:

- Their true operating costs are around $3 per minute (you can look at NECA’s report and recommendations to see EXACTLY what Sorenson’s cost structure is)

- The rest of their costs on top of the $3 actual costs, to sum up to the $5 or more costs they cite? It’s interest expense. After the private equity owner took out $1 BILLION in money (a special dividend), how do you think they did that? They sold bonds with the promise to bond investors that the government would continue to pay them the high rates in the future, so bondholders would be assured of getting the money. Smart move by the private equity owners — they got their dividend just in time (how convenient), before all this ruckus is happening now. So debtholders hold $1 Billion on bonds, and guess what? They’re holding the bag. The equity owners already got their $1 Billion (funded from issuing the bonds earlier) and laughing all the way to their banks, yachts, etc.

- Let’s be clear. BANKRUPTCY IS NOT ABOUT SHUTTING DOWN THE BUSINESS. If a company files a Chapter 11 bankruptcy, they simply restructure their debt and equity structure. THE BUSINESS ITSELF STAYS THE SAME. DON’T BE FOOLED BY SCARE TACTICS! Take a look at GM (General Motors). They filed last year. Notice how they’re still making cars? In fact, bankruptcy was good for them: forced them to shake up the old ways and get better at what they do.

- By the way, take a look at the NECA report (it’s right on their website). It’s clear they’re referring to Sorenson as completely FABRICATING their projected 2010 intepreter costs, saying they’d be 60% higher than they actually were. That way they could claim their projected operating costs would be $5 or more per minute. NECA called them out on it. What shenanigans! Maybe even fraud!?

Oh, and the concern many have about a rate set too low stifling innovation? Been there, done that. Sorenson claimed the same thing in 2007, during the last go-round on rate-setting (don’t believe me? Google around and you’ll see it’s deja vu all over again). Guess what? After the rates were set very high in 2007 for the three year period, Sorenson has been milking (bilking) the cow. You can guess they’ve invested very little in true R&D and innovation and all their capital expenditures have simply been to provide their proprietary equipment for free to users, so they could lock up their market share. NOT because they had any love for deaf people. Ha! Funny how its’ really the FCC who’s trying to look out for deaf people, and yet it’s the FCC who is being accused of being callous and ignorant.

17 05 2010
Truthmaster (09:40:25) :

And all this side discussion about some of the disallowed costs by NECA? If you actually go into the report and look at the numbers, it’s just peanuts. It’s just diverting the discussion.

17 05 2010
arpy (11:28:03) :

Betty Boop asks:

Are you equating highest pay with highest efficiency? That is not necessarily the case. Can you clarify?

For convenience sake, we call what CAs do “interpreting”, but in fact it is often little more than guesswork. It isn’t unusual to know nothing about who either party is, what their relationship is, where they are, or what they want, information that is vital to successful “interpreting”. Given this remarkable circumstance, the most efficient VIs tend to be the ones who are the quickest at making accurate guesses. Successful decision-making is largely a factor of experience. There’s the connection between experience and efficiency.

Mind you, my comments hinge on the fact that the payscale for interpreters originally followed the going rate in the local city. Cities with the highest prevailing rates are the places hit hardest in the new economics of VRS. In the early days, it was important for companies to establish credibility, and so experienced interpreters were vital to the success of the enterprise. Eventually, however, it became clear that “interpreting” really wasn’t what was wanted or needed in many cases, and that signers could handle a lot of calls. Signers are also a lot cheaper than interpreters. It is no coincidence that the prerequisites for employment for VIs have quietly moved away from certification and five years experience to “entry-level”. That’s a pretty significant change, and it did not come out of the blue.

So, no, experience does not in every case equate with efficiency any more than statistical efficiency equates with quality. And yes, it’s just good business practice to engage in cost/benefit analysis. It’s sound practice for VRS companies and it is prudential oversight by the FCC.

17 05 2010
Adam (12:48:29) :

“It’s clear they’re referring to Sorenson as completely FABRICATING their projected 2010 intepreter costs, saying they’d be 60% higher than they actually were. That way they could claim their projected operating costs would be $5 or more per minute. NECA called them out on it. What shenanigans! Maybe even fraud!?”

No, they aren’t referring to Sorenson there. Nor is it “clear” that they are. From the report:

“One provider has proposed an increase in its interpreter staff of
approximately 57 percent for 2010 and over 62 percent for 2011 when compared to 2009
staffing levels despite consistently meeting speed of answer requirements and submitting
a demand projection that remains virtually constant (+2.8%) with the demand reported
for compensation in 2009.”

17 05 2010
CR (15:29:49) :

Here is the link to the filing that I’m assuming that Truthmaster is referring to…

https://www.neca.org/cms400min/WorkArea/linkit.aspx?LinkIdentifier=id&ItemID=3430&libID=3450

Thanks for bringing this report to my attention as it is very informative.

I don’t see anything referring to Sorenson in the filing. NECA does not mention who the provider is that is projecting the additonal interpreter costs. I also can’t find the part that shows what Sorenson’s cost structure is.

I wonder who the provider is in the report that thought the rate should be 80 dollars per minute.

17 05 2010
Truthmaster (15:55:00) :

You’re right it’s not explicit but it seems pretty obvious. First of all, Sorenson is the only Tier 3 provider out there (Sorenson admits this — see their own response report from May 14, it’s on this site). Second, NECA points out the “unsubstantiated data” is from a Tier 3 provider (one example: “…is not impacted by the unsubstantied data noted above regarding Tier 3″). Finally, when NECA excludes this outlier data, all the average costs-based rates change DRAMATICALLY, for example, from $3.89 to $5.66 in one case. Sorenson is the only player that would be big enough to have such a large impact on the averages.

All in all, not hard to connect the dots.

18 05 2010
CR (14:37:06) :

Adam says:

“CR, I agree with your ideas on VP innovation, though every VRS provider will have to invest $$$ in the software to make that happen. I would love to see it happen, but will it if these proposed rate cuts go through?”

Adam,

With a voucher program a VP producer can still charge hundreds of dollars for their VP. R & D will be built into the cost of the phone just like any other industry. Paying for VPs and R and D through the VRS per minute rate is illogical because not all VRS companies provide videophones. No reason for a VRS company to get paid for developing,providing and installing VPs if they are not going to do it.

This is how a voucher program might work

Let’s say for example there are 3 videophones on the market. A basic version, a nice version, and a fancy version.

Let’s say the retail value of the three videophones are as follows..

Basic $300.00
Nice $350.00
Fancy $500.00

NECA might base its reimbursment rate on the cheapest phone minus the 20 dollars that us deaf people should pay for it. (20 dollars is based on the cost of a basic telephone that a hearing person would have to purchase)

Here is the cost to NECA and to us

Basic: NECA pays 280 dollars we pay 20 dollars
Nice: NECA pays 280 dollars we pay 70 dollars
Fancy: NECA pays 280 dollars we pay 220 dollars

You see what I am getting at?

Some positives to this system

-It gives Deaf people a choice empowers us to demand features. Under this system its our money that does the talking and not FCC rules and regulations.

-It doesnt reward VRS companies that dont produce VPs when the rates are high, and it doesn’t punish VRS companies that do when the Rates are lowered.

-It will foster competition and enhance technology because the VP producers will have to manufacture the best phone at the lowest cost just like any other industry.

- This will end the practice of us owning 5 different Videophones. This will actually be cheaper in the long run to NECA because instead of subsidizing several videophones per deaf person they will just be subsidizing one.

18 05 2010
Terpgirl (23:09:51) :

Who will pay for the vouchers?

18 05 2010
Terpgirl (23:11:14) :

“Well, I’m disappointed FCC didn’t point finger @ one of VRS for starting this madness scare tactic”

Dave, they would’ve had to point two fingers. And one of those fingers would’ve had to snap

19 05 2010
CR (09:19:20) :

Vouchers would be paid for by NECA. They would have two seperate funds. One for VRS services and one for Hardware.

19 05 2010
Adam (13:52:14) :

Truthmaster:

Here is what I don’t understand. NECA came up with a weighted average of $5.6039 after they included the “unsubstantiated data” and a rate of $5.7826 after they include costs of E911 and 10-digit numbering. If Sorenson’s data skewed the data to this rate (which would mean they supplied NECA with higher costs – of course excluding all of the costs that aren’t being allowed) why then did Sorenson propose a rate of 5.95/minute the first year, and in 5 years a rate of 5.72 in their filing with the FCC?

If Sorenson is able to sustain the status quo in terms of service (which includes all of the costs that weren’t allowed to be submitted to NECA as “allowable) and turn a profit @ 5.72/minute, why would their “allowable costs” be so much higher than that?

19 05 2010
Grains (20:07:34) :

It’s funny how some people think that a “bankruptcy” means “shutdown” or “closed” in an ASL sense. I had to explain to several of them that for a such large company as Sorenson is, it would likely going to be a “restructuring” type of bankruptcy (Chapter 11, I believe). Though, I am no expert in this bankruptcy subject, but I do know enough.

With 3.89 per minute, if adopted by FCC, would certainly seems plausible that it would force Sorenson to restructure their whole business plan.

19 05 2010
Terpgirl (20:17:29) :

“Vouchers would be paid for by NECA.”

NECA will cut the vouchers.

25 05 2010
Terpgirl (20:56:26) :

“Well, I’m disappointed FCC didn’t point finger @ one of VRS”

Two, not one

25 05 2010
Terpgirl (21:01:42) :

“With 3.89 per minute, if adopted by FCC, would certainly seems plausible that it would force Sorenson to restructure their whole business plan.”

You are right. And it would not be restructured in a good way, is my concern. This is true for any of the providers, but most particularly for the company that will lose almost half of its earnings. A chapter 11 reorganization can mean that the company continues to function, or it can mean that the company closes down. There are plenty of examples of both. And there is nothing that says that they have to keep this, or any other video relay company, open and functioning. If they do not feel they are making any profit or making enough profit, they will close. More than one company has threatened to close. Read the comments from Snap. I used to work there, and I know that they would not say that unless they were really worried about their viability, and they would not be losing 40% in any scenario. I don’t think these are empty threats. The companies may not close, but they would lose most of their reason to be open. I think we would like to believe that people will provide relay, any kind of relay, with or without a solid profit. That’s a fantasy and an impossibility.

15 06 2010
Mike Campbell (03:19:52) :

So much incorrect information is out there in this debate. Example of pure baloney … Sorenson should be able to make a profit because the government is subsidizing their operation at $233 per hour … That is like saying the government subsidizes the US Army. Subsidize is a deliberately misleading word. It is in fact a lie! The government does not subsidize the Deaf Relay Inudstry .. it funds it 100% .. Just like the US Government funds the US Army 100% … Take away the 100% funding and it is the same as taking away the Service. Who would dare take away the funding for the US Military ? What would happen if the military funding were taken away? Farmers are subsidized … VRS Services are 100% dependent on US government funding. Take the funding away .. or cut Sorenson’s funding by 40% and the deaf people are going to lose a big portion ( more than 40% of their communication services. The deaf people have a hard enough time just paying for their high speed internet … Don’t make them pay for their video phones and tech support.. That just ain’t going to happen .. cuz they can’t afford it …) They will be forced to go without the communication services mandated by Congress who passed the ADA . Now… when someone says the company is getting $233 an hour at the present rate .. that is at best being naive and more than likely being downright dishonest. VRS interpeters do not spend 100% of their time relaying conversations . Nor do they operate in vacant lots .. without health insurance .. without equipment … without software … without long gaps between calls … Nor do the deaf people communicate through VRS with VPs that they paid for and installed and supported all by themselves … Yet the FCC is trying to make us believe that all of that are not essential costs. Why is the FCC favoring Purple over Sorenson ? It looks like they are trying to drive Sorenson out of business so they can then beef up the rates and let Purple enjoy the windfall. Indeed … something really stinks here !

24 06 2010
Terpgirl (00:53:23) :

I have worked plenty without health insurance and continue to do so, but I see your point. I guess my only question is, why doesn’t Purple appreciate this? I mean, they could’ve saved a lot of time writing their comments to the FCC (and every time they write to the FCC and all of their vlogs) if they just write “We Hate Sorenson” over and over again, like a child being punished in school. Maybe they could get Bart Simpson to write it on the chalkboard. I just don’t see the point. They are welcome to hate anybody they want, but they are not conducting themselves in a professional manner. There are many ways to express hate, beyond the fourth grade level, beyond Bart.

Leave a comment

You can use these tags : <a href="" title=""> <abbr title=""> <acronym title=""> <b> <blockquote cite=""> <cite> <code> <del datetime=""> <em> <i> <q cite=""> <strike> <strong> <font color="" face="" size=""> <span style="">