FCC’s Declaratory Ruling, Order, and Notice of Proposed Rulemaking on VRS
28 05 2010All..
This one has a short window of opportunity to comment. 14 days for Section V – A, Section V – B and V -E5, then 21 days for all other issues; these public notices need to be first published in federal register before the 14 and 21 days take effect so little more time for anyone to comment. I would love to know why each different deadline dates for each sections? I am sure FCC has its own reasons for that.
Basically, FCC wants to clarify and explore few issues. FCC wants to address whether reimbursable rates should apply for certain types of calls using VRS or not.
Before I go on and outline, I want to point out one interesting interpretation by the FCC that – frankly I find the statement somewhat offending.
"The statute and regulations provide that TRS users cannot be required to pay for the costs associated with relaying a call. Therefore, TRS users are not strictly "consumers" or purchasers of a service; rather they are the principal beneficiaries of a federal program that gives access to the telephone system."
Hey, that sounds like welfare. Does not meet the definition of ADA which Title IV (relay regulations) is part of. Anyway, this one I will have to chew on. Remember TTY relay service was based on using existing telephone network; VRS uses Internet (not unlike VoIP using Internet). Does that make difference, I think it does, but will discuss this particular issue at another time.
On declaratory ruling: FCC wants to "reiterate that Interstate TRS Fund payments may be suspended to providers that do not submit to audits."
That is what teeming masses who at least understands the basic budget will agree with the underlying idea that VRS providers should open their books to FCC/NECA. However, a few providers have problem sharing their full books with FCC. So it is gonna be interesting how FCC will enforce that. I support that, though, and know many of you do, too.
Order: adopt the interim rule "to make providers more accountable by requiring senior executives to certify compliance with our regulations under penalty of perjury."
Good rule, but I thought that was already done. I will have to chew on this as well. This interim rule, however, is NOT asking for comments, and basically said will enforce it without due process. "We adopt this interim rule without notice and comment, pursuant to 5 U.S.C. § 553(b)(3)(B)."
Notice of Proposed Rulemaking:
A. VRS Call Centers outside of USA not allowed. This one makes sense.
B. VRS CAs working from home. Ah, this is a sticky issue for a couple VRS providers. I do not support the concept of VIs working from home; too many possible issues with that. Security measures are most effective in a call center instead of from home.
C. Basically FCC is outlining procedures on suspending or delay payments to a TRS provider if TRS provider failed to provide adequate verification. This is area where TRS providers will need to comment. Good one this one.
D. FCC is asking for comments on these type of calls.
- International calls
- Caller’s Face does not appear on screen; use of privacy screen or Idle calls. If VRS caller does not want to show his/her face, use TTY relay service is what I think.
- Calls that involve remote training. Ongoing discussion on this; should it be VRI, not VRS and the one providing remote service should pay for that? Same old argument where if Title I or II fails, then should Title IV take over, or go thru due process of complaining to DOJ which has historically not taken high priority on telecommunication issues that fall under DOJ.
E. Procedures in detecting and stopping the billings of illegitimate calls
1. Automated Record of the VRS calls. This one, to me, should already be in the rules based on existing telephone regulation, but guess good to emphasize that.
2. Data must be filed with the Fund Administrator to support payment claims. This also should already be in regulation, so guess one or few providers are not doing enough of that.
3. Requiring providers to submit info on new and existing call centers on a periodic basis. Very good!
4. This refers to white label company. Read this carefully. I believe there is other option for that.
5. Offer whistleblower protections for VRS CAs and employees of TRS providers. Very good and should be supported.
6. Transparency and the disclosure of provider financial and call data. This will be a sticky problem for a few VRS providers, however, I think that is needed to help FCC reach reasonable and balanced rates.
7. Provider Audits. Self explanatory by now…
8. Provider certification must meet criteria as listed or be subject to penalty of perjury.
As always, feel free to comment. This is an important notice from FCC.
eyes open & thumbs up,
Ed B
Long Link: http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-10-88A1.doc
Hi Ed –
Thanks for your forthright comment about the FCC going out of its way to characterize us as “beneficiaries” rather than consumers, I was rather taken aback by this. You are exactly right Ed, in using TRS we are not beneficiaries of a welfare or some other social service program, we are deaf Americans who expect the US to carry through its ADA law to provide access and equal opportunity.
While I appreciate the FCC progressing in this issuance to provide opportunity for comment on critical issues affecting our relay experience – and I personally agree with a great number of their tentative conclusions – I am also concerned that many issues are addressed primarily through the lenses of the TRS Fund rather than the ADA. For example, the Commission raises the issue of remote training by discussing its costs/potential fraud and does not attempt to inkoke an ADA based analysis and that why the heck we have Title I and IV ADA provisions is because our employment opportunities suck in denial of our civil rights. I share the concern that privacy screens potentially lead to abuse, but I expect that the FCC step up to the discussion from the vantage of functional equivalency applied in a reasonable way to this situation otherwise I am completely unsure if the FCC will legislate that my “unresponsiveness” to a CA means that I am booted from a call due to reasons associated with the Fund regardless of whether I was simultaneously doing other legitimate things during that call.
I appreciate the FCC’s repeated public commitment to supporting high quality VRS. Making that commitment manifest in FCC policymaking in balance with other considerations such as fraud and abuse is an extraordinary challenge I see the FCC working very hard to address, that I also very much appreciate. The stuff regarding the financials and enfircement, I’m favorable with discussing in context of the TRS Fund. But when it comes to policy issues involving our access to telecommunications, I respectfully request the FCC to clearly premise that discussion firmly on ADA precepts.
-Jeff Rosen, a proud consumer of VRS.
Jeff and Ed,
Thanks for both of your insights. Likewise, I was taken aback by the label that FCC has given us as beneficiaries rather than consumers. This disturbs me greatly because it seems to state to me that we have no right to demand or complain about VRS and that we should become complacent and be thankful that we have a service available to us. I agree that we should work with FCC to clarify our role and enforcing our rights based on ADA precepts.
Would it be possible to arrange for the FCC folks to come to NAD Convention this coming July and have an open dialogue about their proposed rulemaking on VRS? It seems difficult to respond to every NOI without having a full understanding of their intent or to be able to clarify our intent so that we can come to the same conclusion. Furthermore, it is difficult for VRS users who are not well versed in ADA law or TRS regulation to provide sound feedback. There has to be a better process to first educate VRS users before posting NOIs. I am concerned that our rights are being exercised in futility.
Diana
I suggest googling on the keyword “beneficiary” in Google’s News to understand how it is used in different contexts. Here are few examples:
1. http://www.kctribune.com/article/KC_News_Features/Cleon_Rickel/High_Speed_Rail_One_Step_Closer_to_Reality/19387 stated that Missouri is a beneficiary of the plan for high-speed rail.
2. http://www.punchng.com/Articl.aspx?theartic=Art201005250275612 stated that private institutions should be beneficiaries of the fund for education trust.
3. http://www.google.com/hostednews/ap/article/ALeqM5gBPaHA8wyvhZsKWPW8Uxp30QpfqgD9FVMN2G0 stated that President Barack Obama is the main beneficiary of the congressional bill that will provide fund for additional troops.
(The above links may be no longer valid after a period of time but they worked for me at the time of writing this comment.)
After checking various online dictionaries, I would say that FCC used the term of “beneficiaries” only because there exists a fund that provides monetary benefits for the users known as beneficiaries. The fund could come from a welfare program but the definition of beneficiary is very broad enough that the fund could come from any program that has no connection to welfare such as education fund.
Joseph Pietro Riolo
josephpietrojeungriolo@gmail.com
Public domain notice: I put all of my expressions in this post in the public domain.
Why can’t they say callers or users? If consumers bothers them too much, there are other choices that are more neutral and less offensive. I don’t pay for the library, but I am a patron. It’s a decent word. The government pays for it. Well, I pay when my books are overdue, but you know what I mean. Diana, you have an interesting point. But I think I can tell you what their intent is – - they want to save money and they want to make sure that there is no more fraud or minute pumping possibility. But yes, they would benefit from listening to a large group of actual consumers.
Ed, you may remember the part during the FCC workshop where the economist commented in this offensive tone that you refer to here. I was very insulted by it, and I made sure to include a rebuttal as one part of my recent comments to the FCC about the proposed rate hack (40% is not a mere cut) and I tried to use my professional voice. Here is what I wrote:
The economist at the video relay workshop commented that callers were being critical of interpreters’ skill level, even though the callers were not paying for the service. Those familiar with the field of interpreting know that most deaf people never pay for an interpreter out of pocket, whether it be through video relay or out in the community, because it is often legally required that interpreters or other accommodations be provided as a way to make communication accessible. Most importantly, however, sign language users who critique interpreters’ skills are not doing so for aesthetic reasons. Having an unqualified interpreter in any setting is far worse than having none at all. Misinterpreted information can easily seem correct, and this is doubly true in video relay, where the callers cannot see each other to self-edit the message from the other consumer’s visual cues.
Interesting reading this – I can see both sides of the customers/beneficiaries definition – I am not an US citizen and in my country there is a discussion going on to alleviate some of the cost of the VRS (rather petty and minuscule in my opinion) by charging the deaf VRS caller the equivalent cost of any hearing person making a phone call. The proposal is that the VRS provider collect the money direct from the deaf person as with any other telecom provider. I am very much aware that the regulators talk to each other and I would not be surprised to learn that the FCC got this from a discussion in which our regulators are involved… As a customer this should not really be an issue but the main problem is the extra bureaucracy imposed on the VRS provider in relation to billing and so on…..
Secondly I am also concerned about the face/privacy screen and its impact on the ‘policing’ role imposed on VIs. What happens if the caller get asked for specific documents/reference numbers etc and need to get away from the VP to get these out – how long is a reasonable ‘hold’ time – some documents may be difficult to find and may take time to find/locate.. This can also be open to abuse too – how do one measure a piece of string? Leave it to the hearing party to hang up? Too many loose ends and the ‘free call rates’ does not help in my opinion here as it becomes difficult to argue when one does not pay anything for the length of the call at all….
Ed,
I’m starting to enjoy reading your blog. There is a reporter from Warren News Communication who contacted me the other day and is doing a story on Sorenson’s intent with VRS rates, which was proposed by NECA to FCC. You seem to have a far more wealth of knowledge about FCC and its regulations of the TRS/VRS industry, than I do. That said I was wondering if you would be willing to send me an email so I can pass your name on?
Thanks!
I think we need to remind them that fully half of our people (whatever you call them) are hearing!
DJ Stacey,
I’ve been contacted by numerous media news reporters. Feel free to pass my name on.
eyes open & thumbs up..
I don’t know if it’s FCC ‘standard operating procedure’ in issuing NPRM orders, but it sounds like the FCC is making assumptions and preferences in this latest round of rule-making in reforming the VRS industry. In this order, the FCC outlines the rationale behind such rules, makes its intentions known and outline proposed rules to take effect and to seek comment. It appears that the ‘voice’ of the stakeholders have been diminished somewhat. I could be way off the mark, though.
My concern is that the ‘tone’ of this DA seems to suggest that FCC is ‘advocating’ for the TRS Fund and not necessarily in the name of the functional equivalency mandate of the ADA. Is the FCC creating rebuttable presumptions about certain proposed orders? If so, what kind of evidence or persuasion does the stakeholder community need to rebut those? Who would be the final arbiter in this NPRM? The full FCC Commission? Or just the DRO of the FCC?
I do have some thoughts, but need further time to digest…
I don’t get it. People can’t be on hold for 2 minutes? That’s a lot of companies you can’t call. I guess it’s time for me to admit that I haven’t read it yet and go take a look at it for myself.
terpgirl – the idea is that the VI shouldn’t hold when there isn’t someone on their screen for more than 2 minutes.
At the risk of stirring up a hornet’s nest, I think hold times are fair game for consideration. It is not uncommon to be placed on hold for 30, 40, 50 minutes and more. It’s hard enough to justify paying $400 an hour for interpreting. Paying that much for being on hold is preposterous. It wouldn’t take all that much to add a “hold” button to VI software that would eliminate those minutes, or recategorize them as minutes to be reimbursed differently.
Awaiting the corporate howl….
Cousin Vinny,
I’m glad you are wondering about the FCC’s “tone” of advocating TRS Fund rather than functional equivalence. You are not alone in thinking that now. As matter of fact, one of my two presentations at the NAD Conference this coming July is about functional equivalence.
Anyway, the other interesting observation of this recent FCC declaratory, rulemaking and order is that most of items listed seems to be individually focused on past violations on VRS provider(s); what I mean is one item for one VRS provider, and the other item for another VRS provider, and so on. A few items, not many, listed seems to be for overall VRS industry.
eyes open & thumbs up..
Up here in Canada we are all in support of the proposal that VRS centers must be in the USA! Sorenson came up here and established a good number of centers – not sure, but I think they are the only VRS provider to do so. We got all the problems you have down there with the resultant impact on community and other interpreting. Very difficult to get interpreters and sometimes none available at all! You USA ers experienced that too but you got the offsetting benefit of VRS service. We here got none of that!
So set our interpreters free to interpret for us!
TRS users are hearing, hard of hearing, deaf, deaf-blind, etc. The entire population are “beneficiaries” of a federal program that gives access to the telephone system. At first the word, “principle” bothered me as I wondered who were the “principle beneficiaries”. At first impression, the answer is “relay users”. But then access to the telephone system benefits even those who are not relay users. If my hearing sister and I use the relay system, does that eliminate her husband as a beneficiary? The minute my sister tells her husband that she and I had a conversation via the relay, her husband became a beneficiary. If the plumber and I use the relay to arrange a date for him to repair my leaking plumbing, his wife and family and the business community are beneficiaries of the relay system via his making a living repairing my leaking pipes. When in the late 1980′s-early 1990′s, the PA PUC commissioner at a meeting ordered the telephone companies to submit proposals for running a relay service for the deaf in PA, I corrected the commissioner that it was a relay service for everyone, not just for the deaf. Ultimately, all of us are paying for the relay services as the telephone companies pass on the cost of their share to the NECA funds to their customers. Perhaps that statement needs to be revised because if that statement is true, maybe I’ll write a letter to the PUC with cc to the Feds saying that according to FCC’s statement, “The statute and regulations provide that TRS users cannot be required to pay for the costs associated with relaying a call.”, the 8 cents/month surcharge on all telephone customers for the relay service is in violation of FCC’s statement!
Ed, thanks again for a great posting. Although I do disagree with the comparison to walfare. If you look at it from the very basic practice it is walfare. Dont get me wrong, I am all for equality, however, we (deaf and hoh) must also work towards our own equality. I know I am a different variable as I do not let my so called “handicap” preclude me from being a productive person. I constanly look for ways to get what I need done in a professional and amicable manner. Many of my frineds are hearing and some of their friends can not beleive I am deaf of one ear and hoh on the other. I still think that we must endure soem of the burden that the VRS providers are compalining about. I also beleive that in this day and age and with all the issues that we have as far as financials it is time that we move on from looking at the goverment to give us the equality that we deserve. Again they should cut the rates and the providers should pass on the cost to the customer as all otehr communication buisnesses are curently practicing. Other than the basic service I think if you want video email, video messaging, cell phone notifications and all the other cosmetic add ons then you should pay a fee for them. Hearing people pay for everything they want extra, we should as well.
Again thanks for keeping us informed!!!
[...] Link: Ed's Telecom Alert » FCC's Declaratory Ruling, Order, and Notice … [...]
Arpy,
Since nobody else has risen to the bait, I will. While paying for time holding on the phone appears to be wasteful, I don’t see a good alternative. You propose paying for the hold time at a different (presumably lower) rate. The interpreter doesn’t know when the hold will end and has to remain available to process the call when it does. Is the interpreter to earn less during that time?
My question is, why is it OK for businesses to put a video caller on hold indefinitely but the video caller has to be checking in with the interpreter every 2 minutes? Hearing callers can use cell phones or put calls on a speaker while on hold and go about their business. How is it functionally equivalent to keep deaf callers tethered to their videophones?
$400 an hour for interpreting? On what planet? Maybe Avatar but not here.
tg
$400 per hour come from taking the high end of the reimbursement rate ($6.70 per minute) and multiplying by 60 minutes per hour. It is highly misleading.
First of all, interpreters can’t be interpreting converasations all of the time – some time has to be spent waiting for and connecting calls. I have no idea what the average is for that. Next, interpreters get paid break time (labor laws dictate this). Finally, some calls may need more than one interpreter – if CDIs are to be used, it will require two intepreters on those calls. What about time spent trying to connect to busy lines, disconnected numbers or just waiting for the other party to answer?
Consider speed of answer … for a provider to reliably answer 90% of calls within 90 seconds (I think that’s the current standard), there has to be interpreters available. Since calls probably don’t come in in a steady stream, providers will need to have a certain number of extra interpreters available to handle spikes in the number of calls. This means that some of the time a VRS interpreter is working is spent waiting for calls. The faster the speed of answer, the higher the number of extra interpreters needed to ensure it and the less efficient each intepreter (and company) is.
There is a certain amount of “inefficiency” built into the system and that isn’t a bad thing. VRS interpreting is more demanding than just about any other kind. That time spent on hold or waiting between calls is necessary or nobody would be willing to do the work.
I cannot emphasize enough that I agree with Jeff Rosen and will not compromise the word, “user”. Between the lines, there is an intent behind the authors of FCC’s Declaratory Ruling and believe Karen Peltz Strauss is one of the authors. In addition, there must be much than being a beneficiary of the US welfare system. There is a lot of truth to what Riolo and Deaf Warrior said.
I found on the internet that “Beneficiary” is a common term used by the Federal Government and it is not limited to welfare. There are two most common categories of Federal subsidies. One, Feds provide subsidies by use of government assets, property or services at their price; Two, Feds provide funds of subsidized goods or service so that citizens can use such service. Examples of such goods and services are education, health and highways.
The use of federal infrastructure are heavily subsidized and provided free of charge. Therefore, it is very common for Feds call users or participants of Fed subsidized services “beneficiaries.” There are private businesses who are “beneficiaries” of federal subsidized funding or assets. As a matter of fact, TRS is a heavily federal subsidized service provided to users free of charge. Thus, VRS providers are beneficiaries of federal-subsidized funds.
Though I prefer to be known as a “relay user” and am not comfortable with being labeled as “a TRS beneficiary,” I think the intend of FCC using “beneficiary” in their rule of order is to specify who receives the federal-subsidized TRS funds in order to to determine fair disbursement of NECA funds and audit CEO’s books. I don’t know of any receipient of public education, Social Security and Medicare who would not care to identify themselves as a beneficiary. I wouldn’t bother quibbling about FCC’s choice of word: “beneficiary.”
I am proud to be a relay user, too.
C.
Disclaimer: The comments are opinions of the writer and do not represent her employer.
“I have no idea what the average is for that”
In pretty constant call volume, with back-to-back calls, 25 minutes connected per hour is the average. Sure, some interpreters do 30 and a few do 20, but between waiting for a call, setting up a call, ringing the phone or signing a busy signal, time to set up the next call in multi-call sessions, breaking down a call and waiting for the next call, it’s about half the time connected and half the time not, average over logged-in time. And yes, there has to be a break if you want the interpreters to still have hands and arms and shoulders and a rib cage and a neck tomorrow, and bring those body parts to work with them the next day. New math tells me that at about $6.00 per connected minute, the busier centers can bill the gov’t an average of $150 per hour. $400 per hour is a dream! And $100 per hour is a nightmare.
Oh, and did I mention that the interpreter has to have their hands in the air and actively engaged in a combination of both structured signing and interpreting for 50 minutes to get the 25 connected? In case I forgot to mention it, they do. 25 minutes of signing per hour would be easy on the body compared to 50. That’s where the breaks come in, as well as the very high workers’ comp premiums, just one more expense for the providers.
Terpgirl,
I always enjoy reading your posts. I agree that $400/hr can be a misleading figure. How about we knock it down to $374.40? ($6.24×60). This might be “misleading’, too, but it also has the benefit of being accurate. Since reimbursements are done on a per minute basis, the only way to figure what interpreting costs per hour is to multiply the minutes by 60. Traditionally we have charged for interpreting by the hour. I don’t know of any venue other than VRS where interpreting is sold by the minute. To compare what we pay for interpreting, then, we have to use hours, not minutes.
It’s pretty interesting, actually, to look at it from the perspective of cost and value. For example, in the community an agency pays me $50/hr and charges $80/hr. There the value of interpreting is seen as 5/8 of the cost of interpreting. In VRS, interpreting costs $374.40 an hour, but I am paid the same $50. There the value of interpreting is closer to 1/8 of the cost. VRS has turned the neat trick of both raising the cost and lowering the value of interpreting!
‘Breaks’ are an interesting issue, as well. Someone else here talked about how ‘breaks’ doesn’t mean the same thing at some VRS centers, what with ‘other duties as assigned’ and all. My real concern is the issue of teaming. I don’t think you’ll get much argument from veteran interpreters that VRS is far more complex and taxing than community work. By not requiring teams in VRS we invalidate our justification for having teams at all. What will we tell community vendors who have been grudgingly paying for two interpreters when they find out that those same two interpreters work in far more complex settings for far longer than two hours without any team at all?
Wouldn’t this be a lot more expensive? You bet. But given the workload at many VRS centers today, it is currently the interpreters who are paying that expense, in terms of musculoskeletal disorders, cognitive overload, eye strain, etc. Teaming would help alleviate the pressure on interpreters. To date interpreting has largely been treated as a labor cost. Sooner or later we are going to have to reckon it as a limited resource. And, yes, it may be too late. Interpreters may have been too compliant for too long to now think that they deserve a seat at the table where decisions are made. The recent filing by RID, however, is cause for some optimism.
As always I appreciate this very interesting comments from commentators!
I’ll like to touch on beneficiaries. First of all I do not disagree with what you all tried to define beneficiaries and all that. My underlying concern is the subtle discrimination and what it could lead to. ADA was very clear that we are consumers as we do pay for the relay service via hidden fee in telephone statements.
Again, a little bit of history: the original purpose of hiding the fee for TRS is to show that deaf/hoh are no different than hearing consumers of telephone services. At least that was my understanding. The original intend of FCC was right on the spot. Now they are saying deaf/hoh are the beneficiaries of TRS, and not consumers. Uh, huh? Looks very much like to me that’s taking some rights away, wouldn’t you think?
Why is that statement important for the FCC to post? Why the need to emphasize that in a Public Notice? I suspect they’re preparing public for something (future orders?) that relay users may not like? Am I being paranoid? Maybe…but would like to play it safe and nip the bud so to speak. (“Nip the bud” is an idiom meaning stop something from going further.)
eyes open & thumbs up..
Well, It looks like Tom Chandler, the ex Chief of DRO at FCC, may have had more influence than he thought. That wording about us not being consumers but beneficiaries is almost word for word from the farewell letter he wrote back in march. You can find his farewell letter here: http://www.edsalert.com/wp-content/uploads/2010/03/farewell-Tom-Chandler-032510.doc
The excerpt from his letter:
“A competitive model has not worked or added anything of value in this context – i.e., a service mandated and entirely paid for by the government. VRS users are not “consumers” but rather beneficiaries of a government program. Also, in this context, competition has driven the rates higher (e.g., the tiered rates), not lower.”
I have also noticed that the proposed rates are more in line with what he advocated in the December 2008 House Report on the FCC.
Although Tom Chandler had a few good points in his letter I believe that his overall vision for the VRS industry is rather bleak. From what I understand is that he is not an advocate of competition in the industry and believes that strict standards on VRS calls by the FCC is good enough.
It is a scary thought for me to think about the VRS industry improvement governed by FCC rules and fines rather than competition. In fact I believe if this happens improvement will be slow or nonexistent, Much like what we saw with TTYs and and old text based relay of the 80′s and 90′s. Perhaps this is what FCC is advocating?
I also understand the he would be happy with two or three providers taking up the resposibility of providing all of VRS. The way it works now is if we are not happy with our VRS provider we simply switch to another provider. If Tom got his way we would have no recourse for bad service except to complain to the FCC and hope they fine the company for the transgression. Do we really want to put the quality of service in the hands of the FCC? I would think not.
I hope FCC is not embracing Tom’s vision and taking a step backwards into the 80′s and 90′s.
So, in your example of getting $50 per hour for a community assignment where the agency charges $80 per hour … what if you showed up and only had to interpret for 10 minutes? Would you say that you were earning $300 per hour? Would you say that the agency is charging $480 per hour? That’s the logic you’re applying to the VRS rate.
“it also has the benefit of being accurate”
how?
SRS,
Actually, no. In your example I would still charge and earn $50, the agency would charge and earn $80, and the customer would pay $80. The number of minutes worked here is immaterial since the service is sold by the hour. Since VRS is sold by the minute, the only fair way to compare is to aggregate those minutes into hours, the same way that companies aggregate the seconds into minutes, and then compare the cost per hour.
The problem is that we are comparing apples and oranges. Terpgirl is talking about the net on the number of minutes out of an interpreters’ hour that the company can bill for. I am talking about the rate at which it is paid. These are very different numbers. No matter how you cut it, VRS costs roughly $374 per hour of service billed. That’s what we the people are paying for it.
To be fair though, we should also note the relative effect of that hour. In the community, one hour of service is required for one interpreting assignment. In VRS, one hour of service provides interpreting for a dozen or more “assignments”. This is beginning to make my head hurt.
Only an accountant could love a model where we pay $374 for something that’s only worth $150 to the company that sells it. To me this suggests gross inefficiency in the model of service provision.
Arpy,
In the interest of accuracy, how did you arrive at $150 as the worth? Also, what is the model of service provision you propose?
SRS,
I took the $150 from Terpgirl who wrote: “…the busier centers can bill the gov’t an average of $150 per hour.” I believe she got that by taking the average of 26 minutes of billable time out of every hour a CA works and multiplying it by the average rate of reimbursement. 26 x $6.24 = $162. Correct me if I’m wrong.
And I am not proposing a different model. I am suggesting that other models exist and should be tested. As you can tell from my writing, economics is not my strong suit. I said earlier that I didn’t know of any venue outside of VRS where interpreting was sold by the minute. Turns out I DO know of such a venue: VRI. I did a quick review of the going rates for VRI, and the results are kind of interesting.
To be sure, there are important differences between VRI and VRS, but essentially you have the same technology, and the same employee-expense base. At the same time, you have far less government regulation, which is the price we must pay for government involvement, including everything from ADA to FCC. There is a big difference in scale, however, with VRS being much larger. You might think that would result in economy. After all, the highly vaunted efficiencies of mass production are supposed to lower costs. Not so in VRS and VRI, though, where (in my very limited review) VRI sells for as little as $40/hr and as much as $160/hr. In no case did I find it costing more than $3.50 a minute, and that was a midnight-7am rate for specialized medical interpreting. Many vendors also make clear that VRI must be scheduled in advance, which represents an enormous cost-saving.
Having just called ‘apples and oranges’ recently, I’m leery of drawing conclusions from this, but it does seem odd that (private and small-scale) VRI is so much less expensive than (public and ginormous-scale) VRS. Maybe the difference is in the scale? Maybe if I did propose a model, it would be to make VRS providers smaller in scale and subject to much greater scrutiny from their local communities. Better, stricter oversight would certainly have limited the impact of the recent manufactured-minutes scandal. Until VRS came along, communities were actually pretty good at policing interpreting.
And oh, yeah. A number of VRI rate sheets offer the caution that for jobs approaching two hours, two interpreters might be required. Ahem.
u have to pay for vri, but use it if u can afford it. vrs is (at least) 2 things vri is not — – free and profitble. or 3 things — – popular.
Just to clarify: VRI and VRS really are not the same. VRI can be in any “settings” – can be remote (like VRS), or interpreter sitting next to deaf or interpreter sitting next to lawyer video chatting with deaf, or more likely this, deaf sitting next to doctor video chatting with interpreter via video phone. With VRS, there can only be one settings, and must be remote. Even with remote, there are restrictions: deaf and hearing person cannot use VRS if it is next to the office, nor can deaf and hearing person in same room to call interpreter.
The only same thing is interpreter – even then, with VRI, one theoretically can choose interpreter who is expert in legal, medical, technical, science, etc whereas VRS is technically for conventional translation. VRS is “dial-tone” while VRI is pre-arranged. Also, with VRS, one has to take into cost of average speed answer, occupancy time (down times in between VRS calls), plus other horde of cost items that VRI does not have to take into account. Because of that, theoretically speaking VRI should cost lower than VRS.
eyes open & thumbs up…
“Why is that statement important for the FCC to post? Why the need to emphasize that in a Public Notice? I suspect they’re preparing public for something (future orders?)”
future cuts
I was wondering . . . have any decisions been made on these issues yet?