Disclaimer: I own Edsalert and also am co-founder of Convo so take what the post for what it is.
Today is the deadline (May 14, 2010) to submit comments regarding FCC’s Public Notice on NECA’s report (VRS rates). You’ll see both VRS providers agree on 5 tiered rates system although both differ on amount of minutes. Convo has decided to open its business model to public – not the most detailed, but enough to give public an idea of the cost of operating VRS especially for new or start up companies.
You’ll see three of them are frank and open.
Finally, remember there is a reply comment period as well. If you see either Convo or ZVRS or SnapVRS or for that matter any other comments made thus far that you especially liked, feel free to send comments to the FCC.
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"
As usual here is the disclaimer: I own Edsalert and also a co-founder of Convo so take the post for what it is.
If you don’t recognize me; my apologies. It was an accident. I usually give haircut by using 1/4" clip on a hair buzzer. As I was cutting my hair and then unbeknownst to me dropped clip into wastebasket as I shed hair into wastebasket. I then buzzed my hair with no clip. Sooo I had no choice but to give myself full cut. So here is my new look. Hope you like the new look.
Finally here are the new proposed VRS rates and comments from VRS Providers. Wearing both caps (I don’t use hat of past regulatory work and current VRS industry, I would consider this not very good news. I will also include other VRS providers and their comments to the FCC.
"IP Relay providers to continue to file with the Fund administrator annual costs and demand data, as they had in the past.4 The Commission stated that “this information, which includes actual costs for prior years, will be helpful in reviewing the compensation rates … [adopted] and whether they reasonably correlate with projected costs and prior actual costs.”5 Based on the data received from providers, the Fund administrator indicates that VRS providers’ weighted average actual per-minute costs were $4.4603 in 2006, $3.9604 in 2007, $4.1180 in 2008, and $4.1596 in 2009."
"The Bureau also particularly seeks comment on whether the Commission should adopt 2010-2011 interim Fund Year rates based on NECA’s proposed use of weighted averages in calculating each of the tiers, as described in the 2010 TRS Rate Filing."
"This calculation results in rates of $5.7754 for Tier I, $6.0318 for Tier II, and $3.8963 for Tier III."
See the difference between Tier 1, and Tier 2 then down to Tier 3 – hmmm – something is wrong there. NECA Submission
Above FCC Public Notice is based on NECA’s submission. Read this carefully..
Sorenson was not shy about its thoughts about reduced rates. Read on..
"The FCC should not adopt either of NECA’s proposals for basing rates on providers’ historical costs. Both of these proposals would result in bankruptcy, chaos, and devastation for the deaf. One of these proposals prescribes rates so low that they would immediately drive all VRS providers out of business, forcing deaf consumers to revert to the laborious process of typing their relayed communications, and both of the historic-cost proposals would drive Sorenson out of business, stranding tens of thousands of deaf consumers and making it uneconomic for them to be served by any other provider. The Commission lacks authority under the ADA to adopt any VRS rate that would wreak such devastation."
of past regulatory work and current VRS industry, I would consider this not very good news. I will also include other VRS providers and their comments to the FCC.
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