Letter to FCC from Congress Folks
3 06 2010Folks…
Check this out. Got this letter from an aide of a congressman of which I appreciate.
Quotable Quotes:
"We note with concern that the Commission intends to shift from the long-term compensation method it adopted unanimously to a "cost plus" method which may not account for the real costs of providing VRS. It is also troubling that the proposed compensation rate structure could result in certain VRS providers being paid as much as 50% more than others for the same service."
"We do not see a connection, however, between fraud issues and the rate structure. If the Commission does see a connection, we would be interested to hear how the Commission believes the proposed rate changes address that problem."
I am puzzled by the first paragraph. FCC released the cost rates and asked for comments which means the FCC wants to hear from commentators so the decision has not yet been made. I believe FCC allows profit margin of about 11.25%.
On the last paragraph, there is, to my best of my knowledge, no FCC public notice that ties fraud to rates. The only thing I can recall is the farewell letter from Tom Chandler (he left FCC to join DOJ) which mentioned that. If I am wrong, kindly correct me on this.
One other observation is that first two signatures were from Utah.
At any rate, FCC will have to respond to that; especially with 29 HR Reps.
eyes open & thumbs up,
Ed
Long Link: www.edsalert.com/wp-content/uploads/2010/06/Signed-Chaffetz-Bishop-Ltr-29-total-signers-2.pdf
The link to the HR letter is not working.
FYI, the link to “29 HR Reps Letter” isn’t found.
Sorry folks, the link is now fixed.
eyes open & thumbs up..
Minnesota has 8 representatives and on the letter, 4 of them signed it. Good move on their part to protect multiple VRS call centers in Minnesota. The VRS providers that have call centers in Minnesota are Sorenson (2), Z (2), and Purple (1).
There is another letter I already saw beside this one, from the US Senate.
Pretty much in same vein as this one.
Amy Klobuchar, D-MN
Orrin Hatch, R-UT
Mark Warner, D-VA
Kay Bailey Hutchison, R-TX
John Thune, R-SD
David Vitter, R-LA
Mike Johanns, R-NE
If there were other letters, we have not seen yet or may have already been filed.
wd,
That one was already posted in edsalert.
eyes open & thumbs up…
The VRS reimbursement rate should be maintained. Without adequate compensation, the providers have no incentive to do outreach. Otherwise, potential VRS users will not be taught by VRS. Our goal is for 100% of these potential users to receive the necessary training and experience to use VRS. We face similar problems with Speech-to-Speech because reimbursement is too low. It would be helpful if the VRS community would advocate for both high VRS and STS reimbursement rates. Ed, do you see a way of accomplishing this goal?
What is “cost plus” method? How does this differ from the real costs of providing VRS services? Secondly, the congressional aid said that they do not see a connection between fraud issues and the current proposed rate structure. Umm… what in interesting statement. I thought there was a connection, but now I’m beginning to wonder if there isn’t a connection. Can someone help me out here?
Bob,
VRS and STS do not have same problem. STS is based on state whereas VRS is based on nationwide. The outreach issue is STS’s main problematic issue which means needs aggressive outreach to reach persons with speech disabilities and educate them how to use STS. With VRS, the issues are many which includes fraud, cost of video interpreters, call centers, etc. So to answer your question, no I can’t see how combining STS and VRS for advocating could work out.
DJ Stacey,
That “connection” did not come from FCC’s Public Notices as best as I can figure out. Congress folks seems to be implying (probably fed by a certain VRS provider) that FCC is raising hell because of the connection between rates and frauds. Important to understand what I am saying is that the formal announcements by the FCC have not shown the connection (at least to best of my knowledge). The FCC staff may or may not have said in public presentations that rates and fraud are connected. I just don’t remember any talks like that, though.
As for “cost plus” – I think it meant cost of providing VRS plus a percentage of profit allowed. Yo, CPA folks, care to enlighten us?
eyes open & thumbs up…
I believe the ‘cost plus” term refers to actual cost of providing the service, plus those things that are currently not “allowed” to be included in the cost of providing service calculations. (R&D, etc) I’m still trying to understand how a tiered rate system encourages competition, as much as it rewards inefficiency, since the rate is paid for the same thing, a minute of interpretation. And how does insuring that all providers reap the same profit margin, regardless of efficiency or market share, reward customer service, innovation and efficient service? But I’m not a business expert.