5 VRS Providers Team Up Supporting Tiered Rates
25 01 2011All..
Check the link out on tiered rates.
The 5 VRS providers (4 certified, and 1 non-certified) teamed up and submitted comments supporting tiered rates and cited reasons why. AT&T VRS, Convo, CSDVRS, Purple, and SnapVRS submitted the following quotable quotes.
"At this critical juncture in an evolving and maturing VRS, we continue to hold our consensus view that the tiered rate is a proven methodology for sustaining progress and that now is not the time for the Commission to imperil such progress by experimenting with new untested VRS market approaches."
"..unanimously adopted rate tiers which were carefully calibrated to match the higher costs of smaller and emerging providers who do not have the scale economies and efficiencies of larger providers, thereby avoiding the overcompensation of the dominant provider while enabling greater competition and choice."
"A predictable rate allows providers to plan on undertaking measures to better realize the functional equivalency mandate such as research and development, new hiring, and outreach. "
"Abandoning tiers in favor of a reverse auction or bidding structure will obviate consumer choice and stifle innovation."
"Stakeholder groups including Telecommunications for the Deaf and Hard of Hearing, Association of Late-Deafened Adults, Inc., National Association for the Deaf, Deaf and Hard of Hearing Consumer Advocacy Network, and the American Association of the Deaf-Blind have expressed support for the tiered rate as critical to sustaining consumer choice and innovations to service and products to their benefit."
And finally this:
"To eliminate a proven reimbursement structure in favor of an untested method [in the specific industry] with potentially devastating effects on smaller providers and consumers, would only serve to undo the advances of the past several years and the growth of the life-changing service of VRS throughout the community. "
As you all know I have two caps: one: corporate cap (Convo owner), and second: regulatory cap (19 years in regulatory work), this is one instance where both caps become one. Tiered rates are the best way to go to maintain functional equivalence.
eyes open & thumbs up,
Ed
Long Link: http://fjallfoss.fcc.gov/ecfs/document/view?id=7021026443
Categories : Alerts

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