New TRS Fund Administrator: Rolka Loube Saltzer Associates

25 03 2011

Folks..

FCC has replaced NECA (National Exchange Carrier Association) with Rolka Loube Saltzer Associates as Interstate Telecommunications Relay Service Fund Administrator.  

RLSA

Quotable quotes:

"RLSA is pleased to announce that we have been selected by the Federal Communications Commission, via competitive bid, to succeed the National Exchange Carrier Association as the Administrator of the Interstate Telecommunications Relay Service.  RLSA has partnered with both M&T Bank and McKonly & Asbury to perform the administration of the TRS program and will assume administrative responsibility after completing a transition period ending June 30, 2011.  Information regarding TRS administration is forthcoming."

Is that a good or a bad news?  I simply do not know.    It is with my sincerest hope that RLSA understands the uniqueness of deaf/hoh cultures and how they may differ from regular regulatory world.  Going "by the book accounting" will not work with TRS; so it will be interesting to see what kind of accounting procedure they will adopt.  

RLSA has this to say of themselves:

"Our firm, established in January 2000, is highly specialized in public utility matters.   Our principals have decades of regulatory and administrative experience.  Our expertise includes administering state and federal universal services funds, subsidy program administration, providing expert testimony on behalf of public agencies and drafting orders in regulatory proceedings. Our sample client list reflects the diversity of projects we have successfully completed."  

Uh, hmm okay.  

I’ve worked with NECA for about 11 years as member of Interstate TRS Fund Council.   They’re good people and, I believe, they have done all they can do within the directives from the FCC.   The reimbursement rates for traditional TRS service were reasonable.  The rates for VRS never have been really perfected; is it because NECA not doing their job? Or is it that FCC does not give enough of guidance to NECA where NECA can do their job efficiently?   We’ll never know.   

At any rate, NECA, our condolences and I believe y’all did your best.  

Everyone including VRS industry, VRS users, and, of course, FCC will be evaluating RLSA with a fine tooth comb.  

That said, RLSA, congratulations!    We look forward to your work with TRS industry and that relationship will be a pleasant mutual one. 

It does bring peripheral issues; exactly what role will Interstate TRS Fund Council play with RLSA?   Status quo of rubber stamping with non-transparency reports or more involved in decision making and transparent reporting?  

Indeed the next few months are gonna be interesting!    Especially with FCC Open Meeting on April 7 (don’t forget to watch on website). 

eyes open & thumbs up,

Ed

Long Link:  (long? eh) http://www.r-l-s-a.com/



SVRS Ex-Parte Comments..

22 03 2011

All..

Check out the link.

SVRS Comments

SorensonVRS reiterates on the following. 

"..in Sorenson’s comments stating that
(1) the Commission should not prohibit VRS providers from operating call centers in Canada;
(2) so-called “white label” operators should not be permitted to provide service; and
(3) interpreters should be required to work in supervised call centers. I also pointed out that the Commission needs to consider additional steps to prohibit slamming and to ensure that VRS providers do not interfere with valid attempts to change their default provider."

I do not agree on call centers in Canada being provided for USA, unless call centers in Canada provide services for Canadians.  There are too many variables that need to be addressed first; fluency in sign language, familiarity of USA culture, etc. etc. so no not at this time.  Maybe in future? 

"White label" I would say that pending the FCC’s new regulations (hopefully within a few months), that issue will be resolved once and for all.  FCC will likely do it in a professional and humanitarian manner where it will weed out the ones that do not deserve to continue, and keep the ones that actually provide a true VRS.  So I agree, but do a due process that is fair for all. 

Interpreters work in supervised call centers; that I agree.   The issue is how to define "supervised".  Are overhead surveillance cameras that watch the entry/exit door as well as Video Interpreter station and that these cameras are at another location sufficient as "supervised"; in other words, remotely watched?  ZVRS believe it does.  

Prohibit slamming? Hmmm – that is an interesting comment.  Allow me to explain why:  “Slamming” is the illegal practice of switching a consumer’s traditional wireline telephone company for local, local toll, or long distance service without permission."  In hearing telephone industry, that is no brainer.   In VRS industry, that’s tough to do because practically all of deaf/hoh VRS users I know have more than one phone numbers; many of them have 10 digit phone numbers from each different VRS providers. Many of them use several VRS providers. 

Porting is a way where deaf/hoh who wishes to port his/her phone number to a different VRS provider.  That is permitted and allowed by the FCC.    Is SVRS trying to stop porting the phone numbers to a different provider?   I am not sure why SVRS made that statement.   

"VRS providers do not interfere with valid attempts to change their default provider".   Here, I think, the FCC needs to define what are the "valid attempts"; in other words, define that.   Valid attempts can be considered same as "pestering" if the VRS representatives actually call and bother VRS users with other VRS providers for no reasons at all.   So need to be careful on how to define that and what is permissible and what is not permissible.  Unfortunately this is a tough one as it touches on outreach/marketing issues.  Outreach/marketing issues within the VRS is an ongoing issue for VRS industry and the FCC.   Eventually, the FCC will need to address that.   Why?  VRS industry is funded from federal fund (even though telephone companies, etc. contribute the money to this fund; FCC does have oversight over fund) so public fund needs to be distributed fairly. 

Now my dear edsalert readers, I’ll like to hear your thoughts/rants/raves/analysis/whatever.

eyes open & thumbs up,

Ed

Long Link: https://prodnet.www.neca.org/publicationsdocs/wwpdf/32111sorenson.pdf



NASRA Comments!

18 03 2011

Folks..

NASRA is National Association of State Relay Administration.  NASRA is composed of about 32 states.   State relay administrators typically are representatives of their states and are members of this prestigious association.   Not open to public.    I have fond memories of NASRA as having been chair thrice: two full term, and one very short term.   Very good association. 

A rare comments to the FCC from NASRA forthwith.  All the more unusual as to the nature of the Comments; basically giving quite detailed report of failures of Captioned Telephone Service (CTS).  CTS is mainly used by hard of hearing as well as the elderly persons; there is a growing number of hard of hearing in the USA using CTS so the impact is not small.  

Although couple telephone companies provide CST, the actual service is provided by Ultratec/Captel Inc.   Ultratec/Captel has the monopoly of CST.  

NASRA Comments

Quotable quotes:

"..outlining our concerns including, but not limited to, the proprietary nature of CTS provided over the public switched telephone network, the inability of the CTS resellers to make fundamental changes to the service, and the close proximity of the only two centers that process calls."

The above is referring to if one call center fails due to inclement weather so likely will the other close one.   The below bears that out. 

"Due to four separate technical, staffing, or weather events in a two-month time span, CTS users nationwide could not make telephone calls in a functionally equivalent manner."

"During the February 2, 2011, snowstorm in Wisconsin, where the only two Ultratec/CapTel call centers are located, employees could not get to work at either center. NASRA found that:
* Call answer times were extremely long. We received reports of wait times of over 5 minutes in many instances.
* The majority of calls in queue were abandoned after many minutes of waiting.
* There were many more abandoned calls than there were answered calls.
* There were also long wait times to reach a CapTel Customer Service representative."

The following comment is an interesting observation by the NASRA.

"Interoperability – ALL captioned telephone equipment for landline and IP based captioned telephone calls, regardless of provider, must be interoperable between providers of service. Interoperability should be required to the same extent as the FCC requires Video Relay Service (VRS) equipment to be able to be used to contact any VRS provider no matter which provider equipment is used."

Suffice to say, click and get eyeful of NASRA’s concerns.   NASRA is represented by about 32 states, I am sure the FCC will take action on this.  

eyes open & thumbs up,

Ed

Long Link: https://prodnet.www.neca.org/publicationsdocs/wwpdf/31711nasra.pdf



April 7 Agenda for FCC Commissioners Open Meeting

18 03 2011

Folks..

There are several items for the Open Meeting on April 7, but what caught my eye was this one item.  
 

  • Structure and Practices of Video Relay Service Program:  Report and Order will adopt rules to detect and prevent fraud and abuse in the provision of video relay service (“VRS”).  Also, a Further Notice of Proposed Rulemaking proposes to require all VRS providers to obtain certification from the FCC under new, tighter certification procedures in order to receive compensation from the TRS Fund.

The language on "Report and Order to adopt rules to detect and prevent fraud and abuse".   That’s simply GREAT and about time.  I am already visualizing a tall, sturdy Oak tree with strong branch, and noose hanging loose from the branch waiting for the guilty ones.  

Another language that was intriguing is "..to require all VRS providers to obtain certification.." and this "..under new, tighter certification procedures..".    This to me seems to mean ALL VRS providers including certified and possibly non-certified providers.  That, too, is good. This could very well help FCC whittle down number of VRS providers out there now.   Visualization here is the guillitone block – it will be interesting to note which VRS provider’s head will be chopped off.

This Open Meeting will be available for viewing via Internet.  "..

watch the live stream at www.fcc.gov/live.".  

Gentle Readers, this is one live stream I will be watching and you all should, too.   I hope it will be captioned, though.

eyes open & thumbs up..

Ed B