Ed’s Telecom Alert

Folks,

After talking with several relay veterans, I thought I’ll share our intriguing discussion regarding ten-digit ph nbr that the FCC will require come Dec 2008.   Also couple of comments to the recent vlogs will be included as well.

Obviously, we hope that the vendor workshop that the FCC mentioned in its Rule and Order would help resolve some of these following issues.  These are "what ifs" kind of thoughts. 

• If one has multiple-VP of same manufacturer in the same household, will the TN be assigned to all of the VPs?  Will all of them flash at the same time when they ring? 
• If one has multiple-VP from different manufacturers (i.e. MVP, OJO, VP-200) in same household, will it be possible to have same TN for all of the VPs, and all will flash at the same time when they ring?
• Will hearing person(s) with good signing skill that has a VP  be able to get a TN so deaf/hoh can call them?
• Will web camera with computer be assigned TN? 
• If the person has VP-200 (owned by SorensonVRS), and he/she choose, oh say, Viable, as his/her preferred VRS provider, will SorensonVRS be able to track person’s phone calls?
• If person’s preferred VRS provider is constantly busy, will other VRS providers have their own 800 number (instead of IP address) to offer? (Should be, but I ask that anyway.)
• Will Pagers/Laptop that use IP Relay get its own TN?  If so, how does it work if traveling?  How will pager/laptop access emergency center while traveling – will emergency dispatcher know where the person is?
• During a wide-spread emergency, like tornado hitting a city, or hurricane, or even – heaven forbid – terrorism, and calling the preferred VRS provider for emergency only produce busy time, can he/she call other VRS provider?  Will data or profile be shared among VRS providers so any VRS provider can handle emergency VRS calls?
• If resident only has one VP, and it breaks down, and had to wait for new replacement for weeks, and an emergency situation comes up, who should be held liable for that if any?  

Folks, if you have other issues that you feel should be considered, feel free to share.   

eyes open & thumbs up,

Ed B

All..

I got a private email asking me if there is any circumstance that I would support VRS working from home.  Also, a few private emails that don’t I trust interpreters?  Let’s think on it. The issue is about ironclad confidentiality and this must be met; it is not enough to say "I trust this person".  Trust has nothing to do with that.   I trust most, if not nearly all interpreters and I know they cede to code of ethics very well.  Then what is the problem?  It has to do with reasonable doubt.   So the question begs on how to remove the reasonable doubt?  

If done from home; then it would need to be a room with one door. The room would need to be soundproofed as well so family or dogs won’t react to noises by video interpreter.   Perhaps a cubicle within the room.  There would need to be at least two remote camera that is locked to two sites and "on" all the time; one to video interpreter so the quality assurance control can be maintained remotely if needed and one to the door to ensure no one comes in and out and can be viewed remotely by HQ.      

There would need to be a software program or some kind of foolproof system set up where if need to get support from the HQ. For example, to replace video interpreter (time up or get tired or something), or to provide support.     Emergency procedure needs to be well thought out to maximize the speed of processing an emergency call. 

Would I go for that?   My answer is only if the interpreter pool is at VERY critical point.   I do not think we’ve gotten there yet, and I think there are other viable solutions that are better met – such as sharing of pool of terps by a few VRS providers, or even VRS providers working with other VRS providers in utilizing their pool of terps, etc.  

Comments, anyone?

eyes open & thumbs up,

Ed

All..

Disclaimer: These are just my thoughts and mine alone and no one else including Texas PUC.  Just my observations based on my past experiences.  

Like Robin, I do not object to VRS providers making profit and, in fact, encourage it.  Otherwise they would have no incentives to stay in business.  I also agree with Robin that sharing cost breakdown with public will do a long way helping people understand where VRS providers all are coming from on why Reimbursement Rates should not be further reduced.  Will that happen? Not very likely – there are too many secrets in a cost breakdown that other VRS providers would love to analyze or as will state administrators ;-]  

I support VRS Provider’s premise that VRS Reimbursement Rate should stay the same for a few years.   The obvious reason for that is that VRS industry is labor-intensive undertaking – big time, so the salaries for video interpreters need to be consistent.  So I agree with VRS providers on that position.  

Should VRS Reimbursement Rates be reduced or increased or maintained as it is now?   The honest answer is I don’t know, and neither ANY of you – obvious reason is that you and I have not seen the cost breakdown of VRS providers – so really we do not know.  We only have word from both the FCC, NECA, and VRS providers that they are either too high, too low and all that.  

On other hand, it is interesting to note that there are now 11 VRS providers and still more to come.  So far they haven’t bankrupted, and, so far, from all appearances, they’re not likely to bankrupt anytime soon.  I wonder why?  

I was surprised at number of letters from folks writing to the FCC – over 1,000 – based on what?  I know it is not based on cost breakdowns of VRS providers cuz I haven’t seen any.  So what is it based on?  It is based on word of a VRS provider which we cannot say is "neutral".  Also, equally disturbing is that in one of retired complex in Texas, a renowned deaf leader who is known for his/her savvy would be collecting signatures from the senior folks protesting further cutbacks of Reimbursement Rates for VRS providers.  An hour later, one of the local young deaf man asked few of these elderly folks who signed the form, asking them what did they sign the petition for?  Almost half of them gave wrong answer; other half understood the reason for signing the petition. I wondered, how widespread that was?  I have no way of knowing, but it did make me pause and wonder.   I would love to know what the FCC has to say about that.  

I have felt that VRS providers are wee bit overpaid, but the truth is I cannot prove it and for all I know they could be grossly underpaid.   NECA (National Exchange Carrier Association) and the FCC are the ones that get to see the cost breakdown of VRS providers.   They are supposed to be good at that and professionals in accounting. I think I would have little more faith in regulators than in VRS providers who obviously are not neutral and would want more $$ in anyway they can get hold of them.

Other thoughts: As a state regulator, I wondered – if cry for increased reimbursement rates would only reinforce the FCC’s initial decision to pass the cost of VRS to states, this is what probably is likely to happen.   

Most states will opt for what they perceive to be the cheapest route.  What will that be?  RFP (Request For Proposal) to select ONE VRS provider, and ONE Internet Relay provider.  Boy, that would be a nightmare, I think.   Suppose Arkansas chose HamiltonVRS, what will happen to all these vp-100 and vp-200 distributed by Sorenson in Ark?  Remember these vp are on loan basis, so will Sorenson "recall" them?   Or if vp products breakdown or problem with technical issues with vp, Sorenson will likely not serve the people of Ark because they will not call SVRS.   So that means Ark would have to include video phone or video conference program to be part of the equipment distribution program or HamiltonVRS would distribute the VP, however, Ark would pay for them.   Because of that, RFP for VRS likely will include distribution of VP, so guess which of the VRS providers likely will offer the lowest cost of proposal?  It does not take rocket scientist to figure that out.  

RFP procedure likely will see GREAT reduction of number of VRS and Internet Relay providers down to two or three. 

Ouch..

So separation concept – keeping equipment and service separate – seems like a good idea.   I fervently support separation of VP and service.   What will happen if this happens?   I don’t know, and can only guess at results, and I’m sure in the beginning it will be rough going, but once the rough going gets ironed out, we’ll see a lively and fairer competition among VRS providers.   I almost can promise you that.  

 I’ll stop musing and see, if any, folks will comment on my musings..

eyes open & thumbs up,

Ed