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

Comments : 32 Comments »
Categories : Alerts, FCC Issues, VRS

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

Comments : 4 Comments »
Categories : Alerts, FCC Issues, VRS

Convo Submits Ex-Parte Comments/Docs

2 03 2011

Folks,

As noted in "about" tab of this edsaelrt a disclaimer that I have two caps:  edsalert and Convo.   That said, here are several ex-parte comments by Convo.

List of VRS providers and their features  

It has disclaimer: "The information contained herein is the result of independent research by Convo. Although Convo believes it to be accurate in all material respects, it is not possible to guarantee its accuracy due to the nature of certain sources from which it was collected"

The spreadsheet is revealing.   Keep in mind the FCC’s basic requirements of what a business model of VRS should have: 

  • Own ACD (technical platform)
  • Own Call Centers (more than one for redundancy requirement)
  • 24/7 Service
  • Have access to 9-1-1
  • Meet all the requirement of TRS Regulations

You can look at the spreadsheet, and look at each VRS providers and see which seems to meet the above requirements. 

Recommended VRS Reforms

Convo suggests these as a way to start dialogue:

  • "Establish a nationwide voucher program for devices with which to use VRS software so that marginalized potential VRS users can finally access VRS;"
  • "Institute an “access fee” for videophone providers if their videophones are used to facilitate calls through other VRS providers"
  • "Establish a nationwide voucher program for devices with which to use VRS software so that marginalized potential VRS users can finally access VRS"
  • "Implement a centralized server or servers for VRS user authentication and user data"

Convo offers thoughts on expanding VRS Access:

  • Lack of VRS equipment and rationale why people may not have equipment
  • State telecomm equipment distribution: examples of devices that may be eligible for vouchers
  • Lack of knowledge of how to use VRS equipment
  • Lack of broadband Internet Access
  • Inability to afford braodband Internet access

White Papers on VRS: http://fjallfoss.fcc.gov/ecfs/document/view?id=7021031052
(note: was unable to put in short name for above link. Dunno why, sorry about that; just copy and paste)

This link on White Papers on VRS: you will need to be geek to understand this.  However, White Paper does offer explanations here and there.    

FYI:  Convo, based on historical reporting to the FCC, only one "white-label" VRS provider that has consistently submitted comments to the FCC’s NPRMs, and ex-parte comments on various issues as well as having almost monthly meetings with the FCC.  

eyes open & thumbs up,

Ed

Long Links:

List: http://fjallfoss.fcc.gov/ecfs/document/view?id=7021031050
Reforms: http://fjallfoss.fcc.gov/ecfs/document/view?id=7021031051
White Paper: http://fjallfoss.fcc.gov/ecfs/document/view?id=7021031052

Comments : 15 Comments »
Categories : Alerts, FCC Issues, VRS

CSDVRS Posts on “Secure Virtual Call Center”

24 02 2011

All..

As promised, here is another VRS Provider’s ex-parte comments.

Check out CSDVRS’s comments.  Cousin Vinny complained about bending his neck to read powerpoint.   I had to bend my neck to read the powerpoint as well.  Thanks, Cousin Vinny, for alerting me of CSDVRS’s comments.     

CSDVRS Comments

First of all "Secure Virtual Call Center" is nice way of saying this is for Interpreters interpreting from home in a secure way.  CSDVRS shares its "Share Case Study" and offers recommendations. CSDVRS is making its case of "disaster recovery" and to supplement main CSDVRS call centers.  Several redacted slides, but one slide that was interesting was "Schedule Impact" slide; look at its "recoup" data by using home interpreters. 

Quotable quotes:

"Ability to recover staff losses"

"Secure at-home-interpreting should be permissable under Commission rules"

"Must be supplement to provider’s existing Call Center"

There are more quotable quotes, but my neck can’t stand it anymore  ;-] so I’ll just let y’all get ur necks do a 90% degree turn to read rest of them.  

Once a long time ago, we had discussed this on this edsalert; wow, it was controversial at the time.   I’m curious.  Is it still controversial after you read CSDVRS’s position?  

Let us know ur thoughts.  

eyes open & thumbs up,

Ed

Long Link:

https://prodnet.www.neca.org/publicationsdocs/wwpdf/21811csdvrs.pdf

Comments : 5 Comments »
Categories : Alerts, FCC Issues, VRS

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