National Association of the Deaf

Submitted by andrew Phillips on Mon, 03/05/2012 - 10:31

The Federal Communications Commission (FCC) has proposed new rules and asked for suggestions on how to improve Video Relay Services (VRS). The NAD first found out that the FCC was considering making reforms to VRS last summer. We have been working diligently along with other Consumer Groups representatives, to let the FCC know our concerns about possible changes to VRS and also improvements we would like to see.  (Instructions on how to file at the bottom of the page).

The rulemaking has four key areas for reforms:

• TRS Broadband Pilot Program (TRSBPP)
• Better Technical Standards for VRS
• Change from a Per-Minute to a Per-User Reimbursement System
• Improvements to VRS Quality

1. TRSBPP

The TRSBPP program will make broadband access more affordable for many low-income deaf and hard of hearing people. This will allow some who never before could access VRS to enjoy this important service. It will also allow these people to make video calls to their friends and families. The NAD supports this great program, but believes that it should be funded by the Universal Service Fund (USF) which offers similar programs for hearing people. We don’t believe it’s fair for the TRS Fund to pay for this program. We also believe this program should also include training for deaf and hard of hearing people who are new to broadband. 

2. Better Technical Standards for VRS

The NAD supports this proposed reform. It will improve interoperability between different video phones (VPs) and hopefully with off-shelf equipment. We know that many of our members continue to face problems trying to make calls from their VPs to a different VP. 

3. Change from a Per-Minute to a Per-User Reimbursement System

This is the most important part of the rulemaking. The FCC wants to change the reimbursement system for VRS calls from the current per minute system to a per user system. What does this mean? Under the per user system, VRS companies would get a fixed amount of money for each customer for a specific time (for example, one year). This means that each person will have to pick one VRS provider and cannot use a different VRS provider for that year. The NAD believes that the per user system would cause many problems for our community.  

Some of you may wonder why the FCC wants to change the reimbursement system. The FCC has explained that under the per minute system, VRS companies are motivated to bill for more minutes, and not all of these minutes are legal. The FCC believes that with a flat rate for each user, the companies won’t be motivated create illegal minutes. 

The NAD believes that every government program faces problems with fraud, and that under both the per user and per minute systems, there will be fraud. Under the per user system, there are risks of different kinds of fraud – such as signing up people who don’t need VRS.  The NAD urges the FCC to address fraud in a way that will not hurt the consumers.

The NAD believes that there are three major problems with the per-user reimbursement system:

First, the profit motives of VRS companies would change from one where they want us to make calls and to give us good service, to one where they want us to make less calls so that they make more money. Under the current per minute system, the more service they provide, the more money they make. If this is changed to a per user system, the less service they give, the more money they make. This means that under a per user system, VRS companies will focus on signing up customers who rarely use VRS and avoid those who are heavy VRS users. As a result, the quality of VRS services would likely get worse.

Second, under a per user system, people would have to use only one VRS provider and could not use any other for a specific period (for example, one year). We know that many deaf and hard of hearing people often choose different VRS providers for different reasons. Suppose you need to call someone during a non-911 emergency but you are not able to get through on the only VRS that you are allowed to use? 

Third, in order to implement the per user system, the FCC will have to set up a system to register users who are real VRS users. If they do not, then VRS providers will sign up people who do not really use VRS. We are afraid that this registration system could be burdensome or intrusive. We might have to submit an audiogram or even take an American Sign Language (ASL) skill test in order to quality for VRS. 

For these reasons, the NAD is opposed to a “per user” system, and urge you to send your comments to the FCC to oppose this system as well.

4. Improvements to VRS Quality

The FCC asks how the quality of VRS can be improved. The NAD will submit its recommendations and encourages you to provide your feedback to the FCC about VRS quality. 

The NAD, along with other consumer groups, encourage the FCC to require that all VRS interpreters be nationally certified. It is our position that VRS interpreters should be subject to regulation just like other professions are. 

Moreover, the NAD is also asking the FCC to allow for better matching between VRS users and their interpreters. We currently have a "one-size-fits-all" approach for assigning interpreters and many times the interpreter assigned to a particular individual isn’t the best match, but might be a great match for a different caller. We envision a system where people can stick with the current matching system, or opt out and instead of taking the first interpreter available, wait for an interpreter who is a better match. The NAD hopes to work with the FCC to improve the current matching system.

This rulemaking includes many different issues that will have a tremendous impact on our VRS experience. 

Your help is needed now! Let the FCC know what changes you want and don’t want to see in VRS. We need you to file comments with the FCC. If we do not take action now, we may not like the new VRS system. 

Please go to the FCC comments website at http://www.fcc.gov/comments, select “Telecommunications Relay Service,” and then fill out the form and submit your comment. Comments are due on March 9. Please file your comments right away!

Thank you for reading and act now by sending your comments to the FCC. 

UPDATE 3/7/2012:

The FCC comments system at www.fcc.gov/comments has been down for several days and we do not know when it will be back online. We have been in touch with the FCC and they encourage people to file their comments through a different webpage:
http://apps.fcc.gov/ecfs/upload/display?z=ysqi2

Please visit the webpage, click “Submit a Filing (Express)” on the left side of the webpage. Then click on Proceeding #10-51, “In the Matter of Structure and Practices of the Video Relay Service Program.” Selecting this proceeding will take you to a website where you can fill out your information and write your comment on the VRS Reform rulemaking.

The deadline for comments is Friday, March 9th. Please file as soon as possible! We need to let the community know what we want to see with VRS.