FCC Workshop on VRS Reform
December 17, 2009
Rosaline Crawford, Director, Law and Advocacy Center
National Association of the Deaf
- Relay services enable individuals with hearing or speech impairments to engage in communication in a manner that is functionally equivalent to telephone users.
- Relay services are intended to provide deaf, hard of hearing, late deafened, and deaf-blind people, and people with speech impairments, with equal access to the telephone network.
- The FCC must ensure that relay services are available, to the extent possible and in the most efficient manner, and the FCC must not discourage or impair the development of improved technology.
- the availability, innovation, and advancement of high quality and reliable relay services;
- maintaining the integrity of the Interstate Relay Service Fund; and
- FCC and other efforts to combat waste, fraud, and abuse.
- brand marketing by VRS providers; and
- outreach and education to all Americans about all types of relay services.
- NAD-RID national interpreter certification;
- qualified interpreters; and
- adherence to the NAD-RID Code of Professional Conduct.
- FCC certification for VRS providers;
- clear disclosure when a company is providing service for a certified VRS provider; and
- use of FCC’s enforcement authority to ensure providers meet relay service standards and requirements, and do not engage in abusive or fraudulent activities.
- the operation of VRS as a competitive service under a multi-year, tiered price cap scheme (which is the current system), which rewards efficiency and increases market access.
- transparency in the rate setting process, and access to cost data so we can provide meaningful input;
- a VRS rate methodology that covers all reasonable expenses of VRS providers;
- addressing the issue of VRS equipment (including research, development, manufacturing, and installation costs; availability; affordability; and interoperability); and
- measures against fraud and abuse addressed in enforcement actions, not part of the rate setting proceeding.
We urge the FCC to seek additional public comment on the issues presented today and to respond to requests for clarification, rulemaking, and reconsideration in a timely manner. We also urge the FCC to increase staffing in the Disability Rights Office, and include engineers and VRS users to address these issues.
We appreciate the opportunity to participate in this workshop today. We seek continued improvement in the delivery of VRS and functional equivalency for deaf and hard of hearing consumers.