FCC's Possible VRS Service Changes Draw Support; Compensation Seen as Key
Industry parties and others mostly welcomed possible video relay service improvements floated by the FCC, but also urged the commission to address associated costs and stabilize industry compensation in the face of a four-year regulatory schedule of rate cuts. In a recent Further NPRM, the FCC sought comment on ways to enhance VRS provision of video-connected interpreters for the deaf and hard of hearing to communicate with hearing phone callers. Comments filed in docket 10-51, most of which were posted Tuesday, generally supported strengthening VRS provider duties to answer calls quickly and conducting a trial of interpreters with specialized skills. They split on possible use of at-home interpreters.
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While some changes could enhance VRS “functional equivalence” to communications used by hearing individuals, as prodded by the statute, service providers made related proposals as part of a “unified package of interdependent proposals” that included stabilization of their compensation, said Sorenson Communications, the largest provider. The industry had asked that all compensation rates be frozen to head off further cuts, but the FNPRM proposed to temporarily freeze the rates for the three smallest providers only. That proposal was addressed in a separate comment cycle (see 1512100054) and could produce a draft order this month (see 1512280033). VRS compensation is paid out of the FCC Telecom Relay Service (TRS) Fund.
“The Commission seeks to have its cake and eat it, too, by allowing rates to fall but adopting these service improvements anyway -- in many cases without any additional compensation for providers,” Sorenson said. “The Commission should not delude itself into thinking that it can strangle VRS providers with rate cuts but uphold quality through mandates."
Purple Communications, the next-largest provider, said the bifurcated approach to VRS rates and service improvement raised concerns, in light of an FCC reversal in court on a previous rule to bolster the call-answering speed requirement. “The Commission must directly tie any mandated service level improvements to an FNPRM addressing the VRS rate methodology, including specifically taking into account the impact of service improvements on provider costs, or risk being overturned once again,” the company said. Convo Communications, a small provider, said the FCC can't resolve the VRS compensation issues until there's more certainty about quality standards.
Telecommunications for the Deaf and Hard of Hearing and other consumer groups backed various possible service improvements. “The Consumer Groups urge the Commission to refrain from making further rate decreases for VRS until the Commission adopts service quality standards addressing interpreter accuracy and other parameters, ensures that it adequately compensates providers for essential costs in a transparent manner that includes incentives for research and development to improve VRS and other TRS services, and ensures the burdens of any VRS rate cuts in any rate tier do not fall primarily on deaf and hard of hearing consumers,” they said. Registry of Interpreters for the Deaf said the FCC should “prioritize interpreter qualifications and performance when considering quality of service improvements.”
Commenters backed the FCC proposal to strengthen an existing VRS provider duty -- requiring 80 percent of calls to be answered within 120 seconds (as measured monthly) -- to answer 80 percent of calls within 45 seconds, as proposed by industry and a commission advisory panel. But Purple said the agency was viewing the proposal “in a vacuum without regard to cost,” ignoring the impact scheduled compensation cuts would have on providers. Purple said its support was conditioned on a rate freeze and another FNPRM addressing the VRS rate methodology.
Providers urged the FCC to change its current “all or nothing” approach to penalizing them a fixed amount for not achieving the monthly call-answering standard. They urged a “sliding scale” approach. The consumer groups and interpreter group backed the FCC’s proposed standard, with the former also calling for raising the metric over time and backing provider calls for economic incentives for surpassing the standard.
Commenters supported an 8- to 12-month trial of “skill-based routing” in which VRS callers could ask that calls be sent to interpreters with specific skills in foreign languages, signing styles and subjects such as medicine or law. Providers criticized the FCC proposal to not compensate them for the trial. The consumer groups said they were concerned providers wouldn’t participate in the trial if their compensation rates aren't frozen to prevent further cuts.
Commenters backed TRS Fund compensation for including deaf interpreters on some calls to enhance communications, or at least a related trial. They also supported an FCC proposal to allow VRS providers to assign 10-digit “iTRS” numbers to hearing callers -- some of whom know sign-language -- to allow them to have video calls directly (without an interpreter) with other VRS users.
Commenters split on a proposal to allow providers to use at-home interpreters. ASL Services, Hancock, Jahn, ZVRS and the consumer and interpreter groups supported the idea, with safeguards, while Convo, Purple and Sorenson were opposed. Sorenson said the costs would be “astronomical” and cited previous FCC concerns about security risks and possible fraud and reduced service quality.