VRS Providers Suggest FCC Wants Service Improvements Without Paying for Costs
Video relay service commenters said the record shows a disconnect between FCC attempts to improve VRS service quality while squeezing industry compensation under a four-year rate glide-path, which was intended to bring rates more in line with costs. In replies posted Tuesday in docket 10-51, the providers and a consumer group voiced support for various service improvements, but they urged the commission to address cost and compensation concerns. “What the industry is saying, and consumers recognize, is additional features aren’t free,” one industry representative told us.
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The six VRS providers proposed last year that the FCC halt scheduled cuts in their compensation rates and address cost methodology issues as part of a package to stabilize their revenue and improve service quality. But in a recent Further NPRM, the FCC teed up various possible VRS service improvements to enhance “functional equivalency” with regular phone calls, and proposed to temporarily freeze the compensation rates of the three smallest providers only. VRS provides video-connected interpreters for the deaf and hard of hearing to communicate with hearing phone callers. It's funded by the FCC Telecom Relay Service (TRS) Fund, which taps interstate and international telecom revenue from industry.
Sorenson Communications said initial comments showed the service enhancements the FCC floated can't be considered in isolation (see 1601050047). “The comments confirm that the Commission should not mandate a vast array of service enhancements while continuing to drastically slash rates every six months,” it said in reply comments. “If the Commission wants to improve service, the first thing it must do is fix rates -- mandating service improvements without fixing the rate system is an exercise in futility.” Assuming adequate funding, Sorenson said the comments showed support for changing a speed-of-answer requirement, allowing providers to use deaf interpreters, running a trial of “skills-based routing” and giving hearing users who know sign language access to 10-digit numbers to bypass interpreters, but only if providers don’t bear additional costs and security holes in a database are fixed. Sorenson said a good case hadn't been made for permitting at-home interpreting, which would require “extensive controls” that “are likely to be so expensive and so intrusive as to be infeasible.”
The Video Relay Services Consumer Association backed initial comments from advocates for the deaf and hard of hearing and an interpreter group. It generally supported the various proposals for service improvements, but urged the FCC to do a related analysis. “This should be done before the FCC further decreases rates,” the group said. “Inadequate compensation is a sure way for the FCC to reduce the level of interpreter competency. At the same time, the FCC is expecting the VRS providers to make improvements in these other areas. ... It is quite elementary that any further reduction in rates will be detrimental to the future of the quality of VRS.”
Purple Communications said it shared consumer group views that the FCC shouldn’t move forward with new service mandates “without thoroughly evaluating the impact on provider costs and quality of service.” VRS service quality will be impaired unless the commission ties such changes to a proceeding to address the VRS rate methodology and make corresponding rate changes, the company said. Purple said it supports: requiring VRS providers to answer 80 percent of calls within 45 seconds (as measured monthly), provided the FCC adopts the company’s proposals for a rate freeze and broad review; offering skills-based routing on a voluntary, trial basis; using certified deaf interpreters in a skills-based routing trial; and allowing VRS providers to assign 10-digit numbers to hearing individuals. Purple said it opposed the use of at-home interpreters.
ZVRS said that industry proposed service improvements with the understanding that they would be accompanied by VRS compensation rate stabilization. It urged the FCC to adopt various improvements, and unlike Sorenson and Purple, backed the use of at-home interpreters. “The concerns that led the Commission to ban the practice in 2011 have been mooted by technological advancements that have emboldened use of at-homework forces across industry and government,” ZVRS said. “The VRS industry should be afforded this same right. Authorizing at-home interpreters, subject to the rigorous safeguards proposed by ZVRS, holds clear benefits for the VRS industry and the TRS fund.” Convo Communications noted the agreement on most service improvements and chimed in on the cost concerns.