National Association of the Deaf

NAD & Consumer Groups File Comments on VRS Rates



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On March 14, 2010, the NAD and consumer groups filed comments with the Federal Communications Commission (FCC) responding to questions about funding for video relay services (VRS), for an “interim” one-year period from July 2010 through June 2011. In our comments we told the FCC to make sure that the rates continue the current level of relay services and continue to advance functionally equivalent telecommunications.

What is functional equivalency? Twenty years ago, the Americans with Disabilities Act (ADA) required nationwide relay services that are “functionally equivalent” to telephone services. The U.S. Congress intended to make telephone communication services accessible to our community, using the very best technologies available. Functional equivalency is not frozen in time. Functional equivalency requires reassessment as new technology is developed and new services become available. For us, every action proposed or taken by the FCC and relay service providers should be assessed against the standard of functional equivalency.  In other words, everything the FCC and relay service providers do must move us closer to functionally equivalent telephone services.

While we have made many strides, we still have not achieved true and full functional equivalency. For example, hearing people today can make telephone calls from almost anyplace with their cell phones. The deaf and hard of hearing community continues to struggle to achieve this goal because our equipment is often stuck at one location or the connection is not strong enough to carry our call. Until we can make a call from almost anyplace, we will not have achieved true and full functional equivalency.

We have benefited from improvements in technology and services – such as VRS, captioned telephone, and Internet relay – that, over time, have lead to greater achievements in functional equivalency. In our comments filed with the FCC, we urge them to make sure that appropriate funding is provided to continue the current level of service and upward trend towards true and full functional equivalency.

In Part 2 of my vlog, I will go into detail about the NAD comments on VRS rates, the outcome of our meeting with the FCC on May 11th and other issues. Please view it to learn more about VRS rates.

Video Relay Service

We met with the FCC on May 11th and told the FCC to adopt VRS rates that will ensure the continued delivery of high quality VRS and not put advancement towards functional equivalency on “hold” for a year. We were pleased to learn that the FCC will soon provide an opportunity to begin a comprehensive review of VRS before setting new rates starting in July 2011 which we understand will be a multiple year rate. We look forward to working with the FCC, focusing on the principles necessary to achieve functional equivalency.  We will propose goals for the FCC to use to evaluate its regulatory and funding decisions.  To achieve these goals, sufficient funding is needed, such as for marketing and outreach, research and development, and other activities which are needed to continue moving towards functional equivalency.

The FCC considered four choices for VRS rates for 2010-2011. Two choices were based on past costs and two choices were based on projected costs based on information supplied by VRS providers. The FCC asked about one of the choices of VRS rates based on past costs. In setting prior rates, the FCC used projected costs.

We are alarmed by some statements from VRS providers that the proposed rates may put them out of business. We have asked the FCC to get the data they need from VRS providers to set fair and reasonable rates that ensure quality service and advance functional equivalency. We do not have access to the cost information that VRS providers submitted so we are not able to conduct any specific analysis of the proposed rates and their potential impact on providers and the pursuit of functional equivalency.

We told the FCC that they must consider the goals of high quality VRS technology, highly qualified and certified interpreters, improved speed of answer requirements, consumer marketing and outreach, customer service and training, technical assistance, research and development, and other things necessary to continue moving towards function