On May 16, 2011, the National Association of the Deaf (NAD) took the lead, and was joined by other consumer groups, in submitting comments in response to a Notice of Proposed Rulemaking issued by the Federal Communications Commission (FCC) asking for comments about rates and compensation for Video Relay Service (VRS) for the 2011-12 Interstate Telecommunications Relay Services (“TRS”) Fund year. The FCC sets the annual rates and compensation for VRS.
The NAD generally avoids commenting on the rates and compensation and instead focuses on the principles used to determine the rates and compensation. In our comments, we encouraged the Federal Communication Commission (FCC) to keep the goal of functional equivalency at the forefront and make equal access the highest priority in determining the rates and compensation. Functional equivalency is required by law and the rates and compensation should be determined in a manner that best ensures functional equivalency for Americans who are deaf, hard of hearing, late-deafened, and deaf-blind.