All..
Wow – this is a MUST reading of the FCCs latest report, order and
declaratory ruling as it will impact VRS providers as well as some of
the consumers.
To view his vlog, click here
. (Flash Player Required)
I will try to summarize this, basically it is about how relay
providers – VRS, IP Relay, traditional TTY Relay, Speech to speech,
and Captioning Telephone Service – are paid in a different way. The
FCC also had declaratory ruling which means it outlines rules what
VRS providers can do and cannot do.
If u want the gritty details, click here:
http://www.edsalert.com/wp-content/uploads/2007/11/fcc-07-186a1-new-rates-mars-tiered.doc
Latest FCC report, order, and Declaratory Ruling
Here is my brief summarization of the FCC stuff. I will start with
Declaratory Ruling first because it impacts VRS users, organizations,
and VRS providers. Please bear in mind this is not a NEW rule; it is
based on past ruling that the FCC felt need to clarify. The following
declarations are:
Relay providers may NOT offer consumer financial or other incentives
(i.e. rewards) – directly or indirectly – to make relay calls.
Examples: sweepstakes that encourage VRS user to call particular VRS
provider; that is not allowed.
That use of customer call base or database by VRS providers to
contact relay users for political or marketing practices are not
allowed. What this means is that VRS providers cannot use VRS users
information to contact VRS users for political or improper marketing
practices. Example of that is by deploying an email message,
postcards, etc. to inform them about pending TRS compensation issues
and urge them to contact the Commission about the compensation rates.
This is not allowed.
Track relay users usage and then determine if person should get a
new video phone or upgrade. this is not allowed.
Impermissable VRS marketing practices such as “use this VRS or you
will not get upgrades” or “to get this video phone, you must use our
VRS” or “if you want to keep the video phone, you must use VRS”. All
these are not allowed.
Sponsorship that are tied to service usage. Examples of that is
state association or local deaf club or alumni club having a contract
to receive financial incentives (like 25 cents per min or something
like that). These are not allowed.
Charitable contributions by a provider based on total calls made.
Charitable contributions/gifts/payment by a provider based on
“failure of a call to meet specific time” (in other words, long wait)
– a contribution will be made to a third party organization. This is
not allowed.
By registering with a provider and become its “VIP” customer and
receive reward or financial incentive. This is not allowed.
Providers cannot give relay users equipment (i.e. video phone or
pagers) as part of outreach efforts or for other purpose, and then
seeing lack of use of the provider, get back the equipment.
Why did the FCC decide to do these? The Title IV of the ADA indicate
(according to the FCC) that relay providers are intended to be “dial
tone”; in other words, provide telephone service. Also, relay users
do not pay for the service, the federal funds do. It is not same as
hearing person who pays for the service. For example, pay $60 for
1200 minutes, and if beyond that, then person has to pay additional
fees. There are no obligation on relay user to watch their usage
therefore the FCC does not want any unnecessary minutes that may be
logged and billed to the federal fund. Click to the link, you will
read additional details on this.
Now to this new issue. Before I go into this, it is worthy to note
that the Fund for relay service has grown from approx $40 million in
2000 to over $550 million for FY 2007. Out of that $550, $430 Million
is from VRS. This means about 75%. Whew&.
Now there is a new cost recovery methodology for TTY relay service
including Speech-to-Speech which is called “MARS” plan (Multi-State
Average Rate Structure). This methodology simply is use state data to
determine the reimbursable rate. The FCC will collect all costs of
relay service of all states, and also collect all minutes generated
from each states, then calculate a weighted average rate by dividing
total state dollars paid by total conversation minutes.
Based on MARS, interstate TTY relay service, the reimbursement rate
is $1.59 per conversation minute. This is interesting. Remember this
is interstate relay service. In Texas, our reimbursement rate is
$1.29 per conversation minute.
MARS gave interstate Speech-to-Speech $1.59 plus $1.13 for outreach
costs for total of $2.72. Historically, persons with speech
disabilities are difficult to reach hence this. I applaude the FCC of
this cuz I see great need for that, too.
MARS gave interstate Captioning Telephone Service and IP Captioning
Telephone Service $1.62. This is particularly interesting cuz of IP
CTS (Internet) being reimbursed by MARS methodology.
IP Relay at $1.29 (not from MARS methodology)
VRS:
If under 50,000 minutes, then $6.77
If over 50K to 500K, then $6.50
If over 500K, then $6.30
The VRS tiered rates will be same for 3 years except that each
subsequent years ,the reimbursement rates will be reduced by .5%.
Obviously there is lot more to the FCC report; there are over 100
pages. Even so, worth reading&
Eyes open & thumbs up,
Ed Bosson
Relay Texas Administration
You can look up full details and vlog at his website.
Link:
http://www.edsalert.com/2007/11/22/fcc-latest-report-order-declaratory-ruling-wow-important-info/
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