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NAD Filed Comments about VRS Rates
By advocacy | June 8, 2007
On May 23, 2007, the NAD, along with TDI, ALDA, DHHCAN, CCASDHH, and HLAA, filed comments with the Federal Communications Commission (FCC) about the payment rate for relay services proposed by the National Exchange Carrier Association (NECA) for July 2007 through June 2008.
The NAD made these points:
The Americans with Disabilities Act (ADA) requires that Telecommunications Relay Service (TRS) be functionally equivalent to voice telephone service. TRS includes traditional TTY relay, Speech-to-Speech, IP Relay, and Video Relay Service.
Last year, the FCC raised questions about the TRS rate setting methodology. There is near universal agreement among consumers and providers, and the FCC has acknowledged, that the current method of computing TRS rates is flawed. Therefore, the FCC should freeze rates for TRS and related services at current levels until the FCC decides the questions and concerns that were raised last year. Issuing new TRS rates using the existing methodology would only perpetuate the problems. Any rate methodology adopted by the FCC must result in a rate that covers all reasonable expenses that are critical to making relay services available to the public.
If the FCC decides to go ahead and set new rates using the existing methodology, the FCC should ensure that those rates reimburse TRS providers fairly and sufficiently cover all reasonable expenses:
- TRS providers must be adequately paid for reasonable operational costs and properly allocated executive costs of their TRS services, including the cost of qualified deaf interpreters and the cost of implementing and providing emergency 911 services. In addition to direct costs such as salaries, office rent, and equipment, TRS rates must compensate providers for the reasonable cost of recruitment, training, and retention of communications assistants, including interpreters, and other TRS personnel, because ongoing recruitment, training, and retention is essential to the provision of quality services.
- The TRS fund must support general and brand name outreach and marketing. A larger, more reliable and more visible network of TRS providers will benefit the deaf and hard of hearing as well as the hearing communities.
- The TRS fund must support and cover reasonable research and development costs, which will help fulfill the FCC mandate to “encourage . . . the use of existing technology and . . . not discourage or impair the development of improved technology.â€
- Insufficient funding to cover these areas would be a disservice to members of the deaf and hard of hearing communities and the hearing public by reducing the visibility, reliability, and availability of existing and future TRS services.
Further, the FCC should expand the TRS Fund Advisory Council’s role in the rate setting process by allowing it to study the issue and make a recommendation before the FCC takes action. The Advisory Council consists of a cross section of government, business, and community members and can offer the FCC a balanced perspective. Any rate methodology adopted must provide more transparency in the rate setting process.
To read the full comments, go to VRS Rate Reply Comments. To see the NECA proposed rates, go to http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-07-1978A1.pdf.
Topics: General |
June 8th, 2007 at 5:30 pm
Here is my letter that I left at Amy’s website:
Dear VRS Companies, Interpreters, and Agencies,
Firstly, I wanted to thank each of you for making sure Deaf and Hearing community will be able to communicate through translators. I appreciate your hard work.
I must say that Amy has a good point. We Deaf people need to get involved in the VRS community in order to make our interpreting service’s costs are not a burden to the Deaf and Hearing community’s economic values. We value the reputation or our Deaf community. Anything that is a burden to the hearing community will not affect you but it will AFFECT the Deaf community. I wanted to make sure our taxpayers are not burdened by Hearing and Deaf needs. I am sorry to say but I suspect you charge very unreasonable price. As Amy said we need to see the Data Report. If companies like apple provide data reports, why can’t you?
Why do so many people complain that the costs of interpreting service are unbearable? We as Deaf people have a right to be concerned about them. As I see it, they feel burdened by your expenses. The Deaf community has a right to know how much you all charge people for interpreting service including VRS, freelance interpreters, and agencies.
I notice VRS/Agencies/Free Lancer interpreters, and interpreting requesters do not share their cost agreements with Deaf people. I feel strongly that Deaf people should have access to this information.
In closing, May I request of copy our most recent Annual Report? I will also be writing to FCC to request an explanation of why they have decided to cut the funding.
A solution to this problem can only be possible with full and clear communication between all parties.
Sincerely,
Aidan Mack
July 6th, 2007 at 1:46 am
These consumers have come together to push for equal access to telephone services through VRS because this issue is so important.