YES SHOULD COMPLAIN TO FCC! MUST DEMAND CERTIFIED VRS ONLY NOW!

SCARE US IS NOT NICE!

NOW IS PERFECT TIME TO FIGHT FOR BEST VRS INTERPRETERS!!

DO YOU BELIEVE WHAT SOME BOSSES AT VRS SAY?? THEY WILL GO BANKRUPT IF
THEY DO NOT GET SAME $$$$$ RATES OF ALMOST $$400 PER HOUR!!!!

WHO CANNOT STAY IN BUSINESS IF MAKING THAT KIND OF MONEY?!?!? VERY FOOLISH TO SCARE ALL DEAF AND THREATEN TO CLOSE DOWN BECAUSE THEY ARE GREEDY AND ONLY WANT TO MAKE LOTS OF MONEY AND NOT GOOD MONEY LIKE ALL OF US.

IF YOU READ YOU FINISH KNOW THAT MORE AND MORE VRS COMPANIES ARE FIRING THEIR CERTIFIED VRS INTERPRETERS [OR CUTTING HOURS MEAN SAME SAME] AND USING MORE AND MORE NON-CERTIFIED YOUNG AND INEXPERIENCED VRS INTERPRETERS.

THIS IS WRONG AND MUST STOP. IF FCC IS PAYING $$$$ THEN WE MUST FIGHT
AND ASK FOR ONLY CERTIFIED INTERPRETERS. WE DONT LIKE IDEA THAT
MAYBE CALLING DOCTOR OR HOSPITAL OR LAWYER OR IMPORTANT MEETING ON VRS AND INTERPRETER IS NOT CERTIFIED!!!!

BAD INTERPRETER NO CERTIFICATION MEAN MISUNDERSTAND AND FRUSTRATION FOR VRS CONSUMERS AND WHY IF FCC IS PAYING ALMOST $400 PER HOUR!?!?

NOW IS TIME TO COMPLAIN TO FCC. YES MUST COMPLAIN THAT CUTS TO FCC RATES ARE NOT GOOD IDEA

BUT ALSO ADD THAT YOU DEMAND CERTIFIED INTERPRETERS ONLY FOR VRS!!!!

WE CAN WIN FIGHT THAT WE DEMAND HIGH QUALITY AND CERTIFIED INTERPRETERS ONLY!!!

WANT DO MORE ??!!?!


FOLLOW INSTRUCTIONS TO COMPLAIN TO FCC AND DEMAND CERTIFIED VRS INTERPRETERS ONLY. FOR THAT KIND OF $$$$ WE DEMAND BEST AND CERTIFIED VRS INTERPRETERS ONLY!!!


FCC announced they plan reduce amount money they pay to VRS like sorenson and purple. If happen FCC reduce pay then possible no more VRS!!! Please tell FCC you want keep VRS, tell FCC how important VRS to your life and allow communication with hearing people and other deaf friends. Most deaf finish throw away old tty so if no VRS then how communicate?


Here how you can tell FCC keep VRS

Step 1. Go to ECFS Express Upload Form

Step 2. . Complete the form with your personal information (all fields with an asterisk are required).

Step 3. Enter your comments and BE SURE to complain about non-certified VRS interpreters not acceptable.

Step 4. Select the “Continue” button.

Step 5. You will be presented with a confirmation page to review your comment before submitting comment. Select the “Confirm” button and your comment will be submitted



!!!!!!!!!!!!!!!!!!!KEEP VRS ALIVE WITH ONLY CERTIFIED INTERPRETERS!!!!!!!!!!!!!!

Detail on why Non Certified VRS is BAD IDEA

Reasons for getting Certified VRS only:


Non- Certified interpreters would not be able to work interpreting Medical or legal assignments in almost half of the United States and if they do, they almost all require supervision.

Many of the calls are of a sensitive nature- involving confidential information- Social Security related matters and Financial matters i.e. banks - Credit cards and mortgages.

Many states require certification or licensure to handle Medical or legal situations (Please note Texas' recent Medical Interpreter License Requirement)

Teaming or the pairing up of interpreters, is often done when handling conference calls and calls of a serious nature, 911 or Legal Interpreting- Due to current staffing levels and budget cuts-,may often have two non-certified interpreters handling the calls.

Steps need to be taken on several levels to be sure consumers are informed and to get what the tax payers have paid for.


There are Internal Measures (unseen by consumers- Deaf or Hard of Hearing and Hearing) such as invoicing the FCC for billable calls:

Monitoring the credentials of interpreters who process the calls and invoicing at half of the FCC rate for Non-Certified Interpreters. If the calls are processed by Certified Interpreters then the VRS companies bill at the full rate. This is not an unwieldy or difficult practice technologically as minute details are monitored on every processed call- Average Speed of Answer (ASA), Length of time to disconnect both parties of a call, etc...

The Payment of Half of the FCC rate is similar to many interpreting businesses where they use a sliding fee scale when using Certified and Non-Certified interpreters.

Please note that the requirements or standards have been lowered year after year in many VRS companies. In 2006- Applicants needed to be certified for a minimum of Five (5) years before they could apply- now there is no requirement with the larger VRS companies as they have successfully hired Non- Certified interpreters and reduced the hours of Certified Interpreters, basically having "outsourced" the qualified interpreters. The billing rate stays the same but the quality of service has been reduced and more importantly-in light of the recent fraudulent behavior exhibited by some VRS companies in the past couple of years- Less skilled interpreters leads to a longer processing time for phone calls due to more time devoted to understanding the Deaf or Hard of Hearing Callers or vice versa thus "padding" the billable amount of minutes.

Staffing levels within the Call Centers to make sure that there are enough certified interpreters on duty to team with non-certified interpreters in each Call Center if the companies insist on maintaining the use of non-certified interpreters. A requirement of One to One, at a minimum, should be incorporated.

Restore the experience requirement for working in a VRS Call Center- People who are just newly certified are still not necessarily ready to handle phone calls of a varied nature, minute to minute.

The Registry of Interpreters for the Deaf (RID) has a Code of Professional Conduct that states interpreters should not take on assignments that are beyond their skill level. The former requirements upon application were five years of national experience. Maybe the requirement can be reduced to two (2) or three (3) years but as has been evidenced in the staffing reductions of Certified Interpreters across the nation, most likely the five (5) year minimum requirement is sufficient.


There are External Measures- Clearly Visible or Advertised and adhered to standards for informed Consumers- both Hearing and Deaf or Hard of Hearing:

When answering calls- announce the qualification of the interpreter who is processing the call to both parties as Certified Interpreter (Using the standard Definition of Certified Interpreter according to the National Registry of Interpreters for the Deaf (RID) or Non-Certified.

If the VRS company only hires Certified interpreters then no announcement needs to be made as the information is readily available on the VRS websites and other promotional materials. (Please Note- There are several companies that already follow this policy and only have Certified interpreters processing their calls and would not be affected by the proposed change in billable rate of half for non certified interpreters)

The Deaf and Hard of Hearing Community has been led to believe that VRS interpreters are highly qualified (Certified) and are unaware of the fact that Non-Certified interpreters are working at VRS companies. They already have to share their lives with a third party (an interpreter) and now they have to slow their signing down, repeat common signs and finger spell common words repeatedly, and often end up more frustrated after the call than before due to the lack of skills of the interpreter. It is supposed to be seamless and quick. Unfortunately in this downturn in the economy, many VRS companies are letting go of their Certified interpreters or capping (limiting) their hours and increasing the hours of Non-certified interpreters. There is nothing wrong with that business practice unless the quality of service level drops to unacceptable levels and if it does not encourage an increase of billing minutes to the FCC and ultimately the tax payers because of unnecessary delays in service due to the use of Non-certified interpreters.


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Here is the statement from FCC:

“Washington, D.C. -- Today, as a step toward comprehensive reform of Video Relay Service (VRS), the Commission’s Consumer and Governmental Affairs Bureau issued a Declaratory Ruling to reaffirm the FCC’s rules and policies concerning VRS reimbursement and calling practices, and maximize efficiency and effectiveness of this program to ensure that the communications needs of deaf and hard-of-hearing consumers are met.

Bureau Chief Joel Gurin said: “Today’s action is a first step in fixing a system that is broken. It is essential to keep VRS on a sound footing. Consumers who are deaf or hard of hearing have come to rely on VRS as a service that lets them communicate easily, fluently, and expressively. The Telecommunications Relay Service Fund was established to support exactly that kind of communication. But the Fund can’t be used to support practices that are designed only to increase payments to VRS providers, rather than providing a necessary service for people who need it. We’re taking a strong first step today to stop these practices and ensure that the Fund is always used to benefit the deaf and hard-of-hearing consumers it was designed to help.”

VRS is a form of Telecommunications Relay Service (TRS) that enables deaf and hard-of hearing persons who use American Sign Language (ASL) to communicate with voice telephone users through video equipment, rather than through typed text. Video equipment links the VRS user with an operator who understands ASL and can serve as an intermediary between a person using ASL and a hearing person using his or her voice. Because the conversation between the VRS user and the operator flows much more quickly than with a text-based TRS call, VRS has become an enormously popular form of TRS.

Today’s action emphasized that VRS calls made or arranged to generate per-minute fees for the providers are not and have never been compensable from the TRS Fund, which funds all forms of relay service. This includes a number of calls initiated by or on behalf of VRS providers, including calls made to podcasts or recorded messages.

In the Declaratory Ruling, the Bureau addressed three specific reimbursement and calling practices. Specifically, the Bureau emphasized that:

  • Calls made by or to employees of VRS providers and their subcontractors are not eligible for compensation from the TRS Fund on a per-minute basis. Instead, costs of these calls are compensable as a business expense – and only if the VRS provider can demonstrate that they are legitimate business calls. In the past, some providers sought compensation for these costs twice, both at the per-minute rate and as business expenses submitted to the Fund administrator. Today’s ruling emphasizes that these costs are compensable only as business expenses, that the expenses must be justified, and that the costs cannot be recovered twice.

  • VRS Voice Carry Over (or VCO) is a service that allows a person who is deaf or hard of hearing to use his or her own voice to speak to a hearing party on a VRS call. The VRS operator will then translate the hearing person’s response into ASL for the deaf person on the call. It is possible to abuse VCO to make free long distance calls between two people using their voices. Today’s ruling states that such calls cannot be paid for by the Fund.

  • VRS calls that both originate and terminate outside of the United States are not compensable from the Fund.

Action by the Chief, Consumer and Governmental Affairs Bureau, February 25, 2010 by Declaratory Ruling (DA 10-314).”