My Reply to the CBS Article about VRS Arrests

Feds Crack Down on Call Center Scheme - 26 People Arrested for Stea...

It is important to understand that Video Relay is NOT government funded. It is not an appropriation and it is not a tax. Each telephone company is required to make their services accessible to individuals with disabilities. This has been defined to be relay in the various forms (Traditional, VRS, STS, IP Relay, et. al). Each common carrier contributes 0.01137% of their telephone service revenue.

They do this because not all common carriers provide relay individually. There had to be a way to pay those that provided relay for those that did not, thus the interstate relay fund.

Let me state the contribution factor again in a different way; it is one thousand one hundred thirty seven hundred thousandths of one percent. You would not be able to see the penny if sliced to the proportion a private telephone company contributes.

Only a handful of telephone companies have opted to provide relay themselves. Other telephone companies have the same opportunity, instead they have chosen a group purchasing concept.

The fund collects a % contribution from all telephone companies; those carriers providing relay are paid based on minutes provided. They offer relay for themselves and every other telephone company. The goal being to recoup their own contribution & recover costs of providing relay for everyone else.

The FCC & the contractor responsible for adminstration of, NECA, serve as regulator of standards of relay service and as steward of the fund.

The 2009-2010 fund filing, submitted May 1, 2009, contains proposed provider payment formulas, fund size estimate and carrier contribution factor for the period July 2009 through June 2010. The filing proposes a fund size of $891.0 Million and a carrier contribution factor of 0.01137.

The fund pays for several forms of relay, not just video relay. Included is captioned telephone, speech to speech and voice carry over. These services are vital today and will become even more so in the near future. The veterans of Iraq and Afghanistan will experience greater numbers of hearing loss proportionally. Those citizens will not know Sign Language as they will be late-deafened. The veterans may also face a greater number of other types of disabilities which may effect speech as well. Someone who is late-deafened primarily uses captioned telephone and voice carry over.

The Video Relay service is in and of itself a vital tool in today's workplace for Deaf and Hard of Hearing citizens. I personally know of one CPA who is Deaf. He has told me on more than one occassion that VRS was key to maintaining his career status because clients did not have to deal with antiquated text based services.

While it may seem that Deaf people are getting some "high tech service", the callers on the other end who are hearing are also benefiting from the service. Today, unemployment benefits are verified via telephone touch-tone systems or voice recognition. These are for the most part not accessible via traditional text relay services. The necessity for more technological forms of relay is a function of the greater society that we all are a part of, nothing more.

The events leading up to today are unfortunate, but it should not be seen as a condemnation of Deaf and hard of hearing citizens or of the providers who work diligently everyday to ensure their customers have access to our nations telecommunication network.

There is much left to be done, that is true. I petitioned the FCC to establish the certification program. As founder and former President of the first common carrier certified by the FCC for reimbursement. I have seen the many financial, regulatory and corporate faces that are part of the industry; some good, some bad.

I believe the certification program brought positive technological and much needed regulatory changes. The main one being the adoption of Session Initiated Protocol which enables E911 emergency location and ten digit numbering for videophones.

The certification program simultaneously lowered the barrier of entry for some who would have the public believe they are advocates for ethical business practices, interoperability and service to the community.

I urge the FCC to continue its investigation and audit. Another form of fraud is misrepresentation of the underlying common carrier telephone service sold to the public, a key requirement for certification.

Should a company selling only a handful of telephone lines to the public reap multi-million dollar annual revenues from relay?

The positive benefits to our country and to the citizens impacted by video relay are immeasurable. We must remember that behind every minute of VRS, TRS, IP Relay, STS, CapTel, VCO, HCO, and the next new form of relay is a hard working American finding out about a promotion, a computer programmer at a non-profit leading a team of coworkers, a small business selling their product, a patient getting test results from their doctor and a mother talking to her son.