Dr. Z has a confession to make. He practices what he preaches. He counted to 100 (link) before making his views known on the proposed rates submitted to the FCC by NECA.

There have been vlogs and blogs posted in the last few days on this issue–some emotionally charged, some well-thought out.

First of all, we need to realize that the whole thing is part of a process. The process is that all TRS and VRS providers are required by FCC regulation to submit their projected costs for services for the following year to NECA. NECA is an organization that is contracted by the FCC to take care of this task. They reviewed the data submitted and made this information available to the FCC as they do every year. The FCC is now asking the public what they think of the rates, which is due May 14th. The FCC will then review what the public thinks along with the information submitted by NECA and make its decision for 2010-2011 or may change the length or the tiers or do something new. This is what we do not know yet.

The rate is important to all VRS companies. This is how they get paid for their services (interpreters, telephone lines, internet costs, salaries.) Like with our home budget, if we do not bring enough money home, we have to make cuts. If we bring more money home, we spend it on things we want or make improvements to our home. This is no different for the VRS companies.

The FCC structured rates for 2007-2009 into tiers. The smaller companies are in Tier 1 and the bigger companies are in Tier 2 and 3. The tiers are determined on how many minutes they provide in a given month. The smaller companies have higher fixed costs and cannot spread them as well as the larger companies so the FCC recognized this and they set the rates so that the smaller companies are paid at a higher rate per minute than the larger companies.

This time, the rates do not seem right. It shows something like this–$5.7754 for Tier I, $6.0318 for Tier II, and $3.8963 for Tier III. How can Tier 1 be lower than Tier 2. Logic says Tier 1 should be higher than Tier 2 because Tier 1 reflects smaller companies who have higher costs and cannot spread them as well as Tier 2 (which is for larger companies.) There is a big drop for Tier 3 for much larger companies. Also one company, which is not named, submitted their projected costs 6 weeks later than the February deadline. And this company was in Tier 3, so NECA had to disregard their submission. Whether this had a big effect on the rates for Tier 3, we will never know and could that have made the Tier 3 rate larger–who knows?

ZVRS submitted a proposal changing tiers from 3 tiers to 5 to make it more fairer for smaller companies and to encourage them to grow and develop (and not be penalized for the growth.)

The FCC indicated back in November that the VRS service is “here to stay” (link) after the arrests for fraud took place. In determining the rates, Dr. Z is asking the FCC to think of how the rates are going to affect the VRS service, bearing in mind the smaller companies are more sensitive to rate determinations since they have a smaller area to spread out their fixed costs.

If you want to tell the FCC you want to be sure that VRS quality is not going to be affected by whatever rates they determine, you should feel free to send your comments to the FCC. (link)

There is nothing in the proposal that says the FCC wants to shut down VRS. The only thing that impacts VRS is if the rates are cut, the VRS providers will need to cut back somehow on the services they provide. The FCC needs to be sure that the cuts do not impact the quality of the VRS service. This is a responsibility the FCC upholds for deaf and hard of hearing Americans.

Dr. Z wants to set the record straight so consumers have full access to facts–not assumptions or emotions.

Dr. Z cares about your communication access.

Disclosure: Dr. Z is a contractor working with CSDVRS on several projects.