Clearing the Air
An Op-Ed Editorial from Dr. Z

A recent request for clarification from Purple deserves comment:

First, I do agree the FCC needs to clarify practices in a timely way that may be in a gray area.

I applaud any effort at clarification.

I certainly agree that multi-party calls are reimbursable and that there should be no discrimination for deaf only versus hearing only calls. Dr. Z has participated in many effective multiparty calls thru the years and these are great time savers. A deaf group’s only alternative would be to drive or fly to meet in person. In the future this may be obviated by new technologies. I have seen some promising technology with MCUs that could help in this area.

There is a part of this clarification request that is very disturbing. It involves “outreach”.

We all have heard credible stories of deaf to hearing outreach where indeed the purpose was to drive VRS minutes. One of these involved hiring as many as 60 deaf working 2 shifts making calls all day with requirements to “extend the call as long as you can and be on calls for at least 80% of the time”. We believe this is abuse of the fund and of deaf people. We estimated this was resulting in an annual rate of minutes billed to NECA generating over $20M per year.

At the same time we have heard of hearing people calling deaf people for surveys or outreach to deaf. And this is from the same company that uses deaf to outreach to hearing. Wouldn’t it be simpler to have hearing outreach to hearing and deaf outreach to deaf? Of course no NECA minutes there. The Purple clarification calls for allowing these practices. I do not concur.

We all want to see deaf people hired in real jobs that have a legitimate economic basis other than driving TRS minutes even if the individual’s compensation has no direct tie to minutes. Certainly the provider’s compensation has a direct tie to minutes.

Of course there are times when deaf or hearing at a provider use the TRS service in the course of their job. However when the job is designed with the financial basis to drive VRS minutes then it is unethical and fraudulent.

In regard to 3rd parties:

If it is a third party that does not have compensation tied to minutes, then why are they doing it? ZVRS was approached by a company that said they could generate 10,000 minutes per day. They would do outreach for CSDVRS using a room full of deaf making TRS calls to hearing. They advised because the fund would not tolerate pay for minutes they would pay ZVRS for emails generated as a result of the calls. And then they went on to describe the likely number of minutes generated per email.

It does not take advanced algebra to figure out this formula. Cheating = Cheating. There are creative cheaters and non-creative cheaters but the formula prevails.

My momma once told me, “if it smells bad don’t eat it”. In TRS/VRS, we should ask? Does it past the smell test? If it doesn’t, don’t do it! Some things smell and some things stink.

This editorial in question indicates that there was an issue in making calls from a non-VP 200 videophone to a VP-200 videophone using an assigned local number.

I took it upon myself to check this further. Here is what I did:

Knowing people had problems calling me on my VP-200, I decided to verify my local number on the zvrs.com website.

It said my local number (802) XXX-XXXX was not registered on the national data base. A Sorenson installer put the local number on my unit last spring. He drove over 100 miles to my home to do that.

I called Sorenson technical support and explained my situation. The rep (No. 2030) said he was unaware of this situation. He put me on hold and said he would speak to his supervisor. He said his supervisor told him this was not a technical support question and he transferred me to Sorenson customer support.

The customer support rep (No. 50) answered my call. I explained my situation to him. He said everything appeared OK and he did not understand why the number did not work with non-VP 200 units. I explained that I was not the only one as I knew other deaf people had the same problem.

He put me on hold to talk to his supervisor (No. 36.) He came back on and said his supervisor asked him to write an email explaining my situation and they would get back to me.

I will keep you folks posted on this development on this blog.

Dr. Z

Note: As of today (August 17, 2009), I have yet to hear from Sorenson on this matter. I rechecked the info on the ZVRS website regarding the existence of my number on the national data base. It is still not there. I do not understand how difficult it can be to put my local number on the national data base.

This is the link to editorial #2 (for your review).

Here We Go Again
An Op-Ed Editorial from Dr. Z

Sorenson has filed a petition with the FCC on August 4, 2009 to restrict providers from assigning phone numbers. On the surface, we can understand how it causes confusion, but theres’s a problem with the request coming from the largest service provider in the industry seeking to maintain or increase market share by suggesting such actions.

The request basically asks the FCC to do two things:

1) not assigning multiple phone numbers to a device

2) a videophone device shall be restricted to a single IP address

I can understand the rationale for the first request. It does cause confusion especially on callbacks, and more so in the event of public safety (911) situations.

I respectfully disagree with the second request. This is to lock down the market to protect their market share since they have a large share of the market already. There are technical solutions such as Z-Connect provided by ZVRS which allows incoming calls to ring to a specific device without the need for a second IP address. If the FCC rules on the second one, it will force every deaf and hard of hearing user with multiple videophones to request additional IP addresses from their cable company or phone company at additional expense. This is unnecessary if there are technical solutions out there that render this moot.

I find it interesting that they filed it right after the TDI convention, without the opportunity to feel anyone out at the TDI convention. There were quite a number of Sorenson executives at the conference and they did not make an effort to ask others what they thought of this. A market leader should be responsible enough to seek and solicit feedback on this, working with other service providers to find the best solution for the deaf and hard of hearing citizens, rather that trying to determine the direction by going to the regulatory agencies without industry feedback or consensus.

If you were a market leader, would you be doing this alone, or work with others to provide the best solution?

This is the link to Sorenson’s filing:

Sorenson Filing to FCC re Assignment of Phone Numbers

From time to time, we add links to guest blogs.  This blog is written by an interpreter who expresses his opinion about the FCC’s presence at the recent RID Conference in Philadelphia.  You can read it by clicking on this link:

Guest Blog by Darryl Crouse re FCC at RID Conference

Going One Step Further
An Op-Ed Editorial from Dr. Z

In the FCC regulations governing VRS, it defines the following in 47 C.F.R. § 64.601 for interpreters as: “Qualified interpreter. An interpreter who is able to interpret effectively, accurately, and impartially, both receptively and expressively, using any necessary specialized vocabulary. “

Note it does not require the use of certified interpreters. Some VRS companies have insisted that their interpreters are certified, which is one or several steps above “qualified” interpreters. Some VRS companies use uncertified interpreters in VRS settings. As a deaf person, I insist on certified interpreters who have agreed to comply with the RID Code of Ethics, in addition to whatever code of ethics individual VRS companies have drawn up. There are protections for confidentiality in section 705 of the Communications Act, 47 U.S.C. 605 in which video interpreters (CAs) are prohibited from disclosing the content of any relayed conversation regardless of content.

When an interpreter is deemed “qualified”, the level of qualification is set by the individual VRS companies which are not the same from one company to another. Some VRS companies say, we have “high standards” for qualified interpreters. Some say they pay for the certification of their qualified interpreters. Is this good enough? Is this fair to us as deaf and hard of hearing citizens, entrusting our conversations to a system that is completely determined by the VRS companies?

It is time for the VRS companies to step forward and tell us if their interpreters are certified or not.

(more Editorials…)

Second Class Citizens?
An Op-Ed Editorial from Dr. Z

Why do phone calls from a non-VP-200 phone do not ring a VP-200 phone?

If you have an OJO, MVP or a Z series videophone, you sometimes need to call a friend using your non-VP-200 videophone, you kind of expect your friend to answer it, but instead, an interpreter comes on. What have you done wrong?

The answer is you have done no wrong. It is because Sorenson, the provider of the VP-200 phone for your friend has not given (or put up) your friend’s VP-200 phone number on the national data base. People ask why aren’t they doing it. We have not had an answer to this yet. It may be a good idea for you to ask Sorenson yourself to get an answer as to why your VP-200 does not get calls from your friend’s OJO, MVP or Z phones.

The number has to be on the national data base in order for the VP-200 to ring. If you have a VP-200 call another VP-200 it can ring. This again does not seem to be fair, or “functionally equivalent”. We are not being treated as equal citizens as compared to our hearing counterparts who can receive calls from any cell phone made by any manufacturer or service provider.

Are we deaf and hard of hearing people being treated as second-class citizens?

Let’s “Do the Right Thing
An Op-Ed Editorial from Dr. Z

With what has been occurring in the VRS industry of late—it is time for us to “do the right thing.”

There are many ways to do it right—and that includes stepping forward to tell the world one has a list of things we will stand by when we do our work. That is putting forward a code of ethics. ZVRS has stepped forward, put one on its website for all to see, an internal code of ethics which they have observed for some time. They did so voluntarily, and in addition, asked other VRS providers to do the same or adopt ZVRS’s code of ethics. This is the link  (link no longer working) to the code of ethics for ZVRS on their website.

The code of ethics lists things that need to be done right, such as:

– ensuring all relay calls be “functionally equivalent”, meaning handling calls the same way a hearing person makes a call

– ensuring the privacy of all calls, meaning the content and information of any calls are not shared with anyone else, except the caller and the person receiving the call

– billing the FCC (NECA) for each minute of interpreted phone call, not for the time the interpreter sets up and concludes the call, but between the time the other person picks up the phone and hangs up

– not making calls to generate more minutes–this is called manufactured minutes. Many examples are listed under “impermissible activities” under the code of ethics. ZVRS will only process calls made by people who want to make calls, not urging people to make unnecessary calls so that more minutes can be generated.

– in marketing the VRS service, ZVRS will make people aware of the benefits of using our service and explore the unique benefits and products of ZVRS, not to make more calls than necessary.

– implementing a whistle-blower policy so that any employee who sees things not being done right to feel free to come forward and bring this to the attention of management without having to worry about being punished or the like.

Also, all current ZVRS employees have signed on to the code of ethics since January, 2009 and all new employees will be required to do so.

All this is commendable and as a person who has been with the industry since its inception, I commend ZVRS for stepping forward with this. I hope other VRS providers will step forward doing the same thing—to show the world they will do their work ethically. Some providers have yet to come forward with their code of ethics.

There are more ways to do things right with VRS.

What about all VRS providers setting up more dialogue so that all phones can communicate with one another following internationally-set standards? Sorenson’s refusal to provide caller ID is an example according to recent FCC filings.

If people do not want to work together the way ZVRS wants to do so, what will it mean for the future of the VRS industry?

The answer is simple—step up and “do the right thing.” This is my challenge to all VRS providers.

Click to comment.

Note: Dr. Z (Philip Bravin) is a consultant with ZVRS. The above is an op-ed which reflects the independent opinion of Philip Bravin.

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