The next few weeks at the FCC, there will be several decisions that will have an impact on the future of VRS.

These include:

1) certification of providers who have asked for waivers…some providers may not qualify for waivers and as a result may not provide VRS services

2) 866 numbers may or may not be allowed to be used for free…it is possible that the FCC may require people to pay for the cost of maintaining their toll free numbers

3) while the FCC has extended current rates for the “time being”, it is possible that the FCC may revise rates for the 2011-2012 year sometime in the next few months

There may be other rulings that will not include the above. Dr. Z will keep you posted on this.

Dr. Z cares about your communication access.

Disclaimer: Dr. Z is currently the Vice-President of Marketing at CSDVRS, LLC.

There are over 10 filings by various providers to the FCC regarding certification.

Since the FCC is tightening (making more strict) certification procedures for currently uncertified providers, both the uncertified providers and the certified providers who are providing “white-label” services for uncertified providers have filed letters expressing justification for waiving them temporarily in order for them to do VRS service.

The list of waivers being filed can be found at this link.

The FCC has until June 1st to act on those waivers. In the event those waivers are not acted upon or are denied, those uncertified providers will not be able to provide VRS services after June 1st.

The following providers are certified by the FCC as of this date (May 23, 2011): AT&T, CAC,
Hands On, Sorenson, Sprint, Healinc, GoAmerica, SNAP, and CSDVRS.

Anyone not on the above list are considered white-label and need to be waived by the FCC to continue to perform VRS services after June 1st.

Dr. Z  (and the FCC) cares about your communication access.

Disclosure: Dr. Z is a employee with CSDVRS, currently its Vice-President of Marketing.

The FCC has asked for comments on their proposal to keep the VRS rates the same until further notice for the 2011-2012 funding cycle. This does not mean the FCC will keep the rates for the entire year and they could change the rates in mid-year. Below are comments filed by VRS providers and consumer organizations in response to the FCC proposal on rates.

Snap:
http://fjallfoss.fcc.gov/ecfs/document/view?id=7021648855

Purple:
http://fjallfoss.fcc.gov/ecfs/document/view?id=7021648688

Sorenson:
http://fjallfoss.fcc.gov/ecfs/document/view?id=7021648789

CSDVRS:
http://fjallfoss.fcc.gov/ecfs/document/view?id=7021648785

Consumer Organizations:
http://fjallfoss.fcc.gov/ecfs/document/view?id=7021648685

Dr. Z  (and the FCC) cares about your communication access.

Disclosure: Dr. Z is a employee with CSDVRS, currently its Vice-President of Marketing.

On April 6th, the FCC issued an order to deal with waste and fraud they had uncovered in a series of investigations and arrests more than a year ago. In addition they issued a proposed rulemaking process to deal with certification of VRS providers.  This is only the beginning of what is expected to be a series of orders and proposed rules. Dr. Z commends the FCC for taking such steps to insure viability of the VRS program for years to come.  We need to be sure that VRS is here to stay–we all have become attached to the wonders of the service, along with new devkices and developments that have occurred of late and to come in the near future.

The order requires the following (partial quotes from FCC documents):

· Require that VRS providers submit a statement describing the location and staffing of their call centers twice a year, and a notification at least 30 days prior to any change in the location of such centers;

· Prohibit VRS CAs from relaying calls from their homes and prohibit VRS providers from tying minutes or calls processed by a CA to compensation provided;

· Prohibit compensation for VRS calls that originate from IP addresses that indicate the individual initiating the call is located outside of the United States, with the exception of callers who preregister with their default provider for a specified time and location of travel;

· Prohibit compensation for VRS calls for remote training when the service provider is involved in any way with such training (e.g., sponsors, promotes or hosts such training); · Prohibit VRS CAs from using visual privacy screen

· Require automated recordkeeping of TRS minutes submitted to the Fund;

· Require that VRS be offered to the public only in the name of the provider eligible for compensation from the Fund and, when sub-brands are used, that these identify such eligible provider;

· Prohibit revenue sharing agreements for CA or call center functions between entities eligible for compensation from the Fund and non-eligible entities;

· Prohibit compensation on a per-minute basis for marketing and outreach costs performed through a subcontractor where such services utilize VRS;

· Adopt whistleblower protection rules for current and former employees and contractors of TRS providers;

In addition, the FCC issued a Notice of Proposed Rulemaking to deal with the certification process.

To read the order and the proposed rules, click this link.

Dr. Z (and the FCC) cares about your communication access.

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