Dr. Z has been traveling the past few days and he has had an opportunity to talk with many people and reviewed many of the comments, vlogs and blogs on the FCC website and other websites.

Here are Dr. Z’s thoughts on this…

First and foremost–there is a process in place to determine VRS rates. This process has been there since the early 1990’s when it was established for TTY Relay Service and VRS was added in the early 2000’s. The process has remained about the same all those years. I am repeating the information from my other blog in case some of you did not read the other blog. The process in place is that all TRS and VRS companies submit their actual and projected costs to the FCC’s administrative contractor, NECA in February of every year. In April, the NECA Advisory Council meets and then makes a recommendation to the FCC in late April and early May. The FCC reviews the rates and makes a final determination around July 1st. This is not new–all TRS and VRS companies know about this process. There have been some changes to the process, exceptions made for VRS (3-year rates) for 2007-2009, but the basic process has been about the same and it has worked relatively well.

Having said this, what is so different this time? The FCC merely asked for comments on the proposed rates. The FCC has not made any decision yet and they will not until everyone has had their say. Some people and organizations have reacted in a way that does not fit the process. The way to react to the process is simple–go to the FCC with some information, statistics and data to say “the rate being proposed may need to be changed because the data we have may support such a change….” This is the way to do it and this respects and preserves the integrity of the process the FCC has in place. Two of the VRS companies, as of the date of this posting–ZVRS and one other provider have done just this–they submitted information to the FCC suggesting how the rates should be addressed. Declaring and threatening bankruptcy and the “end of VRS as we know it” does not solve the problem nor it is the way to address the process and question being put forth. Providing data to justify one’s position is the way to go and that preserves the integrity of the process.

Of course, everyone should feel free to comment, saying things like “if the rates are lower than they should be after the FCC has had an opportunity to analyze the NECA data, it could affect the quality of the current VRS service.” This makes more sense than saying “if you take VRS away, we won’t be able to communicate”–taking VRS away is not the FCC’s intent–they have a mandate provided by the ADA to provide functionally equivalent service to the deaf and hard of hearing community.

What disturbs Dr. Z most about many of the comments submitted—they were submitted by employees and interpreters of the dominant provider–this is not what the process calls for. It calls for an unbiased submission of comments so the FCC can fairly make its determination down the road.

Let us all work together to help the FCC make its determination so they can create a basis to provide a functionally equivalent service that deaf and hard of hearing consumers are privileged to use.

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.