| Video Relay Service (VRS) enables persons who use | | | | with deaf callers and who voice to hearing callers over |
| American Sign Language (ASL) to communicate with | | | | standard telephone lines. |
| voice telephone users through video equipment, rather | | | | In late 2009, fraud among interpreter subcontractors |
| than through typed text (like the old TTY). | | | | for VRS service providers nearly destroyed Video |
| Videoconferencing equipment, videophone, or | | | | Relay Services for the deaf. The FBI arrested a |
| computer and webcam links the VRS user with an | | | | number of interpreters in 9 states who were inflating |
| interpreter/operator - called a "Communications | | | | VRS minutes and cheating the TRS fund out of |
| Assistant" (CA) - so that the deaf user and the CA | | | | millions of dollars. |
| can communicate with each other in sign language and | | | | 4. Least cost routing. |
| by voice to the hearing party. VRS has become an | | | | Instead of having calls routed to the default provider, I |
| enormously popular. | | | | would have all calls to 10 digit numbers registered to |
| Unfortunately, high rates (over $6 per minute) for VRS | | | | the deaf routed through a central switch. |
| interpreting led to massive fraud and arrests in 2009. | | | | Sign language interpreting agencies would then submit |
| Recent proposals to lower the rates significantly have | | | | bids to the FCC for providing CAs. Calls would be |
| generated protests from the largest VRS service | | | | routed to the agency with the lowest bid who had an |
| providers. | | | | interpreter available to take a call. |
| I want to emphasize that the following proposals are | | | | At this time, VRS service providers are compensated |
| my own personal opinion. I consult for a sign language | | | | per minute of interpreting. Proposals for new, lower |
| interpreting agency, but not for any VRS providers. | | | | rates have brought claims that the new rates will drive |
| Modest proposal for reforming Video Relay Services | | | | providers into bankruptcy. |
| (VRS): | | | | By having the service providers bid on what it costs |
| 1. Separate the telecommunications/technical | | | | them to handle VRS calls - at a rate and with a profit |
| bandwidth side of VRS from the sign language | | | | they can accept - the fight over rates disappears. |
| interpreters. | | | | 5. NAD/RID Certification for CAs. |
| As it stands now, for a VRS service provider to | | | | As it stands now, the FCC allows VRS providers to |
| become licensed by the FCC, they must combine a | | | | determine the qualifications of their interpreters. This |
| telco with a sign language interpreting agency. The | | | | allowed criminal agencies to hire unqualified interpreters |
| types of businesses have nothing in common and | | | | to process "run calls" and bilk the government. |
| should be licensed and paid separately. | | | | Everyone would be better served if each CA met |
| Major telcos (ATT, Sprint, Verizon) should be able to | | | | some minimal level of competence in ASL, and had |
| bid on providing the telecommunications portion of | | | | something to lose if they engaged in fraud. |
| VRS calls without worrying about hiring ASL | | | | The National Association for the Deaf (NAD) and the |
| interpreters. | | | | Registry of Interpreters for the Deaf (RID) have |
| 2. Have the FCC assign a 10 digit geographical phone | | | | certification programs in place. CA certification could |
| number to each deaf consumer - not providers. | | | | be easily added. |
| As it stands now, 10 digit numbers are assigned by the | | | | Each CA could be identified by a number. Complaints |
| default VRS service provider who originally signed up | | | | or fraud could then be tracked to the specific person |
| a deaf individual for VRS service. Unless the deaf | | | | responsible. Poor interpreters could be weeded out of |
| caller has the technical savvy to modify his equipment, | | | | the system |
| any calls he or she makes is handled by the default | | | | Pass legislation to allow the FCC watchdogs to |
| provider. | | | | monitor random calls, much like wiretapping regulations |
| By giving away free, simple videoconferencing | | | | for police. |
| equipment, SorensonVRS has captured about 70% of | | | | Privacy is a serious concern. Care would have to be |
| all VRS calls. Switching providers is possible but | | | | taken not to record legitimate conversations. Monitoring |
| cumbersome. | | | | could be limited to 30 or 60 seconds unless suspicious |
| Emergency calls - e911 - are now the responsibility of | | | | activity is present. |
| the individual VRS service providers. I would pass this | | | | However, fraud is hard to catch or prevent if calls |
| to a central authority or to the telco who wins the | | | | cannot be checked at random. |
| technical bid for VRS. | | | | Conclusion: |
| 10 digit numbers allowed fraudulent VRS calls to be | | | | Market forces via least cost routing provide a viable |
| routed to a particular agency. | | | | method to reduce the cost of VRS calls to the |
| 3. Let sign language interpreting agencies bid on | | | | government, maximize efficiency in the sign language |
| providing just ASL interpreters. | | | | agencies, and keep the rates at a level that allows |
| Communication Assistants (CAs) are the sign | | | | VRS service providers to survive. |
| language interpreters who use video to communicate | | | | |