Ten years ago, the FCC (Federal Communication Commission) approved video relay service as the first broadband form of relay. Deaf individuals were now able to communicate in their own language by “phone” with doctors, teachers, family and friends. This technology has made it possible for deaf individuals to call anyone, anytime and anywhere.  

As you may be aware, the FCC is now facing a crucial phase as it works to set a new rate to pay VRS providers. Under consideration are four rate plans several of which would cripple VRS as we know it today. These plans are based on cost of service and not incentive based. In addition, these plans are structured on a tier base which rewards smaller less efficient providers and “punishes” large providers who have worked hard to operate efficiently and use funds for a myriad of items that further develop our industry.  

As a result of this new rate structure that is being considered, Sorenson has filed comments to express their concern. As a manger for Sorenson VRS for four years and two years prior to that, a VI, I am strongly in support of Sorenson Communication’s filing in response to the NECA’s proposal for VRS funding beginning July 1, 2010. A multi year incentive based VRS rate is superior to cost of service methodology. By reinforcing providers’ incentives to innovate, enhance quality, attract customers, and lower costs, this incentive based approach will encourage providers to offer the best service to the greatest number of users in the most efficient manner. 

Sorenson VRS has worked very hard to advance the industry of VRS by not only using funds to be as efficient as possible, but to capitalize on that strength by locating, recruiting and training interpreters; and opening call centers in many communities throughout the country. This has resulted in increased service to the deaf and lowering hold times for our customers when making VRS calls. As noted in the filing, we have been able to reduce to speed of answer from over 44 seconds in Feb 2008 to under 10 seconds now. We were able to implement enhanced 911 service ahead of the FCCs deadline, began distributing local 10-digit phone numbers ahead of the FCC deadline, increased training to deaf consumers, rolled out VP 200, developed better call routing software and enhanced software to protect against waste, fraud, and abuse, conducted research and development including research to develop a third generation VP, built and opened a VRS Interpreting Institute that provides state of the art facilities and training for aspiring VRS interpreters, and improved the survivability of the Sorenson’s nationwide infrastructure by deploying redundant critical sites in multiple regions of the country so as to avoid service interruptions in case of a large scale disaster or emergency. 

Our company cannot function under the proposed rate cut outlined and is being seriously considered by the FCC. This severe cut only affects Sorenson as we are the only “large provider” that falls into the 500,000 plus minutes per month. The logic behind this is confusing. Why should a company be punished for being successful and efficient and others rewarded for being less efficient and less successful? As I close, let me suggest two scenarios that will inevitably arise should the FCC decide on the rate they are pondering:

• In the event that Sorenson  “closes their door” because they could not survive on the proposals suggested as possible options beginning July 2010, can other VRS providers absorb the quantity of calls Sorenson takes and still offer the average speed of answer regulated by the FCC? If not, they would not receive their pay for service and in effect be forced to close their doors as well.

• If other VRS providers could handle the call volume, inevitably they would see extreme growth and end up as a provider in Tier 3 (the same rate of pay that forced Sorenson into bankruptcy) resulting in a reduction in pay which in effect would cripple that VRS provider. As a side note, it is not hard to imagine that VRS providers would do what they could to not encourage surpassing the 500,000 minute mark per month (which is the level at which their rate would be reduced from over $6.00/min to less than $3.90/min). Is this the route we want to take?

I am proud to say I have worked for Sorenson Communications for the past 6 years. I am hopeful the FCC will take very seriously the decision they are faced with and not cripple this industry and stifle the amazing service we have been able to provide our customers. It is imperative to be mindful that our success has been largely based, with pride, on our customers who CHOOSE us to be their provider. This has allowed us to grow to be the number one VRS provider in the world. Yes, the deaf community has a CHOICE when it comes to providers and they have many times over chosen Sorenson to be that provider. I am hopeful we will remain strong and stable and continue to give customers the quality service they have come to depend upon.  

Should you be concerned as well, I invite you to contact the FCC and voice your concern as well. Any and all support is needed and appreciated. 

Step 1. Go to http://fjallfoss.fcc.gov/ecfs/upload/begin?procName=03-123&filedFrom=X

Step 2.  . Complete the form with your personal information (all fields with an asterisk are required).

Step 3. Enter your comments. (You can type them in Word first and then cut and paste the comment.)

Step 4. Select the “Continue” button.

Step 5.  You will be presented with a confirmation page to review your comment before submitting comment. Select the “Confirm” button and your comment will be submitted.   
 
 
 
 

Kathy Rapp

Sorenson VRS Des Moines Manager