Dr. Z and You

Dr. Z is still seeing people use 866 numbers and giving them to their friends, relatives and doctors.

Dr. Z wants to remind everyone that FREE 800/866 numbers for VRS will stop on November 21, 2012. All VRS providers have been asked by the FCC to stop servicing 800/866 numbers on that date.

If you want to keep your 800/866 numbers, you will have to pay a monthly fee.

What should you do? Just give out your local number, instead of your 800/866 number. Local numbers are free.

In the next few weeks, ZVRS will make a list available of who you need to contact to service your 800/866 numbers for a monthly fee.

Here’s the link to the FCC web page on this subject.

Dr. Z cares about your communication access.

Disclaimer: Dr. Z is currently the Vice-President of Business Development and Outreach at CSDVRS, LLC.

Another proposed rule has to do with tiered rates. The FCC is asking whether tiered rates make sense. We all know that fixed costs are the same for all VRS companies which means that it costs more for smaller VRS companies to provide the service than its for larger VRS companies. That is why tiered rates allow small companies to compete on an even playing field with larger VRS companies.

What is a tiered rate? If for example a per user rate or per minutes ate would be in effect, the smaller VRS companies would get a higher rate than the larger VRS companies. This enables smaller VRS companies to provide the service. If there were one rate, it’s possible that the smaller VRS companies will drop out of the market.

Dr. Z is of the opinion that we need a number of VRS companies out there so there can be competition. If companies drop out, we will have less competition and therefore less service and features.

Here’s the link to the proposed rules.

Here’s the link to comment to the FCC on those proposed rules.

Dr. Z cares about your communication access.

Disclaimer: Dr. Z is currently the Vice-President of Business Development and Outreach at CSDVRS, LLC.

One of the proposed rules has to do with compensation–how the FCC will pay the VRS providers for doing the service. Currently, the FCC pays the providers a per-minute rate for doing the service; the longer a person uses VRS, the more the provider gets.

In the proposed rules, the FCC is proposing that the providers would be paid on a per-user basis. This means the FCC is proposing to pay a flat fee for a person using the service per month. If a person uses VRS for 5 minutes a month, or 200 minutes a month, the provider will get the same amount no matter how many minutes the user uses. Will this cause behavioral changes on the part of the provider? Will the provider worry about the small users and ignore the big users? How do we define an ‘User”? What if a husband and a wife uses the same videophone in the home? Do they count as 1 or 2 users? What about a company that employs deaf and hard of hearing people? Will the company be defined as one user or each employee defined as an user? What about a deaf child in a hearing household? The list of questions goes on and on.

Dr. Z is especially concerned as to whether they have an impact on the quality of service. If the per user compensation methodology results in less revenue for the VRS provider, will it cause them to be less innovative? Will they eliminate features we have come to benefit?

Here’s the link to the proposed rules.

Here’s the link to comment to the FCC on those proposed rules.

Dr. Z cares about your communication access.

Disclaimer: Dr. Z is currently the Vice-President of Business Development and Outreach at CSDVRS, LLC.

Dr. Z has been getting questions on the recent FCC development, especially the FNPRM.

What is a FNPRM? It is a Further Notice of Proposed Rulemaking.

The FCC has a process whereby they give the public an opportunity to read their proposed rules and comment on them before they issue an order. Very rarely, if ever does the FCC issue an order without a proposed rulemaking in process except in urgent and emergency situations.

The current FNPRM issued on December 14, 2011 is a very detailed (over 100 pages) and comprehensive proposal of new rules to be considered. Some of them are far-reaching and can change VRS as we know it today. And the comment period is 30 days from its publication in the Federal Register which is an unusually short period of time for such a big rulemaking proposal.

Dr. Z will comment on those proposed rules in the next few weeks so you can have an opportunity to send your thoughts to the FCC.

Here’s the link to the proposed rules.

Dr. Z cares about your communication access.

Disclaimer: Dr. Z is currently the Vice-President of Business Development and Outreach at CSDVRS, LLC.

There is a lot of filings and comments on the FCC website related to VRS. It is painstaking to try to read and digest all of these. All this is a result of the FCC’s attempts to reform the VRS industry and this is only the beginning. Whenever the FCC issues an order, people file requests for reconsideration, requests for extensions, requests for waivers, ex parte notices and all that to get what they think is needed.

The dust is all over and it is far from settled. This is not intended as a criticism to the FCC–reform is needed, but it is hard when there are so many players in the game. The FCC has yet to issue proposed rules for compensation of VRS service. The FCC has a full plate because it is also looking at Universal Service Fund reform and internet reform, both of which have an effect on VRS.

Bottom line–we must be vigilant to be sure that all those new rules and orders do not change the VRS experience we enjoy today.

Here are the links to the FCC website for the information mentioned above:

TRS/VRS Headlines
Filings for Proceeding 03-123
Filings for Proceeding 10-51

Dr. Z cares about your communication access.

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

There has been a lot of filings on the FCC website related to VRS. A lot of white-label providers are filing applications for certification.

Why?

The FCC has decided that in order to provide VRS services, a provider must be certified. It is not good enough to be a subcontractor to a certified VRS company. Many of these subcontractors or affiliates are called “white-label” providers. The “white-label” providers are not certified so after October 1st or thereabouts, they will not be allowed to provide VRS services unless they are certified or waived by the FCC temporarily to provide VRS services.

A certified provider must employ (and not contract) with interpreters and they must own, or lease the platform they use to provide VRS services. There are other requirements for certification.

So, by October 1st or around that time, you may or may not be able to access some of your VRS providers. Dr. Z wants you to be aware that it is a possibility.

If that happens, you will need to call a certified VRS provider such as ZVRS to make a call. ZVRS is not the only certified provider–there are others out there.

Dr. Z cares about your communication access.

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

The FCC has issued an order on 800/866 numbers. The FCC has directed that if anyone wants a 800/866 number for their videophone, they will have to pay for it on a monthly basis.

This means those of you who have 800/866 number as your primary number, if you do not want to pay for it, you must use your local number to receive calls. In about a year’s time, if you do not change to a local number and do not pay for your 866 number, you will not be able to receive calls on your videophone.

The FCC (and Dr. Z) in the past has indicated that something like this would be forthcoming and it has happened.

What should you do?

If you already make and receive calls using your local number (not 800/866), you do not have to do anything.

If you use your 800/866 number for others to call you, you must within a year give your friends, relatives and others like your doctor, your local number so they can reach you.

Why is the FCC doing this? They want to be sure that deaf and hard of hearing people receive functionally equivalent communication service, just like hearing people. In this case, hearing people have to pay for their use of 800/866 numbers, so the FCC is saying that deaf and hard of hearing people then have to pay for their use of 800/866 numbers. The copy of the order can be found at this link.

Please take the time to change your 800/866 numbers to local numbers. ZVRS customer service can help you if you wish, by sending an email to h...@zvrs.com (click the … to avoid mail spam) or calling ZVRS on VP# 866-932-7891. 

Dr. Z cares about your communication access.

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

The FCC has issued an order (link to order) on certification of VRS providers. This order has raised some eyebrows and the FCC indicates it is doing this to reduce the incidence of abuse and fraud as much as possible.

For those providers who have been previously certified by the FCC will need to be re-certified again at the end of their certification authorization.

The FCC will no longer recognize those providers who have been certified as “common carriers” by the FCC or through their states. They will need to be re-certified by the FCC as a VRS provider.

In order to be certified or re-certified as a VRS provider, the provider MUST employ all interpreters who work as video interpreters. The FCC will not allow any contracted interpreters or use of interpreter agencies as subcontractors. All interpreters must be employees.

In addition, the all centers that interpreters work out must have a legitimate lease or ownership which must be verified by the FCC at their request. Also, anyone who owns more than 10% of a video relay provider must document proof of such ownership and all video relay providers must provide to the FCC a list of all executives and significant employees. All of this is subject to verification by the FCC.

All current uncertified VRS providers must apply for certification by the FCC provided they meet the above requirements in order to provide VRS service. Those providers cannot contract out any resources–they must own or license any resources needed for operating a VRS service.

There’s a lot more in the fine print of the order. The order will take effect 30 days after publication in the Federal Register which usually means 45-60 days from last Friday, when the order was issued.

Dr. Z cares about your communication access.

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

Google +

Facebook with Skype Video

Upcoming Announcements from Apple (iPhone 5)

Amazon Tablet

After the summer is over, we are bound to see how the sand is shifting in the VRS industry–not only with the new developments above–but with the providers rolling out new and exciting stuff…ZVRS, included!

Stay tuned.

Dr. Z cares about your communication access.

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