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VRS Rate Structure

FCC Flooded with Comments Against Proposed VRS Rate Formula

The video relay service (VRS) rates suggested to the FCC for the 2010-2011 fund year were opposed in comments from the hearing-impaired community and VRS providers. Last month the commission issued a public notice seeking comment on the payment formula and fund size estimate for the Interstate Telecommunications Relay Services Fund. The formula was submitted by the National Exchange Carrier Association for July 1, 2010-June 30, 2011. The three-tiered rates are based on “the 2009 average actual historical cost data submitted to NECA by VRS providers,” the commission said. In the notice, the rates are $5.77 for up to 50,000 minutes under Tier I; $6.03 for monthly minutes between 50,0001 and 500,000 for Tier II; and under Tier III, $3.89 for monthly minutes over 500,000.

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CSDVRS, a video relay service provider, agrees with having a tiered weighted average rate methodology. But “components of this methodology as proposed by NECA are flawed and detrimental to the VRS industry and ultimately a bane to VRS consumers,” it said. “The drastic disparity of rates within the Tier levels from Tier II to Tier III would act as a growth deterrent to the Tier II provider, thus guaranteeing that the largest provider maintains its market dominance.” The proposal “will guarantee the eventual elimination of Tier I and Tier II providers, a degradation in VRS service levels and elimination of consumer choice, lack of innovation, and a reduction of functional equivalency,” the company said.

Speech Communications Assistance by Telephone worries the rates are too low “to allow providers to continue to provide high quality service and engage in continued outreach efforts,” it said. SCT “does not understand why NECA has proposed that VRS providers should be compensated at varying rates, while providers of all other forms of TRS are compensated at a single common rate.” Some VRS employees are worried that if the rates are adopted, providers will be discouraged from investing in their services for the deaf.