Video Relay Service (VRS) enables persons who use American Sign Language (ASL) to communicate with voice telephone users through video equipment, rather than through typed text (like the old TTY). Videoconferencing equipment, videophone, or computer and webcam links the VRS user with an interpreter/operator – called a “Communications Assistant” (CA) – so that the deaf user and the CA can communicate with each other in sign language and by voice to the hearing party. VRS has become an enormously popular.

Unfortunately, high rates (over $6 per minute) for VRS interpreting led to massive fraud and arrests in 2009.

Recent proposals to lower the rates significantly have generated protests from the largest VRS service providers.

Modest proposal for reforming Video Relay Services (VRS):

1. Separate the telecommunications/technical/bandwidth side of VRS from the sign language interpreters.

As it stands now, for a VRS service provider to become licensed by the FCC, they must combine a telco with a sign language interpreting agency. The types of businesses have nothing in common and should be licensed and paid separately.

Major telcos (ATT, Sprint, Verizon) should be able to bid on providing the telecommunications portion of VRS calls without worrying about hiring ASL interpreters.

2. Have the FCC assign a 10 digit geographical phone number to each deaf consumer – not providers.

As it stands now, 10 digit numbers are assigned by the default VRS service provider who originally signed up a deaf individual for VRS service. Unless the deaf caller has the technical savvy to modify his equipment, any calls he or she makes is handled by the default provider.

By giving away free, simple videoconferencing equipment, SorensonVRS has captured about 70% of all VRS calls. Switching providers is possible but cumbersome.

Emergency calls – e911 – are now the responsibility of the individual VRS service providers. I would pass this to a central authority or to the telco who wins the technical bid for VRS.

10 digit numbers allowed fraudulent VRS calls to be routed to a particular agency.

3. Let sign language interpreting agencies bid on providing just ASL interpreters.

Communication Assistants (CAs) are the sign language interpreters who use video to communicate with deaf callers and who voice to hearing callers over standard telephone lines.

In late 2009, fraud among interpreter subcontractors for VRS service providers nearly destroyed Video Relay Services for the deaf. The FBI arrested a number of interpreters in 9 states who were inflating VRS minutes and cheating the TRS fund out of millions of dollars.

4. Least cost routing.

Instead of having calls routed to the default provider, I would have all calls to 10 digit numbers registered to the deaf routed through a central switch.

Sign language interpreting agencies would then submit bids to the FCC for providing CAs. Calls would be routed to the agency with the lowest bid who had an interpreter available to take a call.

At this time, VRS service providers are compensated per minute of interpreting. Proposals for new, lower rates have brought claims that the new rates will drive providers into bankruptcy.

By having the service providers bid on what it costs them to handle VRS calls – at a rate and with a profit they can accept – the fight over rates disappears.

5. NAD/RID Certification for CAs.

As it stands now, the FCC allows VRS providers to determine the qualifications of their interpreters. This allowed criminal agencies to hire unqualified interpreters to process “run calls” and bilk the government.

Everyone would be better served if each CA met some minimal level of competence in ASL, and had something to lose if they engaged in fraud.

The National Association for the Deaf (NAD) and the Registry of Interpreters for the Deaf (RID) have certification programs in place. CA certification could be easily added.

Each CA could be identified by a number. Complaints or fraud could then be tracked to the specific person responsible. Poor interpreters could be weeded out of the system

Pass legislation to allow the FCC watchdogs to monitor random calls, much like wiretapping regulations for police.

Privacy is a serious concern. Care would have to be taken not to record legitimate conversations. Monitoring could be limited to 30 or 60 seconds unless suspicious activity is present.

However, fraud is hard to catch or prevent if calls cannot be checked at random.

Conclusion:

Market forces via least cost routing provide a viable method to reduce the cost of VRS calls to the government, maximize efficiency in the sign language agencies, and keep the rates at a level that allows VRS service providers to survive.

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I want to emphasize that these proposals are my own personal opinion. I consult for a sign language interpreting agency, but not for any VRS providers.

Charles Lamm is a retired attorney now serving as a legal/technical consultant for Accessible Communication for the Deaf (ACD) in Sunrise, Florida – http://acdterps.com