FCC Filing: FCC’s Public Notice on Convo’s Petition

TELECOMMUNICATIONS

CG 03-123 — Telecommunication Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities
CG 10-51 — Structure and Practices of the Video Relay Service Program

COMMENTS

TDI, along with the tagged consumer groups filed comments to the Federal Communications Commission, about Convo’s petition proposing changes to certain Video Relay Service (“VRS”) service rules.  

[see below, under Tags: for a full list of signatories]

Convo requested the revision two discrete waivers made during the peak of the COVID-19 pandemic due to the shortage of VRS Communication Assistants (CAs). Convo requested the Commission to permanently raise the limit of relay call minutes that can be routed to remote workstations (at-home CAs) to 80 percent, and to permanently allow independent contractors to relay up to 30 percent of a VRS provider’s call minutes per month. Lastly, Convo asked the FCC to extend the Commission waivers granted in 2020 allowing CA’s to work remotely and independent contractors to relay calls with revised rules mentioned above. 

TDI has no issue with the first request to relax the monthly minute limit a VRS provider made through remote CA’s only with the implementation of safeguards. However, we opposed the second request due to the previous experiences of problematic issues of fraud and wasteful activities with independent contractors. We noticed that the petition does not offer any solutions to address future situations that may arise concerning the independent contractors. 

We had no objections to the waiver extensions allowing VRS providers to offload more traffic through remote workstations and allow subcontractors to relay VRS calls in the near term given the ongoing COVID-19 pandemic and the challenges of safely staffing call centers. But we urged the Commission to immediately restore the obligation that VRS providers answer most calls within 120 seconds. 

  1. Additional oversight and performance obligations must accompany any Commission relaxation of limits on monthly minute volume relayed through remote workstations
  2. The Commission should not relax the current prohibition on independent contractors relaying VRS calls
  3. The Commission should extend waivers regarding remote workstations and subcontractors expiring in August 2021, but restore VRS call answer time obligations effective immediately

We look forward to continuing our work with the Commission to improve the integrity and performance of next-generation VRS services. 

URL below is linked to the actual filing document on FCC’s Electronic Comment Filing System 

https://ecfsapi.fcc.gov/file/10719283281816/TDI%20et%20al.%20Comments%20on%20Convo%20Petition.pdf