trs advisory council presentation - rolkaloube€¦ · march 3, 2016 – fcc released report and...
TRANSCRIPT
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
TRS ADVISORY
COUNCIL
PRESENTATION
Karen Peltz Strauss
Eliot Greenwald
Consumer & Governmental Affairs Bureau
Roundtable
Communications needs for Deaf Persons with
Mobility Disabilities – March 17, 2016
Panels included:
Accessible Communications for Everyone (ACE)
platform
Ways to achieve functionally equivalent TRS for DPMD
Developing recommendations to address the
communications needs of DPMD
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
Disability Advisory Committee
N-1-1 Services Emergency Communications Subcommittee
TRS Access to Non-Emergency N-1-1 Services
On February 23, 2015, as proposed by the
subcommittee, the DAC: “Recommended, that the FCC
provide clarification of current TRS rules and remind
TRS providers of their obligation to handle N-1-1
calls and, if appropriate, institute an inquiry to find out
the extent to which people who use [TRS] are able to
contact their local or regional N-1-1 services.”
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
DAC - VRS
Relay/Equipment Distribution Subcommittee –
Proposed resolutions for the September 22, 2016
DAC meeting
VRS 911 call handling recommendations:
Disability Rights Office (DRO) and Consumer and
Governmental Affairs Bureau (CGB) work with Association of
Public Safety Communications (APCO) and National Emergency
Number Association (NENA) to develop an Implementation
Guide for Mandatory Minimum Training Standards for 911 call
handling for all VRS CAs
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
DAC – VRS (2)
Relay/Equipment Distribution Subcommittee –
Proposed resolutions for the September 22, 2016
DAC meeting
VRS 911 call handling recommendations:
DRO and CGB support development of Best Practices for
911 call handling and processing for VRS CAs
FCC take steps to ensure that annual 911 training is
required for all VRS CAs, including a refresher course for
veteran CAs
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
DAC – IP CTS
Relay/Equipment Distribution Subcommittee –
Proposed resolutions for the September 22, 2016
DAC meeting
Recommendations for IP CTS quality metrics:
Verbatim and accuracy standards
Speed standards
Delay standards
Testing to determine compliance take place at least
monthly
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
DAC – IP CTS (con’t)
Relay/Equipment Distribution Subcommittee –
Proposed resolutions for the September 22, 2016
DAC meeting
Recommendations for IP CTS quality metrics:
Clarify that the 10 minute time period required for CAs to stay
on a call does not begin until the CVA full understands the
person they will be captioning
FCC solicit information from consumers and providers regarding
how IP CTS may benefit from the introduction of HD voice,
RTT, and other technological improvements
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
NDBEDP
CVAA
Authorized $10 million annually from the Interstate TRS Fund
To support programs approved by the FCC
For the distribution of specialized customer premises equipment
Designed to make telecommunications services, advanced
communications services, and access to the Internet accessible by
individuals who are
Deaf-blind, as defined in the Helen Keller National Center
Act and
Low-income, which is defined for this program as 400% of
the Federal Poverty Guidelines
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
NDBEDP (2)
History
In 2011, the FCC established the National Deaf-Blind
Equipment Distribution Program as a pilot program,
which has come to be known as iCanConnect
The pilot program began on July 1, 2012
We are currently in Year 5 of the pilot program, which
runs through June 2017
On August 4, 2016, the FCC adopted rules to convert the
pilot program into a permanent program
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
NDBEDP (3)
How the Pilot Program operates The FCC selected and certified one entity in each of the 50
states, plus the District of Columbia, Puerto Rico, and the
U.S. Virgin Islands, to receive funding to distribute
equipment
The FCC allocates $50,000 to each of the 53 certified
programs, plus additional funding based on the size of each
state or territory’s population
States with larger populations are allocated larger amounts of
funding than states with smaller populations
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
NDBEDP (4)
How the Pilot Program operates (con’t) The FCC also set aside $500,000 per year for the Perkins School
for the Blind to coordinate nationwide outreach
Certified programs distribute specialized and off-the-shelf
equipment, separately or in combination, as long as it meets the
needs of the deaf-blind individual, and makes communications
services covered under the program accessible
Types of equipment the program has distributed: Computers, laptops, tablets, deaf-blind communicators, braille
devices, smartphones, amplified phones, alerting devices, and various
software applications
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
NDBEDP (5)
How the Pilot Program operates (con’t) Funding covers the reasonable costs of:
The equipment distributed, warranties, maintenance,
repairs, inventory for temporary replacements, and
refurbishing
State and local outreach efforts, individual assessments of
a deaf-blind person’s communications equipment needs,
equipment installation, and individualized training of
consumers on how to use the equipment
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
NDBEDP (6)
Highlights from the Permanent Program rules: what’s new: Extends the program to Guam, Northern Marianas, and
American Samoa
Adds administrative and financial management experience to
program certification criteria
Requires entities to disclose potential or actual conflicts of
interest in the certification application process and after
certification
Will certify programs for periods of five years
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
NDBEDP (7)
Permanent Program rules: what’s new (con’t) Requires an outgoing program to take certain steps to ensure
a smooth transition to the newly-certified program
Reduces funding for national outreach
Allows certified programs to be reimbursed for pre-approved
consumer travel costs for assessments and training conducted
at a program center location
Allows certified programs to use up to 2.5% of their annual
allocations on train-the-trainer activities to address a
persistent shortage of qualified trainers
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
NDBEDP (8)
Permanent Program rules: what’s new (con’t) Allows certified programs to be reimbursed for
administrative costs up to 15% of their annual allocations
Establishes program performance goals and directs CGB to
establish performance measures
Authorizes the development of a centralized database that
certified programs must use for reporting purposes and may
use to generate reimbursement claims
Requires submission of a copy of each certified program’s
annual audit to the FCC
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
NDBEDP (9)
Permanent Program rules: what’s new (con’t) Requires certified programs to retain records for five years
Requires CGB to assess program performance during the
fifth year of the permanent program, including the extent to
which funding should be continued for outreach, travel, and
train-the-trainer activities
Adds new consumer attestations for compliance with
Commission rules
Establishes procedures for filing informal complaints with
the FCC
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
TRS Fund Contribution Base
November 25, 2015 – IDT filed a petition for rulemaking
requesting the FCC to review and revise its rules and policies
on the contribution methodology for the Interstate TRS
Fund
Requests intrastate revenues to be included in the
contribution base
Requests elimination of rule requiring that VRS costs be
recovered from only interstate and international revenue
December 18, 2015 – Public Notice seeking comment
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
Numbering Directory Waiver
November 23, 2015 – Wireline Competition Bureau
granted waiver to permit
VTCSecure – contractor building VRS reference platform
MITRE – contractor performing TRS research for FCC
To access TRS Numbering Directory to extent necessary
to carry out tasks related to contractual responsibilities
Both operate under detailed contractual obligations to
protect non-public information consistent with security
and privacy concerns
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
Numbering Directory Waiver (2)
July 6, 2016 – VTCSecure filed petition for waiver
and declaratory ruling
To permit providers of direct ASL customer support
services to access TRS Numbering Directory
To clarify that VRS providers are required to support the
ability of VRS users to make and receive direct video,
voice and text calls to and from any number listed in the
TRS Numbering Directory, including direct customer
support numbers
July 18, 2016 – Public Notice seeking comment
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
Equal Access Waiver
August 24, 2016 – CGB granted 2-year temporary waivers to
Sprint and Hamilton of two requirements for traditional TRS,
STS, and CTS:
Providers must allow users to select their own long distance
telephone carrier
Providers must offer the same billing options (such as collect, calling
card, and third party billing) as traditionally offered by wireline
telephone companies
Conditioned on providers not charging for long distance
In 2014, FCC eliminated these requirements for iTRS
Intend to address issue on a permanent basis
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
TRS Rates
June 30, 2016 – CGB adopted rates for July 2016 –
June 2017 rate year
Interstate traditional TRS - $2.6245 per minute
Interstate STS - $3.7555 per minute
Interstate CTS and IP CTS - $1.9058 per minute
IP Relay - $1.30 per minute subject to possible true-up
VRS rates previously adopted by the Commission (to be
discussed in the VRS slides)
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
VRS
November 3, 2015 – FCC released a Further Notice of
Proposed Rulemaking (FNPRM) seeking comment on:
Rates
A proposal to modify in part the four-year compensation
rate plan for VRS adopted in 2013, by adopting a limited-
duration compensation rate freeze applicable to VRS
providers with 500,000 or fewer monthly minutes
Speed of Answer
A proposal to amend the speed-of answer rule to require
80% of all VRS calls to be answered within 45 seconds,
measured monthly
It is currently 80% of calls within 120 seconds
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
VRS (2)
November 3, 2015 FNPRM also seeking comment:
Speed of Answer
Alternatives to the current policy of withholding an
entire months compensation for missing the speed of
answer requirements:
A siding scale approach
An incentive approach with additional
compensation for a stricter speed of answer
A streamlined waiver process
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
VRS (3)
November 3, 2015 FNPRM also seeking comment:
Speed of Answer
Whether to modify how to calculate speed of answer in
terms of defining when a call is answered to conform to
other TRS rules, which are based on when the caller’s call
is placed, and not put in a queue or on hold
Deaf Interpreters
Whether to permit compensation for a deaf interpreter in
addition to a hearing interpreter for certain users
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
VRS (4)
November 3, 2015 FNPRM also seeking comment:
Skills-Based Routing
Provider proposal for a trial of skills-based routing
The merits of skills-based routing
How to define types of calls for skills-based routing
Additional costs from skills-based routing
How to structure a trial of skills-based routing
The length of the trial
The type of data that should be collected
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
VRS (5)
November 3, 2015 FNPRM also seeking comment:
At-Home Interpreting
Whether to permit interpreters to work at home at any
time
Safeguards needed for at-home interpreting
Assigning Ten Digit Numbers to Hearing People
Whether to assign ten digit numbers to hearing people for
the limited purpose of making direct (point-to-point) video
calls to and from other VRS users
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
VRS (6)
March 3, 2016 – FCC released Report and Order to
adjust VRS rates
Provides limited rate relief to providers with 500,000 or
fewer monthly minutes (smallest VRS providers)
$5.29 per minute from July 1, 2015 (applied retroactively)
through October 31, 2016
$5.06 per minute from November 1, 2016 through April
30, 2017
$4.82 per minute from May 1, 2017 through June 30, 2017
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
VRS (7)
March 3, 2016 VRS rate order
Maintains rates adopted in 2013 for other VRS
providers
Tiers I and II (first 1 million monthly minutes)
$5.06 per minute July 1, 2015 – December 31, 2015
$4.82 per minute January 1, 2016 – June 30, 2016
$4.44 per minute July 1, 2016 – December 31, 2016
$4.06 per minute January 1, 2017 – June 30, 2017
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
VRS (8)
March 3, 2016 VRS rate order
Maintains rates adopted in 2013 for other VRS
providers
Tier III (monthly minutes exceeding 1 million)
$4.06 per minute July 1, 2015 – December 31, 2015
$3.87 per minute January 1, 2016 – June 30, 2016
$3.68 per minute July 1, 2016 – December 31, 2016
$3.49 per minute January 1, 2017 – June 30, 2017
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
VRS (9)
August 4, 2016 – CGB released a FNPRM on VRS
interoperability standards
August 2015, the VRS Task Group of the SIP Forum published
the VRS Provider Interoperability Profile
July 2016, the Relay User Equipment (RUE) Forum published
the Interoperability Profile for Relay User Equipment
FNPRM seeks comment on tentative conclusion that these
standards meet the FCC’s objective of facilitating
interoperability and portability for VRS, and should be
incorporated by reference into the FCC’s rules
Comments due September 14, 2016
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
VRS (10)
VRS issues still pending from the FNPRM
accompanying the June 10, 2013 VRS reform order:
VRS rates beginning July 1, 2017
Whether to transfer responsibility for handling 911 calls to a
single VRS contractor
Whether to prohibit the use of non-competition clauses in
employment contracts
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
IP CTS
April 7, 2015 – CGB suspended InnoCaption’s
conditional certification because InnoCaption failed
to operate in compliance with FCC emergency call
handling requirements
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
IP CTS (2)
June 17, 2016 – CGB released on Order reinstating
InnoCaption’s conditional certification to provide IP CTS
Order waived certain elements of the emergency call
handling rule:
Send to the public safety answering point (PSAP)
The provider’s name and callback number
ID number for the CA handling the 911 call
Initiate the reconnection of a 911 call if one or both legs
are disconnected
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
IP CTS (3)
Background
In 2014, the U.S. Court of Appeals for the DC Circuit
invalidated two of the requirements adopted in the August
2013 IP CTS order
The FCC may not require consumers to pay $75 for IP CTS
equipment
It is permissible for consumers to have a choice of obtaining
third-party certification or paying $75 for equipment
The FCC may not require that IP CTS phones be set to default
with captions off
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
IP CTS (4)
Issues pending on remand from the court:
Users who have registered since the court decision went into
effect have not been required to obtain either a third-party
certification or pay $75 for equipment. Question pending is
whether to require third-party certification of new users as well as
users who have registered since the court decision went into effect
Since the court decision, IP CTS phones are required to have a
button, key or icon to easily turn captions on, but there is no
similar requirement to turn captions off. Question pending is
whether to require a button, key, or icon to turn captions off
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
IP CTS (5)
Issues pending from the FNPRM accompanying the
2013 IP CTS Reform Order:
Whether to restructure the rate methodology
Whether to prohibit the use of phones which require
captions to be turned on before certain volume
adjustments can be made
Whether to require a default of “captions on” for 911 calls
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
IP CTS (6)
Issues pending from the 2013 FNPRM:
Whether to migrate IP CTS to state TRS programs
Whether to centralize registration and verification of IP
CTS users in the TRS-URD
Whether to adopt mandatory minimum requirements for
speed and accuracy
Whether to require provider websites to have notifications
regarding prohibited use of IP CTS by hearing individuals
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
IP CTS (7)
Other pending IP CTS issues :
Updating 911 calling rules for web and wireless IP CTS
With traditional IP CTS, the 911 connection is provided by the
underlying telephone or VoIP provider
Rules governing web and wireless IP CTS were adopted in early 2008
before iTRS providers were part of the North American Numbering
Plan
Question is how to update the rules, now that there are easier and
better ways to connect users to 911
Whether to make permanent the alternatives to providing the last 4 digits
of SSNs for those who do not have SSNs
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
IP Relay
Pending IP Relay issues:
Enhanced registration, certification and verification
procedures to prevent ineligible users from using IP Relay,
thereby ensuring the availability of the service for legitimate
users
Per call validation procedures
Application of the centralized TRS-URD to IP Relay,
including security of information in the TRS-URD
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
IP Relay (2)
Pending IP Relay Issues:
Alternative ways to restructure IP Relay, such as
Selecting the provider or providers through a competitive
bidding process or
Making IP Relay a mandatory service and turning over
administration to the states, similar to what is now done for
traditional TRS and STS
Restructuring the ratemaking methodology
Determining the needs of deaf-blind users and how to
accommodate those needs
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
IP Relay (3)
Pending IP Relay Issues:
Permanent elimination of “guest user” procedure for calls to 911
June 2012 order prohibited guest users except for calls to 911
In 2014, to address “swatting,” rules were waived for 1 year to
permit providers to refuse to handle 911 calls by guest users
In June 2015, waiver extended until FCC addresses the issue on
a permanent basis
When to disconnect an idle call – what is the appropriate wait time
Whether to prohibit more than 2 simultaneous calls by the same
user
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
STS
Pending STS Issues:
Establishing a nationwide STS outreach program
Registration, certification, and verification requirements for
STS users
The inapplicability of certain TRS mandatory minimum
standards established for TTY use – typing and spelling,
ASCII and Baudot, call release, and VCO – to STS
The minimum wait time – 60 seconds – that should be
required before terminating an idle STS call
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
STS (2)
Pending STS Issues:
Minimum STS CA training standards
Requiring providers to allow STS users to create profiles
Video Assisted STS (VA STS), a form of STS where the user
and CA are connected by both audio and video
IP STS, a form of STS where the user is connected to the CA
over an IP connection rather than the PSTN
September 15, 2016
TRS Advisory Council
Annapolis, Maryland
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September 15, 2016
TRS Advisory Council
Annapolis, Maryland
Contact Information
Karen Peltz Strauss
Voice telephone: (202) 418-2388
Email: [email protected]
Eliot Greenwald
Voice telephone: (202) 418-2235
Email: [email protected]
DRO website: www.fcc.gov/cgb/dro
FCC videophone: (844) 432-2275
September 15, 2016
TRS Advisory Council
Annapolis, Maryland