Speech-to-Speech
A free national telephone relay service
for people with speech disabilities
We are asking STS users and their friends family as well as disability agencies to send us information for the FCC suggesting improvements to STS. To do so, send an email to Bob Segalman with the following information.
A. A paragraph of any length describing your association with STS.
B. Your contact information.
C. A list of the paragraph numbers from the following talking points which you would like sent to the FCC.
I will file for you at the FCC website and send you a receipt. If you are comfortable filing yourself, email me and I will send you the procedures.
Bob Segalman drsts@comcast.net
Talking Points: FCC’s STS and STS-IP Notice of Proposed Rulemaking
A. STS Issues |
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Some STS users have cognitive problems and cannot activate a 10 digit number. Other STS users have limited dexterity and difficulty dialing and they will also have access problems if the STS choice requires multiple keystrokes. With proper outreach procedures there could eventually be 500,000 STS users in the United States. They all deserve easy access to STS.
Forcing only STS users to ask for their particular service detracts from the functional equivalency of STS compared with TTY relay also offered through 711.
1. I agree with all FCC conclusions except the one stating that: “IP STS will be compensated at the same per-minute rate as STS”
2. It is Speech Communication Assistance by Telephone, Inc.’s position that the reimbursement rate for IP STS, if recognized as a service eligible for compensation from the Interstate TRS Fund, should be very large for several reasons.
3. First, for IP STS to be effective, the reimbursement rate must be high enough to give providers the incentive to identify and recruit users. Because the population is so small, the reimbursement rate will need to be extremely high, possibly higher than the VRS reimbursement rate. Another justification for the high reimbursement rate is that poverty is extremely common in the STS-user population because of the low employment rate of people with speech disabilities (PSDs). A large percentage of PSDs had brain injuries from conditions like Cerebral Palsy. Such conditions cause additional disabilities which drastically lessen the likelihood of employment.
4. Furthermore, rehabilitation statistics show that people with multiple disabilities are very hard to place in jobs. Therefore, consumers will likely not use IP STS unless the providers are reimbursed for supplying computers and all other necessary equipment. Many people with speech disability (PSDs) have dexterity problems which require expensive equipment for computer access such as “eye gaze” access software and hardware or equipment to provide PC access through alternative and augmentative communications (AAC) devices. Accordingly, the Commission should reimburse the provider for all necessary equipment.
1. States should be required to provide STS users as much information about STS as the public receives about general telephone service. How this is done is not issue, but one method is for states to increase their STS compensation rates for intrastate calls. Speech-to-Speech was established in effort to provide functionally equivalent telecommunications services to Americans with speech disabilities. We recommend that the FCC make the following changes to the National STS service in an effort to provide that functional equivalency
A. We are pleased that FCC is continuing its provision for Speech-to-Speech Outreach by establishing a $2. 7248 per minute rate for interstate STS. The providers are now receiving adequate financial incentive to identify and train the majority of potential STS users who do not know that STS exists. We urge that the FCC continue with that high rate an ongoing basis. This high rate meets the need regarding interstate calls. We understand from one major STS provider that that high rate alone can not significantly increase use significantly.
B. General telephone service for the public is administered by the FCC in a way that will give providers maximum economic incentive to recruit as many users as possible. STS users must receive similar encouragement to use the telephone. One solution is for both intrastate and interstate rates to be high enough to provide the necessary profit. The FCC is obligated to provide functional equivalency in respect to encouraging increased use of telephone service by STS users for all calls, not just interstate calls.
C. Such higher rates are also important because intensive consumer training is often needed. There is generally a lack of long-term use resulting from brief customer introductions to STS (such as in Texas) compared with greater success from a minimum of 3 visits (such as in Minnesota some years ago) . For this reason, we strongly recommend that STS outreach be funded to allow 3-10 home visits. Building such a cost into the STS reimbursement rate would not cause it to exceed the current VRS reimbursement rate. VRS users need such expenses for interpreter services, and STS users need the expense for training. As both operator services and consumer training (advertising) are provided the general public, the functional equivalency mandate is not met if VRS users receive necessary operator services but STS users do not receive necessary training. Even with 10 home visits, new STS users exposure time to STS would be far less than the average citizens lifetime exposure time to general telephone advertising. Therefore to provide such extensive training when necessary would fall under the functional equivalency mandate.
D. We know that many people with speech disabilities find assistive technology useful for communications because of the thriving industry producing augmentative and alternative communications devices, also called AAC devices or voice output computers. Thousands of Americans use AAC while STS users appear to number between 200 and 500. The reason for the difference appears to be profit. AAC manufacturers and sales organizations have lobbied to receive a reasonable profit from reimbursements through medical insurance. In my own case, a pro-bono lawyer, supported by donations from the AAC industry, fought for 2 years until my medical insurance provider agreed to pay for my $7,000.00 AAC device. Thus, those who gained financially from my obtaining an AAC device included : my physician (who prescribed it), the pro-bono lawyer, the speech language pathologist ( who taught me to use it), the device salesman and the device manufacturer.
On the contrary, nobody in a position to lobby for STS consumer training gains enough financially from STS to be motivated to lobby on its behalf. This must change!
2. The MARS rate alone is not adequate to generate the necessary STS outreach.
The MARS rate alone is insufficient given that providers have no financial incentive to do STS outreach. The MARS rate cannot fund both STS and the marketing necessary for functional equality as described above. For STS to reach a significant portion of the speech disability population, reimbursement must be sufficiently above cost to provide that necessary financial incentive.
3. The FCC asks comment on the effectiveness of specific outreach.
There is no known successful STS outreach method to reach consumers in large numbers. If STS providers have sufficient financial incentive, they will do the necessary research to find one. Some years ago, a program providing multiple home visits succeeded but was labor intensive. While for VRS, deaf consumers transferred telephone skills from previous relay experience, many new STS and IP STS users will not have used the telephone before. Hence, learning to use these services will be a significant lifestyle change and will require up to ten home visits to enable consumers to internalize the social and psychological lifestyle changes that are necessary to use IP STS. As PSDs often have social and psychological barriers to telecommunications, combined with rampant poverty among PSDs, it is extremely unlikely that many PSDs will use these services unless all equipment is provided along with 3-10 home visits to overcome social and psychological barriers. Qualified speech language pathologists (SLPs) should make these home visits. SLPs will spend much time identifying potential users, who are very hard to find. SLPs charges for such services must be built into the reimbursement rate.
3. The Commission seeks comment on a proposal to have a single, nationwide provider offer both interstate and intrastate STS and whether the Commission would have the authority to mandate such an approach to the provision of service.
STS and IP-STS can be administered nationwide in a manner similar to VRS. The Commission’s authority for nationwide providers of STS is similar to its authority to have national providers of VRS. A national service would be very reasonable given the small number of potential users. When this small number (perhaps 500,000 to 1,000,000 for STS and IPSTS combined) is divided among the states, some states have less than 500 potential users.
Congress designed TRS as a state administered service based on the size of the various populations who might use TRS and the advocacy ability of those populations. The speech disabled population is extremely small and very limited in its advocacy, as a large proportion of us have multiple disabilities (such as ALS and severe CP) which prevent self-advocacy. A reasonable interpretation of Congress’s intent is that it would not expect such a small and limited population to provide the State level advocacy required of the current TRS structure as it applies to STS. A compassionate interpretation of Section 225 would allow a nationwide administration of STS. It is cruel to require continued administration of STS in a manner which prevents 95% of potential users from learning to use the service and puts an unnecessary burden on many states.
Adding additional temporary sums to a basic national rate, as the FCC is doing for the STS interstate rate now can provide some incentive. That is, doing away with the low intrastate rates over which the FCC has no control would allow providers to make a reasonable profit from STS (as they cannot do now). That would provide the necessary incentive to educate large numbers of potential users. As the FCC allows VRS to be provided nationally, it would be discriminatory and a violation of the functional equivalency not to allow STS to be provided nationally. Since our last filing, SCT was informed that the FCC lacks rate setting authority to require states to raise their very low current intrastate STS rates. Unfortunately, those low rates deny providers the financial incentive to do outreach projects with large numbers of these consumers. The spirit of Section 225 demands that the overwhelming majority of STS consumers receive training to use STS. Making STS a national service under the FCC, as VRS is, would give the FCC rate setting ability over all STS calls. It is for these reasons that SCT strongly urges the FCC to put STS under national control rather than under state control.
Alternatively, if it is not feasible to put STS under national control, the FCC could resolve this issue by supplementing intrastate STS rates to provide the financial incentive required.
4. STS and IP STS should each have multiple national providers
After further discussion with providers we have determined that there should be multiple providers under a nationwide system similar to that provided for VRS. This is a departure from our initial recommendation and is based on the fact that competition improves quality of service. The marketplace would determine the number of providers. The reimbursement level would be high enough above cost to ensure participation by multiple providers.
Each provider will serve the whole country from one call center with dedicated STS CAs. Because these CAs only do STS calls they will develop sufficient expertise to provide excellent service.
5. STS and IP-STS CA compensation must be adequate.
CAs will be paid enough to establish a career path just as video relay interpreters are. If video relay users have the right to receive service from interpreters who have the motivation to provide good service (because of adequate compensation and a career path), than STS users have the same right.
Supervisors and CAs should receive regular training from qualified speech language pathologists (SLPs), so that they will have a thorough understanding of the physiology of STS users. Such trainers would have the ethical responsibility (because of the SLP code of ethics) to ensure a much higher quality of service than currently exists. This high quality of the CAs would help stop users from abandoning STS because of low quality CAs. Such ethical responsibility cannot be undertaken by the providers as it may conflict with obtaining maximum profit and demanded by the providers’ stockholders. Using trainers bound by the SLP code of ethics ensures that this ethical responsibility will be met.
6. STS and IP-STS
STS would be a national service guided by the STS Advisory Council. VRS is administered nationally and STS should be too. No state has sufficient call volume to justify a state run STS service. It is inefficient to have state run STS services. Economy of scale is the primary reason to make STS a national service.
IIt is inefficient to have state run STS services, and there are not enough state level STS consumer advocates to monitor state administered STS programs to ensure that STS consumer rights are adequately protected. If STS is to be functionally equivalent from the prospective of consumer advocacy, it must be a national service. Only on the national level are there sufficient consumers advocates to ensure such functional equivalency.
Costs for intrastate STS calls and a pro-rated share of outreach costs will be reimbursed by the states to the FCC through NECA.
IIP-STSs users should be accorded access to the new ten digit numbering and emergency call services available to other IP users.
7. Sufficient STS and STS-IP outreach is required.
Efforts are in progress to validate effective STS outreach strategies. Once that is done, we can assume that providers will chose the most effective strategies as that will maximize call volume and profits. The STS Advisory Council will work to insure that each potential user of STS nationwide will be identified and given as much information about STS as the public has about general telephone service. The STS Advisory Council will develop national short and long range plans that will increase consumer awareness and education.
These plans will identify each potential user of STS and give them as much information about STS as the public has about general telephone service. Such a program will make STS functionally equivalent from a marketing perspective.
8. Abuse of must be controlled.
The FCC will stop abuse of STS by people without speech disabilities. Such abuse is wide spread now and interferes with the functionally equivalent administration of STS
Bob
Bob Segalman, Ph.D., Sc.D. (Hon.), Founder of Speech-to-Speech
President, Speech Communications Assistance by Telephone, Inc.
515 P Street, #403; Sacramento, CA 95814
Call 1-888-877-5302 and then ask for me at 916-448-5517
E-mail: drsts@comcast.net
Website: http://www.speechtospeech.org
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