Let IP Relay Providers Recoup Outreach Costs, FCC Asked

Industry and deaf and hard of hearing advocates asked the FCC to let IP relay providers recoup costs for outreach and marketing to users from the Telecom Relay Service Fund, in comments posted Tuesday in docket 03-123 (see 2108050038). The move to establish a new compensation methodology stemmed from a 2018 petition for rulemaking by T-Mobile, the sole remaining IP relay provider.

The FCC prohibited IP relay providers from recouping the cost of outreach and marketing in their annual cost submissions in 2013. Commenters backed reversing this decision; the FCC has repeatedly granted T-Mobile a waiver since then for costs associated with outreach to the deaf-blind community. It also granted T-Mobile several waivers for "other forms" of IP relay outreach.

Outreach "will continue to be necessary as the user community changes," said T-Mobile, asking to establish both forms of outreach as compensable: “Absent such outreach, there will be ongoing confusion in the potential user group about the availability of IP relay.” Allowing T-Mobile to include the cost of marketing and outreach in its annual cost submissions “may reach more individuals who have been relying on a spouse or others to make their calls,” said the Telecommunication Equipment Distribution Program Association (TEDPA).

IP relay is "primarily used by individuals that are DeafBlind" and unable to use video relay or IP captioned telephone services, said groups including the Telecommunications for the Deaf and Hard of Hearing, Association of Late-Deafened Adults and Conference of Educational Administrators of Schools and Programs for the Deaf. They backed allowing T-Mobile to recoup the cost of outreach and education.

Don't cut IP relay reimbursement rates any further, the advocacy groups said, saying a multiyear compensation period would “provide IP relay providers consistency and predictability.” Such a structure “reduces inefficiencies and cost overruns by providing rate certainty,” said USTelecom. The group backed additional research on "newer technologies for efficiencies" in all services covered by the TRS Fund.

Compensate IP relay providers “on a percentage like what many states may experience” and programs like iCanConnect, TEDPA said (see 1608050045): “It may best serve the FCC to compensate the provider at a reasonable set rate or … an estimated amount based on previous minutes to compensate for any new consumers.”