IP Captioned Telephone Service Providers Seek More Data Before Setting New Rates

IP captioned telephone service providers urged the FCC to proceed with caution in setting new rates for the service, which is funded through the Telecom Relay Services Fund, in reply comments posted Tuesday in docket 03-123. Industry agreed additional data is needed and new rates should account for the full cost of providing the service.

"The risks associated with a rushed decision in this proceeding, devoid of necessary cost data, are simply too great" for IP CTS users, said Hamilton Relay. The current record "lacks critical cost data" that must be considered before a "rational IP CTS rate" can be established, it said. Hamilton backed InnoCaption's proposal for a three-year continuation of the existing rate in the interim, adding the commission should "adjust the current rate upward" until a new methodology is established.

There's a "clear correlation to the age of the IP CTS users and the technology they prefer," said ClearCaptions. InnoCaption noted the average age of its IP CTS user is 59 years old. ClearCaptions agreed the FCC lacks enough data to determine new rates, saying the record showed "unanimous" support for setting rates that "ensure that an already unsaturated IP CTS market does not continue to shrink because of provider exit or customer attrition." ClearCaptions also backed using operating margins that "consider all real costs and risk" for providing IP CTS with automatic speech recognition (ASR) and communication assistants.

The FCC should "place the needs of consumers first as it decides how to proceed with new rates for IP CTS," said CaptionCall. Develop "appropriate and meaningful metrics and standards" to ensure IP CTS is functionally equivalent, it said. CaptionCall agreed the FCC may not have sufficient data to determine average industry costs for ASR and "should do so cautiously" if it adopts an ASR-specific rate. It also agreed with ClearCaptions that all costs of providing IP CTS should be considered and "must reflect the anticipated costs of operations at appropriate wage levels." The FCC should set a compensation rate for communication assistants that's "well above that current federal contractor minimum wage," the provider said.

IP CTS costs should include the cost of software and provisioning customer premises equipment, Hamilton said, noting other providers agreed. "Until the commission agrees to recognize these legitimate costs as allowable costs that must be included in the rate base, the commission risks setting a rate that is too low and thus non-representative of the actual costs of providing the service," it said. Not including the cost of CPE "ultimately means that the commission either seeks to have IP CTS providers abandon providing such resources and support, or to charge hard-of-hearing consumers for these resources," CaptionCall said. CPE is "an absolute necessity for older seniors," said ClearCaptions, and "failure to account for the costs of providing this critical communication tool to seniors will effectively result in denying these seniors access to IP CTS."

Consumer advocacy group Hearing Loss Live raised concerns about the proceeding "unintentionally shift[ing] away from human-based captioning methods." The group asked the FCC to let providers "maintain their current technologies" and not differentiate ASR "based on technology and cost" compared with communication assistants.