3-a
It looks like those VRS companies that overlooked the important part of Rate plan. I realize that it is really called double payment from FCC to TRS.
If you go in section III then part A-3. It states that the rate plan includes any business calls made using TRS already included the rate.
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A. VRS Calls Already Compensated Through the Rate Base
3. We emphasize that VRS calls made by or to a VRS provider’s employee, or the employee of
a provider’s subcontractor, are not eligible for compensation from the TRS Fund on a per-minute basis as
part of the provider’s calls submitted monthly to the Fund administrator for payment. Instead, the costs of
such calls are business expenses that can and should be included in the providers’ cost data submitted to
the Fund administrator for purposes of setting VRS compensation rates.6 The Relay Services Data
Request form, which is submitted to the Fund Administrator annually by each provider for purposes of
determining the compensation rate, expressly identifies such expenses (e.g., for telecommunications
expenses, operations support, human resources, and marketing and advertising) as business expenses.
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Now you see, the rate plan which I believe is currently $6.64 per minute already has portion that would pay for any of employees requiring Relay service to make calls or recieve calls to their center. Also has portions for several other costs like research and development, providing equipment, service, interpreters, etc. So, it is like FCC is already paying for these services, however those TRS who decided to bill *AGAIN* for the full rate is not acceptable and is considered as double billing. That is clearly abuse, and do you guys think FCC would just simply forget and sweep under the rug? I don't think so. Whats more FCC already gave all TRS warning long time ago, they should have read the regulations more carefully and consult their attorneys.
Please remember, I am dead Deaf and I am part of Deaf community and am customer just like you. This is just purely my personal view, and has nothing to do with my employment. I value TRS and it is MY lifeline and will always depend on them just like you.
DHB