FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011 Page: 5,572
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arrangements because they say that such arrangements are vital to their businesses, allowing them to be
competitive and make the service of their high-quality interpreters available.'50
53. Convo recommends that one way of addressing problems with fraud would be to require
"white label" providers to either apply for provisional certification or leave the VRS market; in this way
Convo suggests that the Commission would have a vehicle to track these providers.'5' TDI supports
Convo's proposal for provisional certification as it would allow start-ups to provide service. TDI further
suggests that all providers be certified by the Commission prior to offering VRS, and that a provider
should become eligible for certification only after it has handled a minimum number of minutes, to be
determined by the Commission.152 Purple agrees that all entities wishing to offer VRS should have to
apply for certification.'"5 Finally, Sorenson proposes allowing subcontracting if the eligible provider
seeking compensation from the Fund actually provides the core components of the relay service, and that
such entity is "clearly identified...to the calling parties at the outset of the calls as the TRS provider for
those calls."'54
54. Discussion. As described above, the Commission's VRS eligibility requirements provide
several avenues for entities to become eligible to receive compensation from the Fund, including
interstate common carrier status, a contractual relationship with a state or interstate common carrier, and
certification by the Commission. These eligibility requirements and service mandates are intended to
ensure an adequate level of governmental oversight over relay providers, compliance with the
Commission's rules, and accountability in the operations of all VRS providers. Yet, virtually none of the
fifty or so ineligible carriers that are now providing VRS have been vetted through any of these
processes or are accountable for compliance with our rules, even though each has held itself out to the
public as providing VRS service.
55. The proliferation of ineligible VRS providers that are providing VRS has had substantial
adverse consequences. Most significantly, in addition to effectively rendering our eligibility process
meaningless, it has hampered the Commission's ability to exercise oversight over the provision of VRS
and to prevent fraud. Several of the indictments have involved alleged illicit activities by individuals
associated with or employed by ineligible providers.'"5 Because these ineligible providers circumvent
'50 BISVRS Comments at 4; PAHVRS Comments at 5.
151 Convo Comments at 17.
152 TDI Comments at 10, 12.
153 Purple Comments (Sept. 13, 2010) at 13.
154 Sorenson Comments (September 13, 2010) at 14-15.
'55 See, e.g., United States v. John T.C. Yeh et al. Criminal No. 09-856, D.N.J. (Nov. 18, 2009). ("On or about
September 20, 2006. defendant John Yeh signed an agreement with Company 1, in which Company I agreed to bill
NECA for Viable VRS services provided by Viable and that Viable would receive approximately 90% of the NECA
reimbursement. On or about September 20, 2006, Defendant John Yeh signed a Memorandum of Understanding
with a Las Vegas, Nevada based call center to provide VRS call center services for Viable and which provided that
the call center would receive 55% of all money billed by or through Viable to NECA for VRS calls processed by the
Las Vegas call center."); ("On or about September 15, 2007, defendants John Yeh and Joseph Yeh signed a contract
with a New York, New York based call center to provide VRS call center services for Viable in return for $2.25 per
VRS call minute processed by the call center. On or about February 29, 2008, defendant John Yeh signed a contract
with a Round Rock, Texas based call center to provide VRS call center services for Viable in return for $2.00 per
VRS call minute processed by the call center. On or about October 10, 2008, defendant Joseph Yeh signed a
contract with a Miami Lakes, Florida based call center to provide VRS call center services for Viable in return for
$2.00 per VRS call minute processed by the call center.")5572
Federal Communications Commission
FCC I1-54
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United States. Federal Communications Commission. FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011, book, April 2011; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc52169/m1/744/: accessed March 29, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.