Before the Federal Communications Commission

**Washington, D.C. 20554**

**In the Matter of: )**

**)**

**Telecommunications Relay Services ) CC Docket No. 98-67**

**and Speech-to-Speech Services )**

**for Individuals with Hearing and )**

**Speech Disabilities )**

**\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
)**

**VISTA INFORMATION TECHNOLOGIES, INC.**

**PETITION FOR RECONSIDERATION**

# OF FCC REPORT AND ORDER NO. FCC 00-56

**VISTA Information Technologies, Inc.**

**489 Whitney Avenue**

**Suite 100**

**Holyoke, MA 01040**

**Thomas O'Neill**

**Vice President**

**Call Center Services**

**Rita Beier**

**Director, Outreach and Quality Assurance**

**Call Center Services**

Before the Federal Communications Commission

**Washington, D.C. 20554**

**In the Matter of: )**

**)**

**Telecommunications Relay Services ) CC Docket No. 98-67**

**and Speech-to-Speech Services )**

**for Individuals with Hearing and )**

**Speech Disabilities )**

**\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_)**

**VISTA INFORMATION TECHNOLOGIES, INC.**

**PETITION FOR RECONSIDERATION**

# OF FCC REPORT AND ORDER NO. FCC 00-56

## SUMMARY

On March 6, 2000 The Federal Communications Commission (FCC) issued its
Report and Order (Docket No. 98-67, FCC 00-56) governing provision of
Telecommunications Relay Service. Among the changes the Order makes are
revisions to the mandatory minimum standards for Communications
Assistants. The Order raises the minimum typing speed for Communications
Assistants to 60 words per minute (WPM).

VISTA Information Technologies, Inc. (VISTA) as provider of the
Massachusetts Telecommunications Relay (MassRelay) respectfully requests
that the Federal Communications Commission reconsider the effective date
for the minimum typing speed standard for Communications Assistants
(CAs) of 60 words per minute at hire date. While VISTA fully supports
the Commission's improvement of standards for TRS, the 60-wpm-at-hire
typing requirement would severely hamper the ability for Providers to
hire candidates and would eliminate some excellent potential CAs without
the opportunity to develop their skills.

VISTA has been the Provider of the Massachusetts Telecommunications
Relay Service (MassRelay) since May 1, 1999. The typing standard for
Relay Operators (they are not referred to as CAs in Massachusetts) in
Massachusetts has exceeded the minimum set by the FCC up to this date
and, in fact, exceeds the new standard. MassRelay Operators are required
to type 65-wpm with 90% accuracy on an individually tested basis, not a
group average.

VISTA provides a 90-day training period for Operators to develop their
typing skills in order to attain the 65-wpm goal. The Massachusetts
Relay contract requires that new hires test at 55 wpm on both audio and
visual typing tests. Following their 90-day training period, those
Operators must pass audio and visual tests at 65-wpm. VISTA's experience
indicates that the lower hiring requirement, combined with the 90-day
training period are necessary in order to identify, hire and train
sufficiently qualified persons to provide Relay service. VISTA requests
that the Commission please review the MassRelay typing speed program as
described in this document.

While the MassRelay program has proven to be reasonable and effective,
it also has allowed recruitment efforts to remain fruitful, although
challenging, in today's tight employment market. We believe that any
standard above 55-wpm would severely limit the potential hiring pool
beyond what the market could support. Additionally, requiring immediate
60-wpm performance eliminates the Relay Providers opportunity to develop
Operators with excellent potential that only require some additional
typing instruction.

VISTA therefore, requests that the FCC reconsider the 60-wpm-at-hire
requirement and instead allow for a 90-day training period of a lower
typing speed. Then, upon being tested at 90 days, the CA/OPR would be
required to demonstrate the 60-wpm minimum speed.

TABLE OF CONTENTS

Current standards and practices at MassRelay Page 4

VISTA experience in hiring/meeting standards Page 4

Raising minimum impedes hiring and increases costs Page 5

Proposal for FCC consideration Page 6

Conclusion Page 6

I. CURRENT PRACTICES AND STANDARDS AT MASSRELAY

The current Massachusetts Relay contract is based on an RFP that was
carefully crafted to exceed national standards for Relay provision.
Relay Operators for MassRelay are required to type 65 wpm with 90 %
accuracy. New hires must pass an audio and a visual test at 55 wpm. Then
upon completion of their 90-day training period, each Operator must pass
audio and visual tests at 65-wpm minimum.

The current working and education environment seldom teaches audio or
transcription typing to the average student. Unless someone goes into a
specific field, medical transcription or CART reporting for example,
they do not acquire the ability to type what they hear with significant
speed or accuracy. In addition, the current economic climate is
characterized by extremely low unemployment among persons with the
skills required to work at MassRelay. VISTA has implemented strategies
in order to overcome these difficulties and identify and develop
potential candidates as Relay Operators.

For persons unable to demonstrate an ability to reach the incoming
55-wpm standard, VISTA has developed a cooperative training program with
a Job Assistance local agency. Good potential candidates (who can type
at the 43 -- 45 wpm level) are offered free transcription typing
instruction, *prior to being hired by VISTA*, at this agency.

The applicant can then choose to participate in these classes and return
to the Relay Center to be re-tested once their typing speed reaches the
55-wpm hiring minimum.

For those applicants who successfully demonstrate 55 wpm skills, VISTA
provides intensive, focused typing training and practice during the
initial four-week Operator training session in order to enable trainees
to reach 65 wpm ultimate goal. Daily instructional and practice sessions
are provided to improve both overall typing skills as well as specific
transcription-type skills. Once the trainee "graduates" from their
initial training class, they begin handling live relay calls. They are
provided, as part of their regularly scheduled shift, additional typing
training and practice time depending on their individual skill levels
and needs. VISTA has discovered that merely handling Relay calls for the
additional 60 days of training combined with applying those techniques
acquired in the initial training frequently enables the employee to
successfully pass their 90-day tests. However, this additional two-month
period, beyond the initial 4-week class, is necessary to develop the
speed and accuracy needed to reach the goal.

II\. VISTA EXPERIENCE IN HIRING/MEETING STANDARDS

Utilizing the above strategies, VISTA has been able to develop trainees
successfully but not without difficulty. Only approximately 10% of the
people who initially apply for positions as MassRelay Operators pass the
incoming testing (which also includes 2^nd^-year college level Grammar
and Spelling tests\...again above the national standard).

The tight employment market, and low success rate upon initial contact
require the recruiting department to work tirelessly to attract enough
candidates to fill our needs. While all providers face a similar problem
hiring CA-level skilled persons, raising the entry-level minimum would
substantially tighten the candidate pool.

VISTA's current typing training program has enabled us to staff the
MassRelay with qualified Operators. Not only do these Operators
demonstrate their skills in regularly scheduled audio typing tests, but
typing speeds are tested each month on live calls through our Contract
Administrator, Bell Atlantic. In the 12 months that VISTA has held the
MassRelay contract, our Operators have never failed to meet the typing
speed minimum for any month. This minimum is established each month
based on the current ratio of trainee and experienced Operators and
their respective typing speed requirements. We believe that by allowing
VISTA to hire persons with a lower typing speed and then allowing a
90-day training period to teach and improve typing, Massachusetts has
established as successful method to achieve superior Relay typing
speeds. However, that 90-day training period is essential to that
success.

III\. RAISING MINIMUM IMPEDES HIRING AND INCREASES COSTS

While raising the minimum typing speed from 55-wpm to 60-wpm at hire may
not at first seem like much of an adjustment, in reality those 5-wpm
will be crippling to our hiring efforts. Those infrequent applicants
whom enjoy superior audio typing skills (above 50 or 55-wpm) are
generally able to gain employment in more highly skilled environments
with varied job responsibilities, etc. Relay, by its nature, requires
employees who are able to develop strong skills, possess firm ethics,
but also are able to perform a singular, repetitive task for hours each
day. This type of employee is not the common "first job" type of
employee, due to the very strict standards of confidentiality and ethics
required by Relay centers. There is a fine balance of personality traits
and job skills that are necessary to produce a great Relay Operator who
will remain on the job long-term.

Raising the minimum typing speed to 60-wpm at hire would suggest
reducing the potential hiring pool more than it is already burdened.
VISTA doesn't believe that there is a large enough pool of those highly
skilled (and therefore highly marketable) candidates to adequately staff
Relay Centers. While it is true that various incentive programs can
induce Operators to remain on the job long-term, call centers experience
relatively high turnover and Relay is no exception. While our turnover
rates are no where near as high as a telemarketing center for example,
the sedentary, repetitive nature of Relay just isn't for everyone over
time. Basically, Relay centers need the broadest possible hiring pool as
possible in order to identify and hire strong Relay Operators.

VISTA believes we would face serious challenges both practically and
economically should the 60-wpm-at-hire ruling stand. In order to keep
the pool as broad as it is today, VISTA would be forced to develop some
sort of "pre-Operator" intensive on-site typing training program in
addition to our current 4 week Operator training. This additional month
of training would be necessary to enable us to continue to hire at
55-wpm and still meet the FCC requirement of 60wpm before the trainee
ever handles a call. As stated earlier, handling relay calls is one of
the best ways for an Operator to increase typing speed, as it is a
"true" call experience with bursts of typing, and moments of rest.
Disallowing a 90-day training period with time on live calls means that
the Provider must replace all of that on-call typing practice with
classroom practice. The cost ramifications are serious. Supporting a job
candidate for two months before they can perform any Operator functions
is an onerous burden for a Relay Provider to bear (as well as the
State).

IV. PROPOSAL FOR FCC CONSIDERATION

VISTA, based on our experience in hiring and developing highly skilled
typists, respectfully requests that the FCC reconsider the 60-wpm
in-coming typing minimum.

We propose that the minimum hiring standard be set between 50 and 55-wpm
and that Providers be allowed a 90-day training period before the OPR/CA
is required to demonstrate 60-wpm typing skills. Our plan fully supports
the Relay User Community's right to excellent standards of service. We
believe that this 90-day training period is not an unreasonable training
time period. It will allow the Provider to develop the trainee's typing
skills while not putting undue burden on Relay users while the training
is taking place. Relay users recognize the value of "live call" training
experience, and in fact, many of the Relay RFP's we've reviewed require
some "live call" training.

V.  CONCLUSION

In conclusion, VISTA commends the Commission for this Order and for
improving the minimum standards for Relay provision. We do, however,
request reconsideration of the 60-wpm at hire typing requirement for
CAs. We believe that our experience in providing the highest typing
standard in the country, as described above, demonstrates that CAs can
be successfully and efficiently trained if allowed a 90-day training and
"speed ramp-up" period, including time handling "live" calls. We
therefore request the Commission change the Order to require a 50 or
55-wpm typing skill at hire, with a 60 wpm minimum required when the CA
reaches 90 days of employment.

Thank you for your consideration.

Sincerely,

Rita M. Beier

Director, Outreach and Quality Assurance