Telecommunications Relay Services (TRS)

ical (actual) and projected costs for IP and VRS must be filed by April 1, 2008.

Return completed responses to:

Jill Cardoso
NECA TRS Fund Administration
80 South Jefferson Road, Room N3097
Whippany, New Jersey 07981

The original signed forms must be returned to NECA. Questions concerning the data request should be referred to Jill Cardoso
at 973-884-8124 or via email to jcardos@neca.org. Also, Jeff Henderson at 973-884-8261 or via e-mail at
jhender@neca.org
is
available to answer questions. This data will be the basis for determining the total fund size requirement. Carrier revenue information
to determine the contribution base will be filed on April 1, 2008 via the FCC Form 499-A, Telecommunications Reporting Worksheet.
NECA will use the provider rate and demand information and the carrier revenue information to calculate the carrier contribution
factor and fund size. On May 1, 2008, NECA will file with the FCC payment formulas, its proposed fund size requirement,
carrier contribution factor and projected demand for each service for the fund year July 1, 2008 through June 30, 2009.

A. GENERAL
INFORMATION
On November 19, 2007, the Commission released a Report and Order (FCC 07-186) adopting new cost recovery methodologies
for the various forms of TRS. The Order also clarified the nature and extent that certain categories of costs are compensable from
the Fund.

For interstate traditional TRS, interstate Speech-to-Speech (STS), interstate captioned telephone service (CTS), and interstate and
intrastate Internet Protocol captioned telephone service (IP CTS) the compensation rates shall be based on the MARS plan. For
Internet Protocol (IP) Relay, the compensation rate shall be based on price caps. For Video Relay Service (VRS), the
compensation rates shall be tiered rates based on call volume.

Providers of IP and VRS are required to file annual cost and demand data with the Fund Administrator as they have in the past.
The Commission believes that this information, which includes actual costs for prior years, will be helpful in reviewing the
reasonableness of the compensation rates adopted for IP Relay and VRS under the new methodologies, and whether they
reasonably correlate with projected costs and prior actual costs. This information will also be needed to evaluate rates every three
years.

For traditional TRS and STS, under the MARS plan each January the Fund Administrator will request each state TRS
administrator, and each provider of interstate TRS, STS, and CTS to provide the following data for the previous calendar year:
(1) per-minute compensation rates for intrastate traditional TRS ,STS, and CTS; (2) whether the rate applies to session minutes or
conversation minutes; (3) the number of intrastate session minutes for traditional TRS, STS, and CTS; and (4) the number of
intrastate conversation minutes for traditional TRS, STS, and CTS. If the contractual per-minute compensation rate does not
include all of the costs paid by the state to the provider for the relay service, the state should also list other amounts paid to the
provider during the relevant calendar year. The state and the provider should indicate what information should be considered
confidential.

The Order also provided that:



Indirect overhead costs are not reasonable costs of providing TRS. Appropriate overhead costs are those costs directly
related to, and directly support, the provision of relay service. Indirect overhead costs may not be allocated to TRS by an
entity that provides services other than TRS based on the percentage of the entitys revenues that are derived from the
provision of TRS. (FCC 07-186, ¶74-75).










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Start-up expenses are compensable, but must be amortized in accordance with generally accepted accounting rules (FCC
07-186, ¶76-77).



All costs submitted must directly support the provision of relay service (FCC 07-186, ¶75).



Reasonable executive compensation for persons who directly support the provision of TRS is compensable from the Fund
(FCC 07-186, ¶79). For example, if executives of a company that provides a variety of services in addition to TRS do not
personally work on TRS issues, no part of their salaries can be included in the companys TRS cost submission (FCC 07-
186, ¶75).



Financial transaction costs or fees unrelated to the provision of relay service are not compensable as reasonable costs of
providing service. Such costs include costs and fees relating to a change in ownership of the entity providing relay service,
the sale of the entity, the spin off of part of the entity, or any other transaction directed at the ownership, control, or
structure of the relay provider (FCC 07-186, ¶80).



Costs attributable to relay hardware and software used by the consumer, including installation, maintenance costs, and
testing are not compensable from the Fund. Compensable expenses do not include expenses for customer premises
equipment whether for the equipment itself, equipment distribution, or installation of the equipment or necessary
software (FCC 07-186, ¶82).



Do not include profit or tax allowances in expenses. (FCC 04-137, ¶179-182)



Only expenses to meet the non-waived mandatory minimum standards should be included. (FCC 04-137, ¶188-190)



Capital investment data, if applicable, must be submitted by service. (FCC 04-137, ¶177-182)



If depreciated expenses are reported, the year end net book value of the capital investment from which depreciation was
computed must be reported in Section F.


TRS providers must submit the following data:

total annual expenses of providing IP Relay and VRS



reported in only one category; the section total of expense categories should reflect the total expenses of providing each service
(i.e. IP and VRS).



actual annual 2006 and 2007 expenses and projected annual expenses for 2008 and 2009.

Please complete the appropriate expense page for each of the services performed. Each expense form is identified by service type
on the first line of the form.

All reasonable expenses of providing eligible relay services, whether as part of a state-contracted service or a stand-alone
service, are reportable.


B. FORM
INSTRUCTIONS

Provider Identification

A. Service Provider/Administrator: Provide the requested information about the service provider -- the entity responsible for
providing TRS/IP/STS/VRS/CTV and IP CTS. The contact name requested is the name of the person who will serve as the
official provider interface for the interstate TRS Fund Administrator.










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B. Data Request Response: List the name and contact information for the person to whom questions and requests for clarification
regarding the data request response should be directed.

C. Changes, Activities & Improvements: If significant changes have occurred or are expected to occur with this service, please
provide an explanation.

D. Other Information: Provide the requested information for each state served. The rate information is confidential and will not be
shared with anyone outside of NECA and the Commission.

E. Center Location: Please provide address, city and state, and the hours of operation for each relay center and list the
services provided in that center.

F. Subcontractors, etc.: Please provide a listing of all subcontractors, marketing entities, websites, and any other entities through
which relay services are provided.

I.
Total Video Relay Service Expenses

Include reasonable expenses attributable to providing Video Relay Service in English as required under Part 64 of the FCC
rules, such as gathering traffic, the center itself, and handing off calls to the interexchange carrier. When reporting expenses,
please round only to the next dollar; report all amounts in whole dollars.

A.

Annual Recurring Fixed/Semi-Variable Expenses

1.

Rent: Annual payments solely for land and/or buildings rented for the provision of TRS.

2.

Utilities: Expenses associated with land and buildings, such as water, sewerage, fuel, T1 lines, internet connectivity and
power. Telephone service expenses, such as center toll free numbers, local and foreign exchange should also be
included here. Also see ITEM B. 4.

3.

Building Maintenance: Expenses for maintenance and repair.

4.

Property Tax (if owned): Taxes paid on property owned and used for the provision of TRS.

5.

Furniture (if leased): Lease or rental expenses associated with center furnishings.

6.

Office Equipment (if leased): Lease or rental expenses associated with office equipment.

Subtotal Section A expenses.

B.

Annual Recurring Variable Expenses (Direct TRS Operating Expenses)

1.

Salaries and Benefits: Compensation to non-management employees (persons performing communications assistant
and interpreter activities), such as wages, salaries, commissions, bonuses, incentive awards and termination payments;
payroll related benefits paid on behalf of employees, such as pensions, savings plans, workers compensation required by
law, insurance plans (life, hospital, medical, dental, vision); and social security and other payroll taxes. Included in this
expense is the cost of contract interpreters and/or communication assistants wh