Mike Pereira is shouting into the wind. He hears the pervasive calls to improve NFL officiating, demands that would have reached his desk when he was the league's vice president. Now, as a Fox Sports analyst and author, he can't believe how few people have noticed what already is underway.

"Officiating is changing before our very eyes," he said, "and I don't know if anyone has recognized it -- except maybe me."

In a conversation this week about his book, "After Further Review," Pereira reiterated and amplified a theory that he first advanced last year -- a premise that makes perfect sense but would undermine the transparency of NFL game administration. According to Pereira, referees regularly receive assistance and advice from replay officials on their wireless headsets, communication that helps them make accurate calls but would be in violation of rules the league itself has published and publicized.

Mike Pereira's book, published in September 2016, digs into his life as an official and as the NFL's former vice president of officiating. Courtesy Triumph Books

The NFL had no comment beyond providing a copy of the applicable policy, one that allows minimal interaction on game administration but not on the type of every-down decisions that Pereira said have been affected.

To be clear, it's a big deal for a credible and respected former executive to charge that the league is breaking its own rules -- even for an ultimately noble cause. Pereira said his theory is based on both his own observations and discussions with replay officials he maintains personal relationships with.

The NFL's silence does not faze Pereira, who has become a media star for his accurate and frank assessments of calls during games since retiring from the NFL and joining Fox Sports in 2010.

"They're never going to come out and admit it because it's not allowed in the rules," he said. "I get that. And I'm not against the notion of trying to get as many calls right as you can, but my only concern is if the rulebook doesn't allow you to do it -- to me, there is a conflict. I get the side of trying to avoid controversy, but I'd rather the rulebook allow it first."

How could this happen? As an example, Pereira cited a play from the fourth quarter of Monday's game at Gillette Stadium between the Baltimore Ravens and New England Patriots.

On first down, Ravens tailback Kenneth Dixon caught a short pass from quarterback Joe Flacco at the Patriots' 30-yard line. Dixon stumbled as linebacker Kyle Van Noy attempted to tackle him, but Dixon regained his footing and made it to the 23-yard line.

Referee Ed Hochuli first marked the ball at the 23. Then he picked it up and placed it at the 27. Dixon's right knee had touched the ground at the 27 when he stumbled, as an ESPN replay later showed.

Patriots coach Bill Belichick hadn't challenged the play, and the teams were nearly two minutes away from the two-minute warning, after which the replay official is tasked with initiating all reviews. Pereira believes that Monday's replay official, whom the official league game book identified as Tom Sifferman, told Hochuli that Dixon's knee had touched the ground to help avoid a mistake.

According to the NFL rulebook, the replay official -- or senior vice president of officiating Dean Blandino and his staff in New York -- is permitted to "consult" with the referee to ensure the correct application of rules and other administrative matters. Three specific instances are mentioned: assessment of penalty yardage, proper down and the status of the game clock. In a news release announcing those changes, the NFL wrote that the policy will not involve "on-field judgment calls beyond what is already part of the instant replay review process."

Dixon's catch was never officially put under review.

"It was the replay official who did it," Pereira said. "They have gotten so involved in the game since they started using this communication system [in 2014]. The official on the field made an error, and boom, they make that change. What do you think happened? I talk to replay officials. They're involved in almost everything now.

"If that's the tack you're going to take, as far as I'm concerned, that's fine. But everyone has to be aware of it. There has been all of this talk of adding an eighth official, but really, they already have one. He's in the booth."

Pereira first spoke out in September 2015, noting a call that referee Jeff Triplette reversed in a game between the then-St. Louis Rams and Seattle Seahawks. Pereira stood by his claim in December 2015 after the NFL codified a limited policy for communicating on administrative issues for the postseason.

Referee Ed Hochuli was involved in one play during the Ravens-Patriots game that Mike Pereira cites as a replay official getting involved from the booth. Brace Hemmelgarn/USA TODAY Sports

But his words have gone largely unheard, ignored or both. Not everyone will consider it a massive controversy, but from my perspective, it's a startling revelation.

Officials are third-party game administrators, and their presence on the field provides a level of accountability. We can see, with our own eyes, who is making the decisions that impact the outcome of the games. We can see how they're doing it, and we also know that the replay official -- and the New York staff -- are evaluating plays that are announced to be under review.

In Pereira's scenario, however, there are officials working surreptitiously and outside of policy. In Monday night's game, Ravens coach John Harbaugh could be seen asking why Hochuli had moved the ball. Shouldn't these decisions be clear, obvious and transparent? And if the NFL is disregarding this particular set of rules, what other polices is it failing to follow?

"It's not necessarily a bad thing," Pereira said. "It's just kind of undercover at the moment. But you can see it. This is the landscape of where officiating is going."

Indeed, I've written often about the inescapable tug of technology on officiating. Ubiquitous HD broadcasts have given fans better and more consistent views of plays than officials, and sports leagues around the world are scrambling to catch up.

Having an official with access to those same views, a system the Canadian Football League established this season, makes all the sense in the world. Many of us figured the NFL would eventually catch up. But Pereira, who has more knowledge and insight into the league's officials than anyone not currently in its employ, thinks it already has.

Our conversation covered a number of topics in the book, including the issue of full-time officials and the impact of new discipline the league introduced last season and appears already to have backed away from. You can find further details below.

17 full-time referees -- or nothing

In the book, Pereira laid out a proposal to convert each NFL referee -- the 17 "crew chiefs," in baseball parlance -- to full-time status. The rest of the officials would remain part time, a financial and structural compromise Pereira believes would achieve a maximum level of realistic efficiency.

As full-time employees, Hochuli, Gene Steratore, Clete Blakeman & Co. would spend their work week at a centrally located officiating academy. Pereira suggested Dallas.

Together, they would review and evaluate film to promote consistency across crews. They would make weekly training videos and practice tasks that seem mundane but have a disproportionate impact on public confidence, such as smooth announcements of penalties. In the offseason, they would work with the competition committee to write better rules, visit teams during workouts and establish training regimens for their crews.

The cost would be significant, Pereira acknowledged. In order to entice veteran referees to give up their other jobs -- Hochuli and Blakeman are attorneys, for example, while Steratore works basketball games and owns a supply company -- they would need guaranteed five-year contracts. Salaries would probably need to exceed $400,000 annually; senior NFL referees earn less than half of that, according to Pereira's book. Any referee who doesn't want to change could accept a demotion as one of the six part-time officials on each crew.

"Those 17 referees are your best and clearly your most important guys," Pereira said. "They reflect the confidence or the lack of confidence in any crew, and they should be involved in everything."

Pereira sees "no benefit" to a recent proposal from NFL executive vice president Troy Vincent to hire 17 new officials full time as middle judges positioned in the defensive backfield.

"How do you think Ed Hochuli will feel when he's got a rookie telling him what to do because he's full time?" Pereira said. "I personally think there is only one way to go."

The NFL disciplined side judge Rob Vernatchi in 2015 for failing to notice an 18-second runoff on a game clock. Charlie Riedel/AP Photo

Damage done by 2015 discipline

Pereira wrote particularly harsh words in the book for the NFL's decision to discipline several officials in a public way last season, including a suspension of side judge Rob Vernatchi for failing to notice an 18-second runoff on a game clock. The league also made a point to push crew members to lesser-profile games after major mistakes to minimize public discussion.

He criticized Blandino for failing to stand up to NFL executives who wanted the discipline. When he had Blandino's job, Pereira wrote, he once made commissioner Roger Goodell so angry for refusing to suspend an official that Goodell shoved him into a door.

In addition to the suspension, Vernatchi was required to speak with NFL security, to "I guess ... make sure that he didn't have a bet on the game," Pereira wrote.

He added: "I had never seen a darker period than the league was going through then -- when accountability went from grading to an attack on integrity."

Over the phone, Pereira pointed out the NFL appears to have backed off that aggressiveness. The most notable example: The NFL apparently did not discipline referee Walt Anderson for a series of miscues -- which Blandino pointed out on Twitter in near-real time -- in a Week 9 game at Seattle's CenturyLink Field.

"You don't want officials officiating out of fear of being suspended for a mistake," Pereira said. "The normal process of evaluation, as it is, could take them out of the playoffs and could get them fired at the end of the season. Doing what they did last year wasn't good and you've seen it ease up."