HLAA Files Comments with FCC Regarding IP CTS

HLAA and several national consumer organizations as well as research organizations filed comments with the Federal Communications Commission (FCC) regarding IP CTS (Internet Protocol Captioned Telephone Services). HLAA spearheaded these efforts because we know how important IP CTS is to many of you.

The Commission opened a rulemaking on IP CTS to gather information from stakeholders about a wide range of issues, including questions that are important to consumers: should consumers be allowed to self-certify or should eligibility requirements be established; should state relay programs certify consumers with hearing loss or third parties such as audiologists or ENTs; should states be required or allowed to administer IP CTS; should the providers of IP CTS services be required to provide specific consumer education about how IP CTS is funded; once consumers have a phone, should those consumers have to certify they are still using the phone every other year; and should providers ensure that the IP CTS phones have an easy way to turn the captions on and off. The Commission will review and analyze all comments submitted now and will also review Reply Comments, which will be open until October 16. When the comment period is over, the Commission will then draft new rules for IP CTS.

These rules will set the tone for how consumers are able to get access to and use IP CTS for years to come. Will the states be allowed to set eligibility requirements and certify providers of IP CTS? If states are allowed to set and administer testing for IP CTS, will consumers who age into hearing loss know about those testing sites or even about IP CTS at all? If you already have an IP CTS phone where you live but move to a state that is now allowed to administer IP CTS, will you have to change the phone you need to one that doesn’t meet your needs? These are the kinds of questions the Commission is grappling with.

HLAA believes the Commission must first consider that the Americans with Disabilities Act includes access to telephone service as a civil right. Consumers should not have to leap hurdles to have access to telephone service. We believe the best way for consumers to get the IP CTS services they need is to allow us direct access and attest to their own need for the service. We are concerned that states may or may not have the resources they need to administer this program, and some states might even need to go back to their state legislature to allow them to administer IP CTS. We are concerned that some states are only allowed to contract with one provider at a time, thwarting competition and innovation, and again, shifting the burden onto consumers if the phone they have is not the phone the state allows. We don’t want to leave your access to a phone to chance. See our comments.

If you have questions or would like to file your own comments with the FCC, contact Lise Hamlin at lhamlin@hearingloss.org.