Industry, Advocates for Hearing Impaired Suggest Ways to Improve Video Relay Services
Providers of video relay services for the deaf and hearing impaired want the FCC to quickly grant VRS users immediate access to new equipment during a two-week grace period while their eligibility is being verified, as proposed in a Further NPRM released in mid-May. The agency took comments on the matter through Tuesday in docket 10-51. "Granting users access to VRS during the verification period will further the goals of providing functionally equivalent service to deaf and hard of hearing consumers, more akin to how hearing individuals are able to use their new phones nearly immediately," said Convo Communications.
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The FCC should allow VRS providers to extend that two-week temporary registration period for consumers who certify in their application that they're deaf-blind or deaf with additional disabilities, said several consumer groups representing the deaf and hearing aid communities. They recommended an initial two-week extension with the ability to grant additional extensions as needed. They suggested two weeks may not be long enough for some who require assistance in completing their applications or more time to provide the validating information to complete the process. "Regardless, a new or ported telephone number should not be removed from the Numbering Directory until after the identity verification process has been completed with a final determination that the user's identity cannot be verified even if such verification process takes longer than the two-week period and any applicable extensions," the groups said.
Convo also wants the FCC to reconsider its plan to require a more stringent log-in process for public video phones in spaces such as schools, hospitals, airports, libraries and governmental agencies. "One rarely sets out planning to use a public phone; public phones are generally by their nature utilized unexpectedly, and thus it is not realistic to expect registered individuals to remember their PIN upon the occasional need to use VRS from a public location," it said. VRS users under stress may also have more difficulty remembering a personal identifying number, Convo said, saying the proposed 911 call exemption would "not assist users who have emergent situations for which they do not call 911," such as to contact an obstetrician when labor has begun, to summon a family member to the hospital, or to reach out to a domestic violence advocate. The new log-in requirements could also exclude children, travelers from abroad and others not otherwise registered from accessing public videophones, Convo said.
Requiring a PIN-based log-in for public videophones could "require consumers to provide sensitive personally identifiable information to providers, exposing them to heightened risks of privacy and security violations," Sorenson Communications said. Sorenson also said those callers most likely to rely on public phones for their communications needs: the elderly, homeless, children and users with cognitive disabilities, are among those most likely to struggle with "remembering or even figuring out how to enter a password." The same groups are also least likely to have regular access to smartphones, voicemail, email "or other devices and accounts requiring routine password memorization," it said.
ALS Services Holdings (dba GlobalVRS) supports the permanent adoption of an FCC pilot program that allows video interpreters to work at home, but it wants better definition and clarification of the safeguards the agency would require for compliance. It suggests that because more providers will be participating in at-home interpreting, the FCC "should be prepared to make further amendments" to the program's rules based on the results from other providers. GlobalVRS said it would "appear highly unusual for the Commission to amend current safeguards based on the trial results of a single provider who required extensions to complete its own trial." The company asked the FCC to clarify what level of technical security is appropriate for an at-home broadband Internet access service line and determine who assumes responsibility for the line's security. GlobalVRS also urged the FCC to "establish the specific level of system redundancy" deemed acceptable for at-home interpreting.
ZVRS and Purple Communications, the only providers in the pilot program, filed comments through parent company CSDVRS asking the FCC to make the at-home interpreting pilot program permanent and to "refrain from adopting additional rules for at-home interpreting that will unnecessarily limit the benefits of at-home call handling." It asked the FCC to remove a three-year experience requirement for at-home interpreters (see 1812130007), eliminate a 30 percent limit on VRS minutes per provider handled at home, "allow market forces to determine the appropriate balance of traditional and at-home calls handled," and lighten other burdens on the program. ZVRO and Purple said they "believe that the regulatory certainty provided by permanent authorization of at-home call handling will allow VRS providers to further increase efficiencies and realize cost savings that will benefit providers and the Fund."
In joint comments, consumer groups including Telecommunications for the Deaf and Hard of Hearing, National Association of the Deaf, Association of Late-Deafened Adults, Cerebral Palsy and Deaf Organization, and the American Association of the DeafBlind said they "generally support" making the VRS at-home call handling program permanent, "but some concerns remain." The groups want the FCC to continue evaluating and improving safeguards for confidentiality as technology changes "because confidentiality in communications is a key aspect of functional equivalency" and is required by regulation.
Reply comments are due Sept. 4.