PRESENTATION Karen Peltz Strauss Eliot Greenwald Consumer & - - PowerPoint PPT Presentation

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TRS ADVISORY COUNCIL PRESENTATION Karen Peltz Strauss Eliot Greenwald Consumer & Governmental Affairs Bureau TRS Advisory Council September 15, 2016 Annapolis, Maryland Roundtable Communications needs for Deaf Persons with Mobility


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September 15, 2016 TRS Advisory Council Annapolis, Maryland

TRS ADVISORY COUNCIL PRESENTATION

Karen Peltz Strauss Eliot Greenwald Consumer & Governmental Affairs Bureau

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Roundtable

 Communications needs for Deaf Persons with

Mobility Disabilities – March 17, 2016

 Panels included:

 Accessible Communications for Everyone (ACE)

platform

 Ways to achieve functionally equivalent TRS for DPMD  Developing recommendations to address the

communications needs of DPMD

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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Disability Advisory Committee N-1-1 Services

 Emergency Communications Subcommittee

 TRS Access to Non-Emergency N-1-1 Services  On February 23, 2015, as proposed by the

subcommittee, the DAC: “Recommended, that the FCC provide clarification of current TRS rules and remind TRS providers of their obligation to handle N-1-1 calls and, if appropriate, institute an inquiry to find out the extent to which people who use [TRS] are able to contact their local or regional N-1-1 services.”

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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DAC - VRS

 Relay/Equipment Distribution Subcommittee –

Proposed resolutions for the September 22, 2016 DAC meeting

 VRS 911 call handling recommendations:

 Disability Rights Office (DRO) and Consumer and

Governmental Affairs Bureau (CGB) work with Association of Public Safety Communications (APCO) and National Emergency Number Association (NENA) to develop an Implementation Guide for Mandatory Minimum Training Standards for 911 call handling for all VRS CAs

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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DAC – VRS (2)

 Relay/Equipment Distribution Subcommittee –

Proposed resolutions for the September 22, 2016 DAC meeting

 VRS 911 call handling recommendations:

 DRO and CGB support development of Best Practices for

911 call handling and processing for VRS CAs

 FCC take steps to ensure that annual 911 training is

required for all VRS CAs, including a refresher course for veteran CAs

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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DAC – IP CTS

 Relay/Equipment Distribution Subcommittee –

Proposed resolutions for the September 22, 2016 DAC meeting

 Recommendations for IP CTS quality metrics:

 Verbatim and accuracy standards  Speed standards  Delay standards  Testing to determine compliance take place at least

monthly

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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DAC – IP CTS (con’t)

 Relay/Equipment Distribution Subcommittee –

Proposed resolutions for the September 22, 2016 DAC meeting

 Recommendations for IP CTS quality metrics:

 Clarify that the 10 minute time period required for CAs to stay

  • n a call does not begin until the CVA full understands the

person they will be captioning

 FCC solicit information from consumers and providers regarding

how IP CTS may benefit from the introduction of HD voice, RTT, and other technological improvements

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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NDBEDP

 CVAA

 Authorized $10 million annually from the Interstate TRS Fund

 To support programs approved by the FCC  For the distribution of specialized customer premises equipment  Designed to make telecommunications services, advanced

communications services, and access to the Internet accessible by individuals who are

 Deaf-blind, as defined in the Helen Keller National Center

Act and

 Low-income, which is defined for this program as 400% of

the Federal Poverty Guidelines

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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NDBEDP (2)

 History

 In 2011, the FCC established the National Deaf-Blind

Equipment Distribution Program as a pilot program, which has come to be known as iCanConnect

 The pilot program began on July 1, 2012  We are currently in Year 5 of the pilot program, which

runs through June 2017

 On August 4, 2016, the FCC adopted rules to convert the

pilot program into a permanent program

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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NDBEDP (3)

 How the Pilot Program operates

 The FCC selected and certified one entity in each of the 50

states, plus the District of Columbia, Puerto Rico, and the U.S. Virgin Islands, to receive funding to distribute equipment

 The FCC allocates $50,000 to each of the 53 certified

programs, plus additional funding based on the size of each state or territory’s population

 States with larger populations are allocated larger amounts of

funding than states with smaller populations

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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NDBEDP (4)

 How the Pilot Program operates (con’t)

 The FCC also set aside $500,000 per year for the Perkins School

for the Blind to coordinate nationwide outreach

 Certified programs distribute specialized and off-the-shelf

equipment, separately or in combination, as long as it meets the needs of the deaf-blind individual, and makes communications services covered under the program accessible

 Types of equipment the program has distributed:

 Computers, laptops, tablets, deaf-blind communicators, braille

devices, smartphones, amplified phones, alerting devices, and various software applications

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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NDBEDP (5)

 How the Pilot Program operates (con’t)

 Funding covers the reasonable costs of:  The equipment distributed, warranties, maintenance,

repairs, inventory for temporary replacements, and refurbishing

 State and local outreach efforts, individual assessments of

a deaf-blind person’s communications equipment needs, equipment installation, and individualized training of consumers on how to use the equipment

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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NDBEDP (6)

 Highlights from the Permanent Program rules: what’s new:

 Extends the program to Guam, Northern Marianas, and

American Samoa

 Adds administrative and financial management experience to

program certification criteria

 Requires entities to disclose potential or actual conflicts of

interest in the certification application process and after certification

 Will certify programs for periods of five years

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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NDBEDP (7)

 Permanent Program rules: what’s new (con’t)

 Requires an outgoing program to take certain steps to ensure

a smooth transition to the newly-certified program

 Reduces funding for national outreach  Allows certified programs to be reimbursed for pre-approved

consumer travel costs for assessments and training conducted at a program center location

 Allows certified programs to use up to 2.5% of their annual

allocations on train-the-trainer activities to address a persistent shortage of qualified trainers

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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NDBEDP (8)

 Permanent Program rules: what’s new (con’t)

 Allows certified programs to be reimbursed for

administrative costs up to 15% of their annual allocations

 Establishes program performance goals and directs CGB to

establish performance measures

 Authorizes the development of a centralized database that

certified programs must use for reporting purposes and may use to generate reimbursement claims

 Requires submission of a copy of each certified program’s

annual audit to the FCC

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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NDBEDP (9)

 Permanent Program rules: what’s new (con’t)

 Requires certified programs to retain records for five years  Requires CGB to assess program performance during the

fifth year of the permanent program, including the extent to which funding should be continued for outreach, travel, and train-the-trainer activities

 Adds new consumer attestations for compliance with

Commission rules

 Establishes procedures for filing informal complaints with

the FCC

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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TRS Fund Contribution Base

 November 25, 2015 – IDT filed a petition for rulemaking

requesting the FCC to review and revise its rules and policies

  • n the contribution methodology for the Interstate TRS

Fund

 Requests intrastate revenues to be included in the

contribution base

 Requests elimination of rule requiring that VRS costs be

recovered from only interstate and international revenue

 December 18, 2015 – Public Notice seeking comment

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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Numbering Directory Waiver

 November 23, 2015 – Wireline Competition Bureau

granted waiver to permit

 VTCSecure – contractor building VRS reference platform  MITRE – contractor performing TRS research for FCC  To access TRS Numbering Directory to extent necessary

to carry out tasks related to contractual responsibilities

 Both operate under detailed contractual obligations to

protect non-public information consistent with security and privacy concerns

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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Numbering Directory Waiver (2)

 July 6, 2016 – VTCSecure filed petition for waiver

and declaratory ruling

 To permit providers of direct ASL customer support

services to access TRS Numbering Directory

 To clarify that VRS providers are required to support the

ability of VRS users to make and receive direct video, voice and text calls to and from any number listed in the TRS Numbering Directory, including direct customer support numbers

 July 18, 2016 – Public Notice seeking comment

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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Equal Access Waiver

 August 24, 2016 – CGB granted 2-year temporary waivers to

Sprint and Hamilton of two requirements for traditional TRS, STS, and CTS:

 Providers must allow users to select their own long distance

telephone carrier

 Providers must offer the same billing options (such as collect, calling

card, and third party billing) as traditionally offered by wireline telephone companies

 Conditioned on providers not charging for long distance  In 2014, FCC eliminated these requirements for iTRS

 Intend to address issue on a permanent basis

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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TRS Rates

 June 30, 2016 – CGB adopted rates for July 2016 –

June 2017 rate year

 Interstate traditional TRS - $2.6245 per minute  Interstate STS - $3.7555 per minute  Interstate CTS and IP CTS - $1.9058 per minute  IP Relay - $1.30 per minute subject to possible true-up  VRS rates previously adopted by the Commission (to be

discussed in the VRS slides)

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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VRS

 November 3, 2015 – FCC released a Further Notice of

Proposed Rulemaking (FNPRM) seeking comment on:

 Rates

 A proposal to modify in part the four-year compensation

rate plan for VRS adopted in 2013, by adopting a limited- duration compensation rate freeze applicable to VRS providers with 500,000 or fewer monthly minutes

 Speed of Answer

 A proposal to amend the speed-of answer rule to require

80% of all VRS calls to be answered within 45 seconds, measured monthly

 It is currently 80% of calls within 120 seconds

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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VRS (2)

 November 3, 2015 FNPRM also seeking comment:

 Speed of Answer  Alternatives to the current policy of withholding an

entire months compensation for missing the speed of answer requirements:

 A siding scale approach  An incentive approach with additional

compensation for a stricter speed of answer

 A streamlined waiver process

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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VRS (3)

 November 3, 2015 FNPRM also seeking comment:

 Speed of Answer

 Whether to modify how to calculate speed of answer in

terms of defining when a call is answered to conform to

  • ther TRS rules, which are based on when the caller’s call

is placed, and not put in a queue or on hold

 Deaf Interpreters

 Whether to permit compensation for a deaf interpreter in

addition to a hearing interpreter for certain users

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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VRS (4)

 November 3, 2015 FNPRM also seeking comment:

 Skills-Based Routing

 Provider proposal for a trial of skills-based routing  The merits of skills-based routing  How to define types of calls for skills-based routing  Additional costs from skills-based routing  How to structure a trial of skills-based routing  The length of the trial  The type of data that should be collected

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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VRS (5)

 November 3, 2015 FNPRM also seeking comment:

 At-Home Interpreting

 Whether to permit interpreters to work at home at any

time

 Safeguards needed for at-home interpreting

 Assigning Ten Digit Numbers to Hearing People

 Whether to assign ten digit numbers to hearing people for

the limited purpose of making direct (point-to-point) video calls to and from other VRS users

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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VRS (6)

 March 3, 2016 – FCC released Report and Order to

adjust VRS rates

 Provides limited rate relief to providers with 500,000 or

fewer monthly minutes (smallest VRS providers)

 $5.29 per minute from July 1, 2015 (applied retroactively)

through October 31, 2016

 $5.06 per minute from November 1, 2016 through April

30, 2017

 $4.82 per minute from May 1, 2017 through June 30, 2017

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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VRS (7)

 March 3, 2016 VRS rate order

 Maintains rates adopted in 2013 for other VRS

providers

 Tiers I and II (first 1 million monthly minutes)

 $5.06 per minute July 1, 2015 – December 31, 2015  $4.82 per minute January 1, 2016 – June 30, 2016  $4.44 per minute July 1, 2016 – December 31, 2016  $4.06 per minute January 1, 2017 – June 30, 2017

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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VRS (8)

 March 3, 2016 VRS rate order

 Maintains rates adopted in 2013 for other VRS

providers

 Tier III (monthly minutes exceeding 1 million)

 $4.06 per minute July 1, 2015 – December 31, 2015  $3.87 per minute January 1, 2016 – June 30, 2016  $3.68 per minute July 1, 2016 – December 31, 2016  $3.49 per minute January 1, 2017 – June 30, 2017

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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VRS (9)

 August 4, 2016 – CGB released a FNPRM on VRS

interoperability standards

 August 2015, the VRS Task Group of the SIP Forum published

the VRS Provider Interoperability Profile

 July 2016, the Relay User Equipment (RUE) Forum published

the Interoperability Profile for Relay User Equipment

 FNPRM seeks comment on tentative conclusion that these

standards meet the FCC’s objective of facilitating interoperability and portability for VRS, and should be incorporated by reference into the FCC’s rules

 Comments due September 14, 2016

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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VRS (10)

 VRS issues still pending from the FNPRM

accompanying the June 10, 2013 VRS reform order:

 VRS rates beginning July 1, 2017  Whether to transfer responsibility for handling 911 calls to a

single VRS contractor

 Whether to prohibit the use of non-competition clauses in

employment contracts

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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IP CTS

 April 7, 2015 – CGB suspended InnoCaption’s

conditional certification because InnoCaption failed to operate in compliance with FCC emergency call handling requirements

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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IP CTS (2)

 June 17, 2016 – CGB released on Order reinstating

InnoCaption’s conditional certification to provide IP CTS

 Order waived certain elements of the emergency call

handling rule:

 Send to the public safety answering point (PSAP)  The provider’s name and callback number  ID number for the CA handling the 911 call  Initiate the reconnection of a 911 call if one or both legs

are disconnected

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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IP CTS (3)

 Background

 In 2014, the U.S. Court of Appeals for the DC Circuit

invalidated two of the requirements adopted in the August 2013 IP CTS order

 The FCC may not require consumers to pay $75 for IP CTS

equipment

 It is permissible for consumers to have a choice of obtaining

third-party certification or paying $75 for equipment

 The FCC may not require that IP CTS phones be set to default

with captions off

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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IP CTS (4)

 Issues pending on remand from the court:

 Users who have registered since the court decision went into

effect have not been required to obtain either a third-party certification or pay $75 for equipment. Question pending is whether to require third-party certification of new users as well as users who have registered since the court decision went into effect

 Since the court decision, IP CTS phones are required to have a

button, key or icon to easily turn captions on, but there is no similar requirement to turn captions off. Question pending is whether to require a button, key, or icon to turn captions off

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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IP CTS (5)

 Issues pending from the FNPRM accompanying the

2013 IP CTS Reform Order:

 Whether to restructure the rate methodology  Whether to prohibit the use of phones which require

captions to be turned on before certain volume adjustments can be made

 Whether to require a default of “captions on” for 911 calls

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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IP CTS (6)

 Issues pending from the 2013 FNPRM:

 Whether to migrate IP CTS to state TRS programs  Whether to centralize registration and verification of IP

CTS users in the TRS-URD

 Whether to adopt mandatory minimum requirements for

speed and accuracy

 Whether to require provider websites to have notifications

regarding prohibited use of IP CTS by hearing individuals

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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IP CTS (7)

 Other pending IP CTS issues :

 Updating 911 calling rules for web and wireless IP CTS  With traditional IP CTS, the 911 connection is provided by the

underlying telephone or VoIP provider

 Rules governing web and wireless IP CTS were adopted in early 2008

before iTRS providers were part of the North American Numbering Plan

 Question is how to update the rules, now that there are easier and

better ways to connect users to 911

 Whether to make permanent the alternatives to providing the last 4 digits

  • f SSNs for those who do not have SSNs

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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IP Relay

 Pending IP Relay issues:

 Enhanced registration, certification and verification

procedures to prevent ineligible users from using IP Relay, thereby ensuring the availability of the service for legitimate users

 Per call validation procedures  Application of the centralized TRS-URD to IP Relay,

including security of information in the TRS-URD

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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IP Relay (2)

 Pending IP Relay Issues:

 Alternative ways to restructure IP Relay, such as

 Selecting the provider or providers through a competitive

bidding process or

 Making IP Relay a mandatory service and turning over

administration to the states, similar to what is now done for traditional TRS and STS

 Restructuring the ratemaking methodology  Determining the needs of deaf-blind users and how to

accommodate those needs

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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IP Relay (3)

 Pending IP Relay Issues:

 Permanent elimination of “guest user” procedure for calls to 911  June 2012 order prohibited guest users except for calls to 911  In 2014, to address “swatting,” rules were waived for 1 year to

permit providers to refuse to handle 911 calls by guest users

 In June 2015, waiver extended until FCC addresses the issue on

a permanent basis

 When to disconnect an idle call – what is the appropriate wait time  Whether to prohibit more than 2 simultaneous calls by the same

user

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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STS

 Pending STS Issues:

 Establishing a nationwide STS outreach program  Registration, certification, and verification requirements for

STS users

 The inapplicability of certain TRS mandatory minimum

standards established for TTY use – typing and spelling, ASCII and Baudot, call release, and VCO – to STS

 The minimum wait time – 60 seconds – that should be

required before terminating an idle STS call

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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STS (2)

 Pending STS Issues:

 Minimum STS CA training standards  Requiring providers to allow STS users to create profiles  Video Assisted STS (VA STS), a form of STS where the user

and CA are connected by both audio and video

 IP STS, a form of STS where the user is connected to the CA

  • ver an IP connection rather than the PSTN

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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AccessInfo

 Join the AccessInfo Email List  To keep informed about all of the FCC’s

accessibility and disability news

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AccessInfo@fcc.gov, and write “subscribe” in either the subject line or the main body

September 15, 2016 TRS Advisory Council Annapolis, Maryland

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Contact Information

 Karen Peltz Strauss

 Voice telephone: (202) 418-2388  Email: karen.strauss@fcc.gov

 Eliot Greenwald

 Voice telephone: (202) 418-2235  Email: eliot.greenwld@fcc.gov

 DRO website: www.fcc.gov/cgb/dro  FCC videophone: (844) 432-2275

September 15, 2016 TRS Advisory Council Annapolis, Maryland