Industry Supports Making Interim IP CTS Measures Permanent
The FCC’s interim measures to prevent misuse of the IP Captioned Telephone Service (CTS) saw universal support from commenters, who generally urged that most or all of the interim changes become permanent. The commission adopted the measures in a January order. However, some commenters cautioned that further study is needed before making permanent a default “off” position of IP CTS devices and software to prevent inadvertent use, warning of harm to the hard-of-hearing community.
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The interim measures included a ban on referrals for rewards programs and any other form of financial inducements; independent certification of hearing loss if a customer accepts IP CTS equipment at a price below $75 from any non-governmental source; and a setting that defaults IP CTS equipment and software to the off position to prevent accidental use.
The commission wasn’t overreacting when it called the recent spike in reimbursement requests “a serious threat to the Fund,” USTelecom said (http://bit.ly/Wiim0s). The association supports permanent adoption of the interim steps, which it said will ensure the long-term viability of IP CTS. “The proposed rules strike an appropriate balance between ensuring the continued availability of IP CTS, and reasonable measures to protect the continued integrity of the TRS fund."
In addition to making all the interim measures permanent, CTIA recommended the FCC require that new equipment designed for use of IP CTS bear a label specifying the captions feature may only be used by those who are deaf or hard of hearing (http://bit.ly/13lxg8p). That labeling requirement would help reduce inadvertent use of the service by hearing individuals, CTIA said. The association also wants the commission to clarify that its rules apply only to equipment primarily intended to be used for IP CTS services. “A smartphone or other wireless devices not primarily intended” to be used for IP CTS “should not be considered IP CTS equipment merely because it runs software” that supports the service, CTIA said.
But for Sprint Nextel, the rapid growth in the IP CTS program “is what one would expect with the aging of the ‘Baby Boom’ generation,” the carrier said (http://bit.ly/Z08vbX). Sprint’s rate of growth has been consistent with its historical growth patterns, it said. Sprint supported permanent adoption of policies prohibiting IP CTS providers from offering financial inducements for referrals of customers who subscribe to the provider’s IP CTS service. “Sprint has not and does not offer bounties for referrals,” and has informed the FCC when it learned about an IP CTS entrant offering rewards. “Kick-backs” puts IP CTS provisioning “on a slippery slope that could lead to the same types of questionable and outright fraudulent activities that have plagued the [Voice Relay Service] segment of the market for years."
Several associations for the deaf and hard of hearing supported the prohibition on referrals for rewards programs, but agreed that IP CTS minutes of use are “legitimately growing” (http://bit.ly/YAyrLv). Like Sprint, the associations pointed to the aging baby boomer population as a reason for the increase in usage, as well as the “aggressive marketing efforts” of IP CTS companies. The associations said labeling requirements are unnecessary, as any notification stating that the service should only be used by people who are hard of hearing can appear on caption screens at the beginning of the call. They also cautioned that requiring default captions off on equipment could unduly burden consumers, having an impact “on the ability of IP CTS users to effectively operate their devices."
Hamilton Relay said the commission’s efforts must be balanced with “the equally important goal of protecting the interests of the numerous hard of hearing Americans, most of whom are elderly, who rely” on the service (http://bit.ly/VOg0Uv). “It may be necessary to re-evaluate the decision to prohibit a user in all instances from selecting captions on as the default setting,” Hamilton said. “The consumers’ loss of this efficiency and functionality may outweigh whatever benefits are derived from the restriction. Therefore, Hamilton urges the Commission to carefully analyze consumers’ needs before making this requirement permanent.” Purple Communications asked the commission to create an exception to the default off rule for devices located where the risk of unintended misuse is “exceedingly low” (http://bit.ly/Xjp6YW). Devices at the private desk of an eligible user who lives alone, for instance, are “extremely unlikely to be used by anyone other than the registered user.”