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Telecommunications Update – FCC Services Accessibility

March 4, 2015

The Shulman Rogers Telecommunications Group would like to remind you of the FCC’s annual Service Accessibility recordkeeping compliance certification and contact information reporting obligation, due this year on April 1, 2015. This filing obligation pertains to all telecommunications carriers, providers of interconnected VoIP, voicemail or interactive menu services, and any manufacturer of telecommunications or interconnected VoIP equipment or CPE. With the intention to make telecommunications services and equipment more accessible to persons with disabilities, the Commission is asking for certifications regarding steps taken to ensure greater access, and for contact information for the party responsible for receiving complaints about inaccessible services or equipment.  From the FCC’s website:

Beginning January 30, 2013, entities that are subject to Section 255 of the Communications Act must maintain records in accordance with the Commission’s rules, and submit recordkeeping compliance certifications and contact information to the FCC annually …

Section 255 of the Act reads in part:

(b)  Manufacturing
A manufacturer of telecommunications equipment or customer premises equipment shall ensure that the equipment is designed, developed, and fabricated to be accessible to and usable by individuals with disabilities, if readily achievable.

(c)  Telecommunications services
A provider of telecommunications service shall ensure that the service is accessible to and usable by individuals with disabilities, if readily achievable.

Q – Does this apply to me?
A – If you are a wireless licensee and provide a communications service to any entity outside of your organization, whether common carrier (i.e., interconnected) or not, then this applies to you.  If you manufacture any telecommunications equipment intended to be operated by end-users (ie, radios and pagers) then this rule applies to you.

Q – What are the consequences of non-action?
A – The FCC has not specified what the penalties will be for noncompliance with these regulations, but if history is any indication, the annual CPNI filings might be a good guide.  These regulations are similar to the CPNI rules, and when the FCC implemented that annual filing requirement, it levied fines of up to $20,000 for telecommunications providers that failed to make a proper certification filing.

Shulman Rogers is pleased to assist with your Service Accessibility filing for a flat fee of $300, and $150 for any additional companies under common ownership required to file. If you would like any assistance in making this filing or in better understanding your obligations under these regulations, please contact Michael Higgs.