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FCC Telecom Service Provider Accessibility Certification Rules

Our friends at ACUTA (the higher education telecommunications administrators association) have posted an alert to colleges and universities that "charge students, tenants, or others for telephone service" (excluding institutions that allocate telephone service costs internally to academic and/or administrative departments) about new accessibility record-keeping certification requirements from the Federal Communications Commission (FCC):

Many colleges and universities have been receiving notifications from the FCC that they are required to file a certification that they are complying with recordkeeping requirements under the rules implementing Section 255 of the Communications Act, which governs accessibility to communications. This certification requirement is new in 2013, and any institution that is required to comply must make the certification by April 1.

As the brief explains in greater detail, the new FCC rules were intended to apply to telecom equipment manufacturers and service providers. However, the FCC determined that "service aggregators"--such as hotels, payphone operators, and apparently some colleges and universities--count as service providers, too, and thus need to certify that they are following the new regulations. I've pasted the core of the brief's explanation of what this means below:
 
Under the rules, service providers must ensure that their services are accessible to individuals with disabilities, if doing so is “readily achievable.” As of January 30, 2013, they also must maintain records of their efforts to meet this requirement. Finally, starting on April 1, service providers are required to submit a certification annually to the FCC that they are complying with the recordkeeping requirements.
 
The recordkeeping requirement covers the following areas:
  • The service provider’s efforts to consult with individuals with disabilities.
  • Descriptions of the accessibility features of the provider’s products and services.
  • Information about the compatibility of the products and services with peripheral devices or specialized customer equipment commonly used by people with disabilities to obtain access to the services.
These records must be kept until two years after the product or service no longer is offered. 
 
The certification must include the following:
  • A statement that the service provider “has established operating procedures that are adequate to ensure compliance with the recordkeeping rules and that it is keeping records accordingly.”
  • The name and contact information for the person or people authorized to resolve complaints.
  • The agent designated by the service provider to receive formal and informal complaints concerning compliance with accessibility requirements.

[...]

The certification must be filed electronically with the FCC at https://apps.fcc.gov/rccci-registry/. An entity filing a certification must provide an FCC registration number (also known as an FRN) and the password for the FRN to get access to the system. (FRNs can be assigned within minutes, but it can take two or three days to reset the password. An institution can obtain an FRN or search to see if it has an FRN at https://fjallfoss.fcc.gov/coresWeb/publicHome.do.)

 

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