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'Unnecessary'

Consumer Groups Concerned About Proposed IP CTS Rules, Question Claims of Fraud, Abuse

Groups representing the deaf and hard of hearing raised concerns about FCC proposals they say could mean some who need the IP captioned telephone service (IP-CTS) will have a harder time enrolling. The FCC proposed in a Feb. 14 Further NPRM to require providers to add user account identifiers to call records submitted for compensation, and allow users to receive service for up to two weeks while their identities are verified (see 1902140032). Comments were posted Tuesday in docket 03-123.

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The American Speech-Language-Hearing Association (ASHA) said members have been working with the FCC on ensuring the integrity of the IP CTS program, but the proposals in the FNPRM weren’t part of the discussion. The FCC should provide more information on the problem it’s trying to solve, ASHA commented. “Both the individual account identifiers on each call and the verification proposal seem to be solutions in search of problems,” the group said. “Requiring individual identifiers for each call seems unnecessary when the device and end-user are known to the provider and the FCC.” The burden ultimately will fall on consumers, the group said.

The Commission has not established that there is waste, fraud, and abuse in the IP CTS program,” said 12 groups representing people with hearing loss. “Without empirical evidence that consumers have misused IP CTS” the FCC should “maintain the ease of registering for and using IP CTS and enable consumer choice by facilitating competition among providers.” The Hearing Loss Association of America, Telecommunications for the Deaf and Hard of Hearing, the National Association of the Deaf and the Association of Late-Deafened Adults were among those who signed the comments.

But ClearCaptions, which provides IP CTS service, said the cost of collecting and providing the information likely will be minimal: “ClearCaptions has assigned a unique account identifier to each customer and is capable of including that number in call detail records.” But the provider said more than a two-week grace period may be needed, especially for ported customers. “If there are delays in the new provider’s re-verification of the IP CTS customer, two weeks may not be adequate time to complete identity verification,” the company said: “The IP CTS provider should not be penalized (denied compensation) for services provided to a ported customer who was initially verified by the original IP CTS provider and whose re-verification takes more than two weeks.”

Hamilton Relay, also an IP CTS provider, raised privacy concerns. Providers should be “given the flexibility to choose which unique account identifier” they will report, the company said: “For privacy reasons … Hamilton recommends that the Commission encourage providers to use a unique account identifier that contains non-personally identifiable information about the user.”