Federal Communications Commission FCC 23-50
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Access to Video Conferencing
Implementation of Sections 716 and 717 of the 
Communications Act of 1934, as Enacted by the 
Twenty-First Century Communications and Video 
Accessibility Act of 2010
Telecommunications Relay Services and Speech-
to-Speech Services for Individuals with Hearing 
and Speech Disabilities
Petition of Sorenson Communications, LLC for a 
Limited Waiver of the Privacy Screen Rule)
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)CG Docket No. 23-161
CG Docket No. 10-213
CG Docket No. 03-123
REPORT AND ORDER, NOTICE OF PROPOSED RULEMAKING, AND ORDER
Adopted:  June 8, 2023 Released:  June 12, 2023
Comments Due: [30 Days After Publication in the Federal Register]
Reply Comments Due: [60 Days After Publication in the Federal Register]
By the Commission:  Chairwoman Rosenworcel and Commissioner Starks issuing separate statements.
TABLE OF CONTENTS
Heading Paragraph #
I. INTRODUCTION...................................................................................................................................1
II. BACKGROUND.....................................................................................................................................6
A. Growth of Video Conferencing ........................................................................................................6
B. Accessibility Concerns......................................................................................................................8
C. Application of the CVAA to Video Conferencing .........................................................................12
D. TRS and Video Conferencing.........................................................................................................21
III. REPORT AND ORDER........................................................................................................................27
IV. NOTICE OF PROPOSED RULEMAKING .........................................................................................42
A. Amending Part 14 to Improve the Accessibility of Video Conferencing.......................................44
1. Performance Objectives............................................................................................................44
2. Safe Harbor Technical Standards .............................................................................................65
B. Providing TRS in Video Conferences.............................................................................................68
1. Authorizing the Integrated Provision of TRS in Video Conferences.......................................68
2. Integrating the Provision of VRS with Video Conferencing....................................................74
3. VRS and Video Conferencing—User Validation and Call Detail ...........................................77
4. VRS and Video Conferencing—CA-Related Issues ................................................................81Federal Communications Commission FCC 23-50
25. VRS and Video Conferencing—Privacy Screen Rule .............................................................87
6. Integrating Other Types of TRS with Video Conferencing .....................................................90
7. Rules Applicable to All TRS....................................................................................................95
8. Costs and Benefits ..................................................................................................................103
C. Amendment of the Commission’s Rule on Multiple CAs ............................................................108
D. Advancing Diversity, Equity, Inclusion, and Accessibility..........................................................112
V. ORDER................................................................................................................................................113
VI. PROCEDURAL MATTERS...............................................................................................................120
VII. ORDERING CLAUSES.....................................................................................................................129
Appendix A – List of Commenters
Appendix B – Proposed Rules
Appendix C – Initial Regulatory Flexibility Analysis
I. INTRODUCTION
1. Prior to the outbreak of COVID-19 in early 2020, video conferencing represented an 
important but still nascent mode of communication.  That is not the case today.  As the world adapted to a 
historic pandemic and the associated quarantine measures, video conferencing took on a central and 
critical role in the day-to-day functioning of American society.1  Further, this change in how we 
communicate has outlasted the pandemic quarantine measures—employers, schools, government 
agencies, doctors, other organizations, and the general public now rely on video conferencing as an 
essential communications tool.  It is difficult to overstate how thoroughly video conferencing has become 
embedded in the fabric of post-pandemic society.2  
2. Today, video conferencing is routinely used by millions of people for workplace 
conferences, classes, and conversations with family and friends.  Yet, for many people with disabilities, 
making effective use of video conferencing continues to be a challenge.  Reported problems include lack 
of—or inferior—captioning; ineffective display of sign language interpreters; inability of blind or low-
vision users to find and use volume controls; and insufficient user control of accessibility tools.  Further, 
there is no easy way to use telecommunications relay services (TRS) on video conferencing platforms.3  
Currently, for a video conference participant to use video relay service (VRS),4 a communications 
1 See, e.g., American Council of the Blind (ACB), Comments, CG Docket No. 10-213 and GN Docket No. 21-140, 
at 1 (filed June 21, 2022) (ACB 2022 IVCS Refresh Comments) (stating that, during the pandemic, “technology and 
communications services have played an increasingly integral role in all aspects of our lives. . . . [T]he ability to 
access and communicate using video services have become ubiquitous and essential in the United States”).
2 See, e.g., Sorenson Communications, LLC (Sorenson), Reply Comments, CG Docket No. 10-213 and GN Docket 
No. 21-140, at 1 (filed July 18, 2022) (Sorenson 2022 IVCS Refresh Reply Comments) (“[F]ull access to healthcare 
must now include access to telehealth; full participation in work life and in our communities now means regular 
video meetings.”). 
3 Section 225 of the Communications Act of 1934, as amended (the Act), requires the Federal Communications 
Commission (FCC or Commission) to ensure the availability, to individuals who are deaf, hard of hearing, 
deafblind, or have a speech disability, of TRS that are functionally equivalent to voice communication services used 
by persons without hearing and speech disabilities “to the extent possible and in the most efficient manner.”  47 
U.S.C. § 225(a)(3), (b)(1).  These services are supported by the Interstate Telecommunications Relay Services Fund 
(TRS Fund), which is collected from providers of telecommunications service, interconnected Voice over Internet 
Protocol (VoIP) service, and non-interconnected VoIP service, and is administered by a Commission contractor.  
See 47 CFR § 64.604(c)(5).
4 VRS is a form of TRS that allows people with hearing or speech disabilities who use sign language to 
communicate with voice telephone users through video equipment.  The video link allows a communications 
assistant to view and interpret the party’s signed conversation back and forth with a voice caller.  47 CFR 
§ 64.601(a)(51).Federal Communications Commission FCC 23-50
3assistant (CA) must dial in separately with a voice-only connection—an unsatisfactory arrangement, even 
when a dial-in connection is available.5   
3. In this item, we take several steps to ensure that video conferencing is accessible to all.  
In the Report and Order, we resolve a long-standing legal question that has caused uncertainty for 
industry and hindered the use of video conferencing by people with disabilities.  Under section 716 of the 
Act, as amended by the Twenty-First Century Communications and Video Accessibility Act of 2010 
(CVAA),6 “interoperable video conferencing service” (IVCS) and equipment used for IVCS must be 
accessible to and usable by people with disabilities, unless that requirement is not achievable.7  The Act 
defines “interoperable video conferencing service” as “a service that provides real-time video 
communications, including audio, to enable users to share information of the user’s choosing.”8  
Revisiting the Commission’s previously stated views9 in light of changed circumstances, we find no 
persuasive reason to modify or limit the scope of this statutory definition, which includes services 
provided on a variety of commonly used video conferencing platforms.  We conclude that section 716’s 
accessibility requirements and Part 14 of our rules10 apply to all services and equipment included in the 
statutory definition of IVCS. 
4. In the Notice of Proposed Rulemaking, we propose to amend our Part 14 rules to define 
more specifically some of the steps needed to make interoperable video conferencing service accessible to 
people with disabilities.  In addition, we propose to amend our TRS rules to facilitate the use of VRS in 
video conferences, and we seek comment on whether analogous changes are needed with respect to other 
forms of TRS.  Finally, we propose a rule amendment to clarify when multiple CAs may be assigned to 
TRS calls (whether video conferences or not) that involve users of different forms of TRS.  
5. In the Order, we grant TRS providers a limited, conditional waiver of the VRS privacy 
screen rule,11 which restricts VRS users’ ability to turn off their video cameras when not actively 
participating in a video conference.12
5 See Recommendation of the Federal Communications Commission (FCC) Disability Advisory Committee (DAC) 
on Telecommunications Relay Service (TRS) Use on Video Conferencing Platforms, at 2-3 (Feb. 24, 2022), 
https://www.fcc.gov/file/22912/download (DAC Video Conferencing Report).  This is beginning to change.  See 
Sorenson, Integrated Sorenson Interpreting for Zoom, https://sorenson.com/solutions/video-relay-services/sorenson-
for-zoom/ (last visited Apr. 24, 2023) ( Sorenson-for-Zoom).
6 Pub. L. No. 111-260, 124 Stat. 2751 (2010).
7 47 U.S.C. § 617(a)(1), (b)(1); id. § 153(1).
8 Id. § 153(27).
9 See Implementation of Sections 716 and 717 of the Communications Act of 1934, as Enacted by the Twenty-First 
Century Communications and Video Accessibility Act of 2010; Amendments to the Commission’s Rules 
Implementing Sections 255 and 251(a)(2) of the Communications Act of 1934, as Enacted by the 
Telecommunications Act of 1996; Accessible Mobile Phone Options for People who are Blind, Deaf-Blind, or Have 
Low Vision, CG Docket No. 10-213, WT Docket No. 96-198, CG Docket No. 10-145, Report and Order and Further 
Notice of Proposed Rulemaking, 26 FCC Rcd 14557, 14576, para. 47 (2011) (2011 ACS Order or 2011 ACS Further 
Notice).  As explained in more detail below, in the 2011 ACS Order the Commission assumed that the word 
“interoperable” needed to be defined independently of the term “interoperable video conferencing service.”
10 See 47 CFR Pt. 14.
11 Id. § 64.604(a)(6).  
12 See Petition of Sorenson Communications, LLC for a Limited Waiver of the Privacy Screen Rule for Piloting 
VRS Integration with Video Conferencing Services, CG Docket Nos. 03-123 and 10-51 (filed Dec. 19, 2022), 
https://www.fcc.gov/ecfs/document/12190888126091/1 (Sorenson Petition).Federal Communications Commission FCC 23-50
4II. BACKGROUND
A. Growth of Video Conferencing
6. Since the March 2020 outbreak of the COVID-19 pandemic in the United States, video 
conferencing has grown from a niche product to a central pillar of our communications infrastructure.13  
In early 2020, after governments, businesses, and schools adopted social distancing requirements,14 
organizations, families, and individuals turned to video conferencing as a work-around.15  Use of video 
conferencing increased exponentially,16 becoming “a significant part of the technology solution replacing 
in-person meetings, conference calls, and traditional classroom instruction.”17
7. The new social interaction paradigm occasioned by the pandemic appears to have 
permanently altered the norms of modern communication in the workplace, healthcare, education, social 
interaction, civic life, and more.18  As the Consumer Technology Association (CTA) observes, the 
pandemic “amplified and accelerated the reality that much of Americans’ lives take place online using an 
increasing variety of connected devices.”19  In CTA’s 2021 member survey, for example, roughly 80% of 
respondents strongly agreed that their employees benefitted from a hybrid work environment.20  In a 2022 
study, the Pew Research Center found that 78% of remote workers use video or online conferencing 
13 See, e.g., Rudly Raphael, Zoom into the Future of Videoconferencing, Greenbook.org (Nov. 6, 2022), 
https://www.greenbook.org/mr/executive-insights/zoom-into-the-future-of-video-conferencing/; Max Kalmykov, 
The Web Conferencing Boom: Covid-19’s Effect on the Video Call Market, Dataart.com (July 16, 2020), 
https://www.dataart.com/blog/the-web-conferencing-boom-covid-19-s-effect-on-the-video-call-market; Roger 
Dooley, How Zoom Conquered Video Conferencing, Forbes (Sept. 30, 2020), https://www.forbes.com/sites/
rogerdooley/2020/09/30/how-zoom-conquered-video-conferencing/?sh=1af02f25a977. 
14 See, e.g., Hristina Byrnes & Grant Suneson, Coronavirus Update: Here’s Every State’s Rules for Staying Open 
and Social Distancing, FDL Reporter  (Jul.26, 2020), https://www.fdlreporter.com/story/money/2020/07/26/
coronavirus-everystates-rules-for-staying-open-and-social-distancing/112351868/ (providing a state-by-state 
breakdown of social distancing requirements, face covering mandates, and capacity limitations on businesses); 
Geoff Whitmore, Update on New York Travel Ban, Forbes.com (Aug. 12, 2020), https://www.forbes.com/sites/
geoffwhitmore/2020/08/12/update-on-new-yorks-extensive-travelrestrictions/#64308ff530df (discussing quarantine 
requirements for domestic travelers to New York, New Jersey, and Connecticut); Elinor Aspegren, Back to school? 
Despite CDC recommendations, most major schools going online as COVID-10 cases spike, USA Today (July 23, 
2020), https://www.usatoday.com/story/news/education/2020/07/23/covid-back-toschool-online-fall-semester-2020-
reopening/5472142002/.
15 Recommendation of the FCC Disability Advisory Committee Prepared by the Pandemic Communication Access 
Working Group, “Concerns and Lessons Learned regarding Communication Access for People with Disabilities 
During the Pandemic,” at 4 (adopted Sept. 9, 2021) (DAC Pandemic Communications Access Report).
16 Id.  For example, between March 14-21, 2020, Google Play and Apple’s iOS operating system recorded 62 
million downloads of video conferencing apps, an all-time high.  See Lexi Sydow, Video Conferencing Apps Surge 
from Coronavirus Impact (March 30, 2020), https://www.data.ai/en/insights/market-data/video-conferencing-apps-
surge-coronavirus/.  Additionally, use of web and video conferencing programs reportedly increased 500% in the 
first two months of the COVID-19 pandemic.  See Mandi Sadler, Covid-19 Software Industry Statistics (April 9, 
2020) https://www.trustradius.com/vendor-blog/covid-19-software-industry-data-and-statistics.
17 DAC Pandemic Communications Access Report at 4.
18 See Eric Griffith, Hate Being on Live Calls? Sorry, They’re Here to Stay (Aug. 29, 2022), https://www.pcmag.
com/news/hate-being-on-live-video-calls-sorry-theyre-here-to-stay.
19 Consumer Technology Association (CTA), Comments, CG Docket No. 10-213 and GN Docket No. 21-140, at 3 
(filed June 21, 2022) (CTA 2022 IVCS Refresh Comments).
20 Consumer Technology Association Member Survey, Future of Work: 2021 at 8 (Oct. 2021), https://shop.cta.tech/
products/future-of-work-2021-cta-member-survey. Federal Communications Commission FCC 23-50
5services at least “sometimes,” with more than half using such services “often.”21  CTA also notes that 
“video conferencing has been a key component of the move to telehealth,” which it calls a “great 
equalizer in a healthcare system where social and economic disparities continue to affect patient care.”22  
To help students and teachers participate in the large-scale shift to remote learning, the Commission 
established the $7.171 billion Emergency Connectivity Fund Program, which helps schools and libraries 
purchase advanced telecommunications equipment and services.23  For millions of Americans, video 
conferencing has become a mainstay of their business and personal lives.  
B. Accessibility Concerns
8. With the growing use of video conferencing has come heightened concern about 
accessibility.24  According to the Accessibility Advocacy and Research Organizations (AARO), a broad-
based coalition of disability advocacy and research groups:
Once the pandemic forced a shift to remote working, many of the 13% of 
American adults who have hearing difficulties found themselves cut off 
from colleagues during calls on Zoom, Microsoft Teams, and other 
virtual platforms.  Faces on the screen are often too small for lipreading, 
and a lack of captions can make meaningful interaction impossible.25  
21 Ruth Igielnik, As telework continues for many U.S. workers, no sign of widespread ‘Zoom fatigue’ (May 4, 2022), 
https://www.pewresearch.org/fact-tank/2022/05/04/as-telework-continues-for-many-u-s-workers-no-sign-of-
widespread-zoom-fatigue/. 
22 In the mental health field, shortly after the COVID-19 outbreak, the American Psychological Association reported 
that 92% of its clinicians had pivoted to providing at least some remote services, either via the phone or on video 
conferencing services, and 76% provided services entirely by remote means.  American Psychological Association, 
Psychologists embrace telehealth to prevent the spread of COVID-19 (June 5, 2020), https://www.apaservices.org/
practice/legal/technology/psychologists-embrace-telehealth.  In 2022, 31% of clinicians continued to provide 
remote-only services while only 11% had returned to entirely in-person services.  More than 95% of clinicians 
reported that they intended to continue providing telehealth services even after the pandemic.  American 
Psychological Association, Psychologists struggle to meet demand amid mental health crisis, 2022 COVID-19 
Practitioner Impact Survey (Nov. 2022), https://www.apa.org/pubs/reports/practitioner/2022-covid-psychologist-
workload.
23 See FCC Emergency Connectivity Fund, https://www.fcc.gov/emergency-connectivity-fund (last visited March 2, 
2023).
24 See AARO, Comments, GN Docket No. 21-140, at 4 (filed June 7, 2021) (AARO 2021 CVAA Refresh 
Comments); CTA 2022 IVCS Refresh Comments at 4; Implementation of Sections 716 and 717 of the 
Communications Act of 1934, as Enacted by the Twenty-First Century Communications and Video Accessibility Act 
of 2010, CG Docket No. 10-213, Biennial Report to Congress as Required by the Twenty-First Century 
Communications and Video Accessibility Act of 2010 (Oct. 11, 2022), https://docs.fcc.gov/public/attachments/DA-
22-1075A1.pdf (2022 CVAA Report to Congress). 
25 Telecommunications for the Deaf and Hard of Hearing, Inc., et al., Comments on Public Notice, CG Docket No. 
10-213, at 8-9 (filed Apr. 4, 2022) (AARO 2022 CVAA Biennial Report Comments).  According to the National 
Institutes of Health, 30 million people aged twelve years or older in the United States have hearing loss in both ears, 
and 20 million people have voice disorders.  See National Institute on Deafness and Other Communication 
Disorders, Quick Statistics About Hearing (March 25, 2021), https://www.nidcd.nih.gov/health/statistics/quick-
statistics-hearing; Sofia Anastasiadou and Yasir Al Khalili, Hearing Loss (July 21, 2022), https://www.ncbi.nlm.nih.
gov/books/NBK542323/; Yasmin Naqvi and Vikas Gupta, Functional voice disorders (Oct. 24, 2022), 
https://www.ncbi.nlm.nih.gov/books/NBK563182/.Federal Communications Commission FCC 23-50
6Small screens also make it difficult for users who are deaf or hard of hearing to identify visual clues, such 
as when a colleague is about to speak.26  When automatic captions are provided on video conference 
platforms, the quality and timeliness of the transcription varies widely.27  In a 2021 survey of 330 people 
with vision disabilities, approximately 57% of respondents found telehealth to be inaccessible in some 
way.28  Further, users who are blind or have limited vision describe struggles to find and toggle volume 
controls.29 
9. In recent years, various accessibility features have been introduced by a number of video 
conferencing providers.  Depending on the platform, these features may include screen reader and braille 
display support, a choice of third-party live captioning or synchronous automatic captioning, multi-
pinning features, and “spotlighting” a speaker so that all participants know who is speaking.30  Some 
services also offer keyboard accessibility features, high-contrast visual elements, customizable 
notifications, verbosity controls, and other accessibility innovations.31
10. However, the accessibility of video conferencing services remains limited for many 
users.  In its February 2022 recommendations to the Commission, the Disability Advisory Committee 
highlighted the inconsistent performance of video conferencing providers in making their platforms 
accessible to people who are deaf, hard of hearing, or deafblind.  In recommending Commission action to 
facilitate TRS access on such platforms, the committee stated:
[S]ome video conferencing platforms incorporate live closed captioning 
using automatic speech recognition (ASR).  However, these solutions are 
not available for all platforms or on all video conferences for platforms 
that do provide them. . . . When ASR-based captions are available, they 
may be of insufficient quality. . . . Some platforms do not allow users to 
customize caption size, color, opacity, and other critical settings to 
ensure readability. And some platforms lack sufficient user control to 
ensure that interpreters and signers are properly displayed and can be 
properly pinned on users’ displays.32
11. Commenters also point out that “users with disabilities often are not in a position to 
dictate what video conferencing service” the host of the conference should use.33  For example, a patient 
who is deaf may not be able to obtain healthcare because the doctor’s telehealth conferencing platform 
26 See Mark Ray, Why Remote Work Can Be Hard For Hard-Of-Hearing People, Forbes (Mar. 29, 2022), 
https://www.forbes.com/sites/nextavenue/2021/09/02/why-remote-work-can-be-hard-for-hard-of-hearing-
people/?sh=76a3d4c46d71.
27 AARO 2022 CVAA Biennial Report Comments at 9-10.
28 Rhoads, C.R., Bleach, K., Chatfield, S., & Camarillo, P.M., The Journey Forward: Impact of COVID-19 on 
Blind, Low Vision, and Deafblind U.S. Adults (2022), https://www.afb.org/research-and-initiatives/flatten-
inaccessibility-survey/journey-forward.
29 American Foundation for the Blind (AFB), Public Notice Comments, CG Docket No. 10-213, at 3 (filed Apr. 4, 
2022) (AFB 2022 CVAA Biennial Report Comments).
30 2022 CVAA Report to Congress at para. 22; see also CTA 2022 IVCS Refresh Comments at 7-8; CTIA, 
Comments, CG Docket No. 10-213 and GN Docket No. 21-140, at 2 (filed June 21, 2022) (CTIA 2022 IVCS 
Refresh Comments).
31 2022 CVAA Report to Congress at para. 24.
32 DAC Video Conferencing Report at 2-3.
33 Accessibility Advocacy and Research Organizations, Reply Comments, CG Docket No. 10-213 and GN Docket 
No. 21-140, at 4 (filed July 18, 2022) (AARO 2022 IVCS Refresh Reply Comments at 4).Federal Communications Commission FCC 23-50
7does not enable an effective connection to a sign language interpreter or VRS.34  A student who is blind 
may be unable to fully participate in a remote class discussion if information provided through a “share 
screen” feature is not accessible to screen readers.35  In these and other scenarios, a person with a 
disability often has no opportunity to request a different, accessible video conferencing system.
C. Application of the CVAA to Video Conferencing
12. Under the CVAA, enacted in 2010, providers of advanced communications services 
(ACS) and manufacturers of equipment used for ACS must make such services and equipment accessible 
to and usable by people with disabilities, unless these requirements are not achievable.36  Service 
providers and manufacturers may comply with section 716 of the Act either by building accessibility 
features into their services and equipment37 or by using third-party applications, peripheral devices, 
software, hardware, or customer premises equipment (CPE) that are available to individuals with 
disabilities at nominal cost.38  If accessibility is not achievable through either of these means, then 
manufacturers and service providers must make their products and services compatible with existing 
peripheral devices or specialized CPE commonly used by people with disabilities to achieve access, 
subject to the achievability standard.39    
13. The Act defines “advanced communications services” as: 
(A) interconnected VoIP service; (B) non-interconnected VoIP service; 
(C) electronic messaging service; (D) interoperable video conferencing 
service; and (E) any audio or video communications service used by 
inmates for the purpose of communicating with individuals outside the 
correctional institution where the inmate is held, regardless of technology 
used.40 
“Interoperable video conferencing service,” in turn, is defined as:
A service that provides real-time video communications, including audio, 
to enable users to share information of the user’s choosing.41  
34 2022 CVAA Report to Congress at para. 27.
35 See Letter from Everette Bacon, National Federation for the Blind, to Marlene H. Dortch, FCC, CG Docket Nos. 
10-213 and 05-231, MB Docket No. 12-108 (filed Aug. 19, 2022). 
36 47 U.S.C. § 617(a)(1), (b)(1); 47 CFR § 14.10(b) (defining “achievable”).  
37 47 U.S.C. § 617(a)(2)(A), (b)(2)(A).
38 Id. § 617(a)(2)(B), (b)(2)(B).  By contrast, section 255 of the Act, which requires that providers of 
telecommunications service and manufacturers of telecommunications and customer premises equipment ensure that 
their services and equipment are accessible to and usable by people with disabilities, does not include a provision 
allowing service providers and equipment manufacturers to choose to meet their obligations by using third-party 
applications or equipment.  Id. § 255. 
39 Id. § 617(c).  ACS providers and equipment manufacturers are also subject to recordkeeping and reporting 
requirements established pursuant to section 717(a) of the Act.  Id. § 618(a); 2011 ACS Order, 26 FCC Rcd at 
14650-55, paras. 219-30.  For example, providers and manufacturers must maintain records of their efforts to ensure 
that their services and products are accessible (47 CFR § 14.31(a)), and must be prepared to demonstrate due 
diligence in exploring accessibility and achievability in response to complaints (id. § 14.36(a)). 
40 47 U.S.C. § 153(1).  Subparagraph (E) was added by the Martha Wright-Reed Just and Reasonable 
Communications Act of 2022, Pub. L. No. 117-338, 136 Stat. 6156 (2022).  The Commission is addressing this fifth 
subcategory in a separate proceeding.  See Incarcerated People’s Communications Services; Implementation of the 
Martha Wright-Reed Act; Rates for Interstate Inmate Calling Services, WC Dockets Nos. 23-62 and 12-375, Notice 
of Proposed Rulemaking and Order, FCC 23-19 (Mar. 17, 2023).
41 47 U.S.C. § 153(27).  Federal Communications Commission FCC 23-50
814. In adopting rules to implement section 716, the Commission incorporated without change 
the statutory definitions of ACS and the four then-existing types of ACS, including “interoperable video 
conferencing service.”42  However, in that 2011 rulemaking a question was raised as to what Congress 
meant by including the word “interoperable” as part of the term “interoperable video conferencing 
service.”43  Noting that the word “interoperable” had been inserted late in the CVAA drafting process, 
without explanation, and agreeing with some commenters that the word “cannot be read out of the 
statute,”44 the Commission found that the record before it was insufficient to decide the correct 
interpretation, and sought further comment on the issue.45  
15. Based on the record at that time, the Commission specifically invited comment on the 
following three possible definitions of the word “interoperable” as used in this context:
•Able to function inter-platform, inter-network, and inter-provider;
•Having published or otherwise agreed-upon standards that allow for manufacturers or 
service providers to develop products or services that operate with other equipment or 
services operating pursuant to the standards; or
•Able to connect users among different video conferencing services, including VRS.46 
16. In response to the 2011 ACS Further Notice, commenters did not reach consensus on any 
of the three suggested alternatives.47  Some commenters argued that the first of the three suggested 
definitions was too narrow,48 while others contended that it was the only appropriate alternative.49  The 
American Council of the Blind (ACB) and the American Foundation for the Blind (AFB) asserted that the 
term “‘interoperable’ should be read to refer to two-way, non-asynchronous video communication.”50
17. Recently, the Commission refreshed the record on this matter.  First, in April 2021, the 
Consumer and Governmental Affairs, Media, and Wireless Telecommunications Bureaus issued a joint 
Public Notice seeking comment generally on whether any updates were needed to the Commission’s rules 
implementing the CVAA and inviting stakeholders to “provide input on aspects of the Commission’s 
CVAA implementation that are working well, on specific areas in which commenters believe 
improvements are needed, and on requirements that may not be serving their intended purpose or have 
42 47 CFR § 14.10(m). 
43 2011 ACS Order, 26 FCC Rcd at 14576, para. 46.  As discussed below, the legislative history is silent as to why 
the word “interoperable” was added.  Despite the late addition of the word, the definition of IVCS remained 
unchanged.  See infra paras. 32-33.
44 2011 ACS Order, 26 FCC Rcd at 14576, para. 47.
45 See 2011 ACS Further Notice, 26 FCC Rcd at 14684-87, paras. 301-05.
46 Id. at 14686, para. 303.
47 Commenters on the relevant issues raised in the 2011 ACS Further Notice are listed in Appendix A, and the 
comments are cited herein as “[Name] 2011 IVCS Comments” or “[Name] 2011 IVCS Reply Comments.”
48 Rehabilitation Engineering Research Center on Telecommunications Access (RERC-TA) 2011 IVCS Comments 
at 4-5 (stating that it is virtually impossible for any service to be “inter-provider, inter-network, and inter-platform”); 
Consumer Groups and RERC-TA 2011 IVCS Reply Comments at 8-9 (stating that “video teleconferencing systems 
. . . are not meant to interoperate directly with each other”) (emphasis in original).
49 Microsoft Corporation 2011 IVCS Comments at 5-8; Voice on the Net Coalition 2011 IVCS Comments at 4 
(“The term ‘interoperable’ . . . should be defined as ‘able to engage across a wide range of platforms, network, and 
providers.’”); Consumer Electronics Association 2011 IVCS Comments at 12 (urging the Commission to define 
“interoperable” as “the ability to operate among different platforms, networks, and providers without special effort 
or modification by the end user”).
50 ACB and AFB 2011 IVCS Reply Comments at 5.Federal Communications Commission FCC 23-50
9been overtaken by new technologies.”51  In response, AARO commented that “the communications 
accessibility problem most cited by members of the Advocacy Organizations since the beginning of the 
COVID-19 pandemic has been the inaccessibility of modern IP-based multimodal platforms that offer an 
array of video, audio, and text communications functionality.”52  Some of the comments responding to the 
2021 CVAA Refresh Public Notice specifically addressed the interpretation of the term “interoperable 
video conferencing service.”  AARO, for example, urged the Commission to “simply clarify that the 
statutory definition of ‘interoperable video conferencing service,’ as a ‘service that uses real-time video 
communications, including audio, to enable users to share information of the user’s choosing,’ is an 
exhaustive articulation of what Congress intended to be covered.”53
18. Next, on April 27, 2022, the Commission’s Consumer and Governmental Affairs Bureau 
(CGB or Bureau) released a Public Notice specifically inviting additional comment on the questions 
posed in the 2011 ACS Further Notice as to the meaning of “interoperable video conferencing service.”54  
The Bureau also “invite[d] commenters to submit additional relevant information about what types of 
services are currently available in the video conferencing marketplace, the kinds of interoperability they 
currently offer, and how such developments may assist in reaching an interpretation of ‘interoperable 
video conferencing service’ that is consistent with the intent of Congress in enacting the CVAA.”55  The 
Commission also sought comment on how consumers access video conferencing services, whether 
various components of such services are accessible and usable, and “any other developments that the 
Commission should consider in resolving this issue.”56
19. Eight entities filed comments in response to the 2022 IVCS Refresh Public Notice; seven 
filed reply comments.57  Commenters provided substantial information about how video conferencing 
51 Consumer and Governmental Affairs, Media, And Wireless Telecommunications Bureaus Seek Update On 
Commission’s Fulfillment of The Twenty-First Century Communications and Video Accessibility Act, GN Docket 
No. 21-140, Public Notice, 36 FCC Rcd 7108, 7109 (2021) (2021 CVAA Refresh Public Notice).  Commenters on 
the relevant issues raised in the 2021 CVAA Refresh Public Notice are listed in Appendix A, and the comments are 
cited herein as “[Name] 2021 CVAA Refresh Comments” or “[Name] 2021 CVAA Refresh Reply Comments.”
52 See AARO 2021 CVAA Refresh Comments at 4.  AARO includes Telecommunications for the Deaf and Hard of 
Hearing, Inc. (TDI), American Association of the DeafBlind (AADB), American Deafness and Rehabilitation 
Association (ADARA), Association of Late-Deafened Adults (ALDA), California Coalition of Agencies Serving the 
Deaf and Hard of Hearing (CCASDHH), Cerebral Palsy and Deaf Organization (CPADO), Communications Service 
for the Deaf (CSD), Conference of Educational Administrators of Schools and Programs for the Deaf (CEASD), 
Cuesign, Inc., Deaf Seniors of America (DSA), Hearing Loss Association of America (HLAA), HEARD, National 
Association of the Deaf (NAD), National Black Deaf Advocates (NBD), National Cued Speech Association 
(NCSA), National Hispanic Latino Association of the Deaf (NHLAD), Northern Virginia Resource Center for Deaf 
and Hard of Hearing Persons (NVRC), Registry of Interpreters for the Deaf (RID), Rehabilitation Engineering 
Research Center on Technology for the Deaf and Hard of Hearing, Gallaudet University (DHH-RERC), 
Rehabilitation Engineering Research Center on Universal Interface & Information Technology Access (IT-RERC), 
Rehabilitation Engineering Research Center for Wireless Inclusive Technologies, Georgia Institute of Technology 
(Wireless RERC), and RIT/NTID Center on Access Technology (CAT).
53 AARO 2021 CVAA Refresh Comments at 13.
54 Consumer and Governmental Affairs Bureau Seeks to Refresh the Record on Interoperable Video Conferencing 
Services, CG Docket No. 10-213, Public Notice, DA 22-463, at 3 (CGB Apr. 27, 2022) (2022 IVCS Refresh Public 
Notice).
55 Id. at 5.
56 Id. 
57 Commenters responding to the 2022 IVCS Refresh Public Notice are listed in Appendix A, and the comments are 
cited herein as “[Name] 2022 IVCS Refresh Comments” or “[Name] 2022 IVCS Refresh Reply Comments.”Federal Communications Commission FCC 23-50
10services are used today, including the extent to which such services are accessible and usable.58  On the 
meaning of “interoperable video conferencing service,” AARO, ACB, and AFB commented that standard 
principles of statutory interpretation compel application of the statutory definition without modification.59  
The groups also urged the Commission to mandate more specific guidelines on implementing 
accessibility of these services.  CTIA and CTA countered that the word “interoperable” limits the scope 
of covered services.  CTIA proposed an interpretation that covered services are those that are able to 
function “inter-platform and inter-network.”60  Pointing to dictionary definitions, CTA argued that the 
Commission should define “interoperable” as “the ability to operate among different platforms, networks 
and providers without special effort or modification by the end user.”61  Under CTIA’s definition, a video 
conferencing service is “inter-platform” if users may access “the video conferencing service on multiple 
software platforms and operating systems, such as Google Android, Apple iOS, and Microsoft 
Windows.”62  A video conferencing service is “inter-network” if a user may “access a video conferencing 
service via the internet and on data networks, such as through a broadband connection like 4G LTE or 
5G.”63  In reply comments, ACB and AFB state that video conferencing services that are provided on only 
one operating system, such as Apple’s Facetime application, might not meet this definition of “inter-
platform” and so “would likely not meet this narrow definition of IVCS.”64
20.Performance Objectives.  In response to the 2022 IVCS Refresh Public Notice, 
commenters also disagree about whether additional performance objectives are necessary for IVCS.65  
CTA and CTIA argue that the existing performance objectives have produced accessible, innovative 
advanced communications services and equipment.66  AARO urges adoption of the following 
performance objectives specifically for IVCS:
•Built-in closed captioning functionality; 
58 See, e.g., AARO 2022 IVCS Refresh Comments at 1-2 (“IVCS now dominates communications in nearly all 
social, business, education, and healthcare settings.”); AFB 2022 IVCS Refresh Comments at 1 (“Accessibility of 
video communications has been an important factor in equal participation and inclusion of people who are blind or 
have low vision in many aspects of society throughout the pandemic.”); ClearCaptions, LLC (ClearCaptions) 2022 
IVCS Refresh Comments at 1 (“Video conferencing is central to communications and ever more important due to 
remote learning and social distancing.”). 
59AARO 2022 IVCS Refresh Comments at 4; ACB 2022 IVCS Refresh Comments at 2; AFB 2022 IVCS Refresh 
Comments at 2.
60 CTIA 2022 IVCS Refresh Comments at 2, 10.
61 CTA 2022 IVCS Refresh Comments at 11, 13.
62 CTIA 2022 IVCS Refresh Comments at 2 (emphasis added).
63 Id. at 2.
64 ACB and AFB 2022 IVCS Reply Comments at 1.
65 To implement ACS accessibility, section 716(e)(1)(A) of the Act provides that, in prescribing regulations for that 
section, the Commission shall “include performance objectives to ensure the accessibility, usability, and 
compatibility of advanced communications services and the equipment used for advanced communications services 
by individuals with disabilities.”  47 U.S.C. § 716(e)(1)(A).  In the 2011 ACS Order, the Commission adopted 
general, outcome-oriented performance objectives. 2011 ACS Order, 26 FCC Rcd at 14647, para. 211; see also 47 
CFR § 14.21.  In the 2011 ACS Further Notice, the Commission invited comment on whether to adopt more specific 
performance objectives with testable criteria.  2011 ACS Further Notice at 14689, para. 310.
66 CTA 2022 IVCS Refresh Comments at 1 (“The Commission’s flexible approach to advanced communications 
services, along with industry-advocate collaboration, is increasing access to video conferencing services for 
individuals with disabilities.”); CTIA 2022 IVCS Refresh Comments at 9 (“Maintaining the current performance-
objective approach to ACS, which provides clarity and flexibility while eschewing any technical mandates, will best 
ensure the continued evolution of video conferencing platforms and myriad accessibility features that meet the 
unique needs of people with disabilities.”).Federal Communications Commission FCC 23-50
11•Integrated support for third-party captioning services and third-party video interpreting 
services;
•Compatibility with and access to current and next-generation relay services;
•Accessible user interface controls for the activation and customization of all video 
conferencing features, including the appearance of captions, ASL interpreters, and cued 
language transliterators.67
ACB argues that the Commission should consider performance objectives “for people who are blind, low 
vision, or DeafBlind.”68  
D. TRS and Video Conferencing
21. Enacted in 1990, Title IV of the Americans With Disabilities Act, codified as section 225 
of the Communications Act, directs the Commission to “ensure that interstate and intrastate 
telecommunications relay services are available, to the extent possible and in the most efficient manner,” 
to eligible users in the United States.69  TRS are defined as “telephone transmission services” enabling 
such persons to communicate by wire or radio “in a manner that is functionally equivalent to the ability of 
[a person without hearing or speech disabilities] to communicate using voice communication services.”70  
There are currently three forms of Internet-based TRS:  (1) Video Relay Service (VRS) “allows people 
with hearing or speech disabilities who use sign language to communicate with voice telephone users 
through video equipment;”71 (2) Internet Protocol Relay Service (IP Relay) allows an individual with a 
hearing or speech disability to communicate with voice telephone users by transmitting text via the 
Internet;72 and (3) Internet Protocol Captioned Telephone Service (IP CTS) permits a person with hearing 
loss to have a telephone conversation while reading captions of what the other party is saying on an 
Internet-connected device.73
22.TRS Fund.  The provision of Internet-based TRS is supported by the TRS Fund.74  In 
addition, the TRS Fund supports interstate use of certain non-Internet-based relay services, which are 
provided through state TRS programs.75  Entities required to make contributions to the TRS Fund include 
67 AARO 2022 IVCS Refresh Comments at 15.
68 ACB 2022 IVCS Refresh Comments at 2 (asserting that the Commission should adopt “performance standards for 
people who are blind, low vision or DeafBlind” and “it is our strong preference that industry work together with 
advocates to develop international or national performance-based standards for ACS, including IVCS”).
69 47 U.S.C. § 225(b)(1).
70 Id. § 225(a)(3).
71 47 CFR § 64.601(a)(51); see also Structure and Practices of the Video Relay Service Program, CG Docket No. 
10-51, Report and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 5545, 5548-49, para. 2 (2011) 
(2011 VRS Call Practices Order).
72 47 CFR § 64.601(a)(23).  The text transmission is delivered to an IP Relay call center, where a CA converts the 
user’s text to speech for the hearing party and converts that party’s speech to text for the IP Relay user.  See 
Provision of Improved Telecommunications Relay Services and Speech-to-Speech Services for Individuals with 
Hearing and Speech Disabilities, CC Docket No. 98-67, Declaratory Ruling and Second Further Notice of Proposed 
Rulemaking, 17 FCC Rcd 7779, 7780-81, paras. 3-4 (2002) (2002 IP Relay Declaratory Ruling).
73 47 CFR § 64.601(a)(22); see Telecommunications Relay Services and Speech-to-Speech Services for Individuals 
with Hearing and Speech Disabilities; Internet-based Captioned Telephone Service, CG Docket No. 03-123, 
Declaratory Ruling, 22 FCC Rcd 379, 385, para. 14 (2007) (2007 IP CTS Declaratory Ruling).
74 47 CFR § 64.604(c)(5)(iii)(A).
75 Id. Federal Communications Commission FCC 23-50
12providers of telecommunications service, interconnected VoIP service, and non-interconnected VoIP 
service.76
23.DAC Report on TRS and Video Conferencing.  The structure of the Commission’s TRS 
program reflects the fact that, historically, most people have used wireline or wireless telephone networks 
to communicate remotely by voice.  Thus, North American Numbering Plan (NANP) telephone numbers 
are used to route calls between TRS users and hearing people,77 and the provision of TRS, to date, has 
typically included a voice-only telephone call, with originating and terminating NANP numbers.  To 
address concerns about the inaccessibility of video conferencing platforms, the Commission requested the 
Disability Advisory Committee to study the use of TRS on IVCS platforms.  In a report delivered in 
February 2022, the committee states:
It is impossible for users of most video conferencing platforms and most 
TRS providers to natively interconnect their preferred TRS provider to 
video conferencing platforms. Typically, TRS users can only 
interconnect their preferred TRS provider to a video conferencing 
platform by dialing in via the public switched telephone network 
(PSTN).78
24. Such a dial-in connection is often unavailable.79  Further, the committee explains, when a 
dial-in connection to a video conference is available, a TRS user may encounter multiple difficulties.80  
For example, the user must use two separately connected devices—one to participate in the video portion 
of the conference and the other to communicate with the TRS provider’s CA, who is only connected to 
the video conference via an audio-only dial-in connection.81  As a result, the user must navigate multiple 
user interfaces, which can cause confusion, fatigue, and other barriers to full participation in a video 
conference.82  The committee also explains that, if multiple TRS users join the conference, with each user 
having a double “presence” as the user’s video image and a CA’s voice-only icon, the result can increase 
the overall cognitive load for video conference hosts and participants to process discussion and facilitate 
shared dialogue.83  Further, the CA’s audio-only connection may result in poor audio quality, causing 
errors in interpretation or captioning.84  The committee also explains that it is not clear whether the 
Commission’s rules allow other methods of linking a TRS CA to a video conference.85
76 Id. 
77 For example, Internet-based TRS providers assign users NANP telephone numbers and maintain those numbers in 
the TRS Numbering Directory, which is used to route calls between Internet-based TRS users and end users served 
by other service providers.  47 CFR § 64.613; see also Telecommunications Relay Services And Speech-to-Speech 
Services For Individuals With Hearing And Speech Disabilities, E911 Requirements For IP-Enabled Service 
Providers, CG Docket No. 03-123, WC Docket No. 05-196, Report and Order and Further Notice of Proposed 
Rulemaking, 23 FCC Rcd 11591 (2008).
78 DAC Video Conferencing Report at 2.  Since the DAC recommendations were published, one VRS provider has 
reported that it now offers a means of integrating its provision of VRS with one video conferencing platform.  See 
Letter from John T. Nakahata, Counsel to Sorenson Communications, to Marlene H. Dortch, Secretary, FCC, CG 
Docket Nos. 10-51 and 03-123 (filed Mar. 10, 2023); Sorenson-for-Zoom.
79 DAC Video Conferencing Report at 2.
80 Id. at 3-4.
81 Id. at 3.
82 Id. 
83 Id. at 3-4.
84 Id. at 4.
85 Id. Federal Communications Commission FCC 23-50
1325. For all these reasons, the Disability Advisory Committee recommends that the FCC 
resolve these issues by:
•Facilitating a technical mechanism for TRS providers to natively interconnect TRS 
services, including video, audio, captioning, and text-based relay to video conferencing 
platforms;
•Ensuring that users can seamlessly initiate TRS from the provider of their choice on any 
video conferencing platform;
•Addressing the integration of CAs and the overall accessibility challenges of 
videoconferencing platforms; and
•Clarifying the legal ability of TRS providers to seek compensation for service provided 
for video conferences from the TRS Fund.86
26.Sorenson Petition.  On December 19, 2022, Sorenson filed a petition seeking a limited 
waiver of the VRS privacy screen rule.87  A visual privacy screen is a feature that prevents one party on 
the video leg of a VRS call from viewing the other party.88  The privacy screen rule prohibits a VRS CA 
from enabling a visual privacy screen or similar feature during a VRS call, and requires a VRS CA to 
disconnect a VRS call if the caller or called party enables a visual privacy screen or similar feature for 
more than five minutes or is otherwise unresponsive for more than five minutes.89  Sorenson seeks a 
partial waiver of the rule so that VRS users participating in video conferences are allowed to turn off their 
video connections when not presenting or for other reasons not related to inactivity.  On January 12, 2023, 
the Bureau sought comment on the Sorenson Petition.90  AARO, the lone commenter, supported grant of 
the Sorenson Petition.91  
III. REPORT AND ORDER
27. The rapid growth of video conferencing underscores the need to resolve lingering 
uncertainty as to the application of our accessibility rules in this area.  As recent comments make clear, 
the social shift born of the pandemic has altered the norms of modern communication.92  The record, other 
relevant FCC documents, and public sources indicate that substantial barriers to effective communication 
remain for many people with disabilities,93 supporting AARO’s general assessment that “some video 
conferencing services are accessible to some people with some disabilities in some contexts.”94  As video 
conferencing becomes further entrenched as an essential means of communication, it is of critical 
importance to resolve the extent to which these services are covered by section 716 and our accessibility 
86 Id. at 4-5.
87 Sorenson Petition.
88 See 47 CFR § 64.601(a)(52) (defining “visual privacy screen”).
89 See id. § 64.604(a)(6); see also 2011 VRS Call Practices Order, 26 FCC Rcd at 5567, para. 41.
90 See Consumer and Governmental Affairs Bureau Seeks Comment on Sorenson Communications, LLC’s Petition 
for a Limited Waiver of the Privacy Screen Rule for Video Relay Service, CG Docket Nos. 03-123 and 10-51, Public 
Notice, DA 23-28 (CGB Jan. 12, 2023).  Commenters on the relevant issues raised in the Sorenson Petition are listed 
in Appendix A, and the comments are cited herein as “[Name] Sorenson Petition Comments.”
91 AARO Sorenson Petition Comments, CG Docket Nos. 03-123 and 10-51, at 3-4 (filed Feb. 13, 2023).
92 See Eric Griffith, Hate Being on Live Calls? Sorry, They’re Here to Stay, (Aug. 29, 2022), https://www.pcmag.
com/news/hate-being-on-live-video-calls-sorry-theyre-here-to-stay.
93 See AARO 2021 CVAA Refresh Comments at 4; AFB 2022 IVCS Refresh Comments at 1 (“Barriers include 
navigating the user interface and accessing information shared by other users.”); AFB 2022 CVAA Report 
Comments at 2-3 (describing specific accessibility concerns with WebEx, Microsoft Teams, and the desktop version 
of Slack).
94 AARO 2022 IVCS Refresh Reply Comments at 4 (emphasis added).Federal Communications Commission FCC 23-50
14rules.  In the absence of clarity, service providers are left uncertain as to their obligations, and consumers 
face an inconsistent patchwork of accessibility features that limit their ability to reliably achieve effective 
communication.95 
28. In light of these changed circumstances, and taking into account comments in the record, 
we revisit the Commission’s previously stated views regarding the interpretation of the statutory term 
“interoperable video conferencing service.”96  The Act defines “interoperable video conferencing service” 
as “a service that provides real-time video communications, including audio, to enable users to share 
information of the user’s choosing.”97  As explained below, we find no persuasive reason to modify or 
limit the scope of the statutory definition of this term.  Therefore, we decline to revise Part 14 of our 
rules, which incorporates the statutory definition, and we conclude that Part 14 applies to all services and 
equipment that “provid[e] real-time video communications, including audio, to enable users to share 
information of the user’s choosing.”98  
29. By its terms, the statutory definition of “interoperable video conferencing service” 
encompasses a variety of video communication services that are commonly used today, or that may be 
used in the future, to enable two or more users to share information with one another.99  Nothing in the 
definition suggests that it is limited to services that are only suitable for particular kinds of users—e.g., 
professional users who need a wide selection of features and tools to conduct online meetings, or casual 
users who want to have spontaneous video conversations with friends.100  The definition also does not 
indicate an intention to exclude any service based on whether it is used primarily for point-to-point or 
multi-point conversations,101 or based on the type of device used to access the service.102  Similarly, based 
on the wording of this definition, its application does not depend on the options offered to users for 
connecting to a video conference (e.g., through a dial-up telephone connection or by broadband, through a 
95 Id. at 4.
96 See 2011 ACS Order, 26 FCC Rcd at 14576.  
97 Id. 
98 47 U.S.C. § 153(27).
99 In 2011, the Commission interpreted a qualifying phrase in the definition—“to enable users to share information 
of the user’s choosing”—to mean that services “providing real-time video communications, including audio, 
“between two or more users” would be included, “even if they can also be used for video broadcasting purposes 
(only from one user).”  2011 ACS Order, 26 FCC Rcd at 14578, para. 50 (emphasis in original).  However, a service 
that provides real-time video and audio communications “only from one user” (i.e., “video broadcasting”) would not 
meet the definition of “interoperable video conferencing service.”  Id. (emphasis in original).
100 See, e.g., Edgar Cervantes, Zoom vs Facetime:  Which is right for you? (Jan. 23, 2022), Android Authority, 
https://www.androidauthority.com/zoom-vs-facetime-1106307/ (explaining that some “video calling services are 
made with very different users in mind”).
101 See Dana Miranda and Rob Watts, What Is Video Conferencing?, Forbes Advisor (updated Aug. 6, 2022), 
https://www.forbes.com/advisor/business/what-is-video-conferencing/ (What Is Video Conferencing) (stating that a 
video conference can be point-to-point, i.e., “[a] one-on-one conversation involving two participants in different 
locations,” or multi-point, i.e., “a conversation that involves three or more people in at least two locations”).
102 See Julia Kagan, Video Conferencing: How It Works, How to Use It, Top Platforms, Investopedia (updated June 
2, 2022), https://www.investopedia.com/terms/v/video-conferencing.asp (noting that “individuals may use web 
cameras connected to or built into laptops, tablets, or desktop computers, as well as [s]martphones and other 
connected mobile devices equipped with cameras,” while “[s]ome businesses use dedicated video conferencing 
rooms that have been equipped with high-grade cameras and screens to ensure the conversation is clear and with 
limited technical faults.”); see also What Is Video Conferencing.Federal Communications Commission FCC 23-50
15downloadable app or a web browser),103 what operating systems or browsers their devices may use, 
whether the service works with more than one operating system, or whether the service may be classified 
as offered to the public or to a private group of users (such as a telehealth platform).  What matters is that 
two or more people can use the service to share information with one another in real-time, via video. 
30. As AARO and AFB explain, narrowing the scope of our Part 14 rules to a more limited 
class of services by importing our own definition of “interoperable” would bring those rules into conflict 
with the definition mandated by Congress.104  In terms of our codified rules, this conclusion maintains the 
status quo, as the statutory definition of “interoperable video conferencing service” has been incorporated 
in the Commission’s rules for more than a decade.105  
31. While the Commission stated in 2011 that it “must determine [the] meaning [of 
‘interoperable’] in the context of the statute,”106 in light of the further comments we received we conclude 
that, as the Supreme Court has repeatedly held, “‘[w]hen a statute includes an explicit definition, we must 
follow that definition,’ even if it varies from a term’s ordinary meaning.”107  Here the interpretation of the 
statutory term has already been given by the statutory definition:  IVCS is “a service that provides real-
time video communications, including audio, to enable users to share information of the user’s choosing.”  
Because that definition does not include the word “interoperable,” it is unnecessary to construe that word 
separately in this context.108
32. The legislative history of the CVAA also supports our conclusion that we may rely on the 
statutory definition of “interoperable video conferencing service” without further elaboration on the word 
“interoperable.”  As the Commission noted in 2011, early versions of the legislation used the term “video 
conferencing service,” without the word “interoperable.”109  The term was left unchanged in the House of 
103 See What Is Video Conferencing (explaining that certain “services require all participants to download software if 
they want to send audio or video,” while others permit users to “start a meeting without creating an account or 
downloading software”).
104 AFB Comments at 2; AARO Comments at 5 (“The Commission may not impose further limitations on the scope 
of IVCS beyond those limitations explicitly provided by Congress.”). 
105 47 CFR § 14.10(m); 2011 ACS Order, 26 FCC Rcd at 14708-09 (adopting the statutory definition of IVCS). 
106 2011 ACS Order, 26 FCC Rcd at 14577, para. 47.
107 Tanzin v. Tanvir, 141 S. Ct. 486, 490 (2020) (quoting Burgess v. United States, 553 U.S. 124, 130 (2008)); see 
also Stenberg v. Carhart, 530 U.S. 914, 942 (2000).  As Justice Cardozo explained in Fox v. Standard Oil Co. of 
N.J., 294 U.S. 87, 95-96 (1935):
There might be force in this suggestion [that the Court should interpret a defined 
term in accord with its ordinary usage] if the statute had left the meaning of its 
terms to the test of popular understanding.  Instead, it has attempted to secure 
precision and certainty by rejecting a test so fluid and indeterminate and 
supplying its own glossary. . . . In such circumstances definition by the average 
man or even by the ordinary dictionary with its studied enumeration of subtle 
shades of meaning is not a substitute for the definition set before us by the 
lawmakers with instructions to apply it to the exclusion of all others.  
108 AARO 2022 IVCS Refresh Comments at 5 (stating that the CVAA “affords the Commission no latitude to 
interpret the term ‘interoperable’ separately from the statute’s explicit definition of ‘interoperable video 
conferencing service’”).  In cases of circularity—where the statutory term and the statutory definition of that term 
include a common word—it might be appropriate for an agency to interpret the common word.  That is not the case 
here because “interoperable” does not appear in the statutory definition.
109 2011 ACS Order, 26 FCC Rcd at 14576, para. 46.Federal Communications Commission FCC 23-50
16Representatives committee report on  H.R. 3101, released in July 2010.110  However, in the Senate report 
on S. 3304, released in December 2010, the Senate Committee on Commerce, Science, and 
Transportation added the word “interoperable” to “video conferencing service.”111  The Commission has 
found nothing in the legislative history of the CVAA to explain why the word was added, or what that 
change was meant to communicate, if anything.  “The interpretation of statutes cannot safely be made to 
rest upon mute intermediate legislative maneuvers.”112
33. Additionally, nothing in the legislative history suggests that Congress intended for the 
insertion of “interoperable” in the defined term to change the draft bill’s existing definition of “video 
conferencing service.”  The definition remained the same in all versions, even when the term it was 
defining metamorphosed without explanation.113  This compels us to conclude that, whatever reason the 
Senate Committee may have had for altering the term used to describe the service, there was no intent to 
alter the definition of that term or to require separate interpretation of any word within that defined term.
34.Alternative Suggested Definitions.  We find unpersuasive the alternative definitions of 
“interoperable video conferencing service” that various commenters proffer in lieu of the statutory 
definition.114  CTA continues to advocate a proposal advanced in 2011:  that covered services be limited 
to those that have “the ability to operate among different platforms, networks and providers without 
special effort or modification by the end user.”115  At that time, the Commission expressed concern that 
“this proposed definition would exclude virtually all existing video conferencing services and equipment 
from the accessibility requirements of Section 716, which we believe would be contrary to Congressional 
intent.”116  In its 2022 comments, citing the development of standards that improve interoperability, CTA 
suggests that its proposed definition would include a number of commonly used video services such as 
Webex, Google Meet, and BlueJeans by Verizon.117  However, CTA emphasizes that its approach “will 
ensure that only the subset of video conferencing services that are genuinely interoperable is covered 
under section 716.”118
35. CTIA suggests a modified version of this formulation that would limit covered services 
to those that can “function inter-platform and inter-network.”119  Under CTIA’s proposal:
110 See Twenty-First Century Communications and Video Accessibility Act of 2010, H. Rept. 111-563, 111th Cong. 
(2010), https://www.congress.gov/congressional-report/111th-congress/house-report/563/1.
111 See Twenty-First Century Communications and Video Accessibility Act of 2010, S. Rept. 111-386, 111th Cong. 
(2010), https://www.congress.gov/congressional-report/111th-congress/senate-report/386/1.
112 Trailmobile Co. v. Whirls, 331 U.S. 40, 61 (1947).
113 As the D.C. Circuit noted in 1982, courts must “exercise caution before drawing inferences regarding legislative 
intent from changes made in committee without explanation. … amendments to a bill’s language are frequently 
latent with ambiguity; they may either evidence a substantive change in legislative design or simply a better means 
for expressing a provision in the original bill.”  Western Coal Traffic League v. U.S., 677 F.2d 915, 924 (D.C. Cir. 
1982).
114 Some commenters also stress that the Commission should not use this proceeding to mandate that video 
conferencing services be interoperable.  CTIA Comments at 11-12; CTA Reply Comments at 4.  That is a different 
question, which the Commission settled in 2011:  There is no language in the CVAA supporting the view that 
interoperability is required or should be required as a subset of “accessibility,” “usability,” or “compatibility.”  2011 
ACS Order, 26 FCC Rcd at 14577, para. 48.  We see no need to revisit that question.   
115 CTA 2022 IVCS Refresh Comments at 13; see also 2011 ACS Order, 26 FCC Rcd at 14684-85, para. 301 
(seeking comment on “inter-platform, inter-network, and inter-provider” interpretation of “interoperable”).  
116 2011 ACS Order, 26 FCC Rcd at 14684-85, para. 301.
117 CTA 2022 IVCS Refresh Comments at 12-13 & n.37.
118 Id. at 13.Federal Communications Commission FCC 23-50
17Inter-platform refers to the ability of a user to access a video 
conferencing service on multiple software platforms and operating 
systems, such as Google Android, Apple iOS, and Microsoft Windows, 
and “inter-network” refers to the “ability of a user to access a video 
conferencing service via the internet and on data networks, such as 
through a broadband connection like 4G LTE or 5G.120
According to CTIA, “[t]his definition reflects the video conferencing market today, which likely means 
the most widely used services today would be covered by the Commission’s ACS rules.”121  Nonetheless, 
like CTA, CTIA acknowledges that its interpretation would narrow covered services to a smaller group 
than those fitting under the statutory definition.122  ACB and AFB state that vertically integrated services 
such as Apple Facetime “would likely not meet [CTIA’s] narrow definition of IVCS.”123
36. The fundamental defect of these proposed alternatives is that they substantially alter the 
definition of “interoperable video conferencing service” provided by Congress.  Supporters of alternative 
definitions fail to show how their proposed approaches, which they acknowledge are less inclusive than 
the statutory definition, could be harmonized with Congress’ definition.  Instead, CTA and CTIA argue 
that relying on the statutory definition would render the word “interoperable” superfluous, effectively 
reading the word out of the statute.124  
37. We reject CTA and CTIA’s argument because it is far from clear that “interoperable” is 
superfluous.  For instance, information sharing cannot take place at all without some degree of 
interoperability between the devices or software that each sharing user operates.  The inclusion of the 
word “interoperable” in the term “interoperable video conferencing service” may simply reflect the fact 
that any video service satisfying that definition—i.e., any real-time video communication service that 
“enable[s] users to share information of the user’s choosing”125—necessarily involves some level of 
interoperability among the particular devices and software employed by users of that service.  
38. In any event, while the Commission should “construe statutes, where possible, so as to 
avoid rendering superfluous any parts thereof,”126 it is not always “possible” to do so, given the 
(Continued from previous page)  
119 CTIA 2022 IVCS Refresh Comments at 2.  By contrast with CTA’s proposed definition, CTIA’s proposal would 
define “interoperable video conferencing services” to include services that are interoperable “inter-platform and 
inter-network” but that are not interoperable between different providers.
120 Id. at 10.
121 Id.; see also ACB 2022 IVCS Refresh Reply Comments at 1 (stating that CTIA’s proposed definition “would 
cover many services available today”); AARO 2022 IVCS Refresh Reply Comments at 13 (stating that “the 
operating-systems-and-Internet definition provides the most plausible way forward if the Commission concludes it 
must define interoperability separately”). 
122 CTIA 2022 IVCS Refresh Comments at 12 (contrasting its approach with a simple application of the statutory 
definition, which “would be so sweeping as to discourage investment and innovation in accessible video 
conferencing services”) (emphasis in original).  
123 ACB and AFB 2022 IVCS Refresh Reply Comments at 1-2.
124 CTA 2022 IVCS Refresh Comments at 10; CTIA 2022 IVCS Refresh Comments at 12.  
125 47 U.S.C. § 153(27).
126 Astoria Fed. Sav. & Loan Ass’n v. Solimino, 501 U.S. 104, 112 (1991) (emphasis added); see also Duncan v. 
Walker, 533 U.S. 167, 174 (2001) (“It is our duty ‘to give effect, if possible, to every clause and word of a statute’ 
(quoting U.S. v. Menasche, 348 U.S. 528, 538-39 (1995)) (emphasis added); CTA Comments at 10 (citing these 
cases). Federal Communications Commission FCC 23-50
18imperfections of the legislative process.  Further, we must also read the text harmoniously.127  
Accordingly, interpretations that result in irreconcilable internal discord must be rejected.  In this 
instance, as the proponents agree,128 their interpretive attempts to give independent meaning to the word 
“interoperable” are inconsistent with the statutory definition.  Therefore, we must conclude that it is not 
“possible” to interpret “interoperable” in the way that these commenters request.   
39.Administrative Procedure Act Notice.  We also conclude that the Commission has 
provided adequate notice in this proceeding that we could arrive at the decision we reach today.  The 
2022 IVCS Refresh Public Notice, which was published in the Federal Register, invited the public to “file 
additional comments on the questions posed in the 2011 ACS Further Notice regarding the meaning of the 
term ‘interoperable’ in the context of video conferencing services and equipment.”129  In the very next 
sentence, the 2022 IVCS Refresh Public Notice made direct reference to a recent filing by AARO 
proposing that the Commission apply the statutory definition.130  The 2022 IVCS Refresh Public Notice 
also specifically invited commenters to “suggest additional alternatives or other types of input on how to 
interpret [the word ‘interoperable’]” beyond the three approaches suggested by the Commission in 
2011.131  The 2022 IVCS Refresh Public Notice thus provided ample indication that the interpretive 
question could have a broader range of outcomes than those specifically suggested in 2011.  
40. Even assuming, arguendo, that notice was lacking, we find no conflict with the 
Administrative Procedure Act.  Contrary to the arguments of several commenters, it is procedurally 
proper for the Commission, in this Report and Order, to conclude that “interoperable video conferencing 
service” has the meaning given by the statutory definition.132  In this Report and Order, the Commission 
is not adopting or amending any substantive rule.133  Therefore, the notice-and-comment requirements of 
the Administrative Procedure Act are not implicated by any action taken here.  We are simply revisiting 
the Commission’s prior assertion, in the 2011 ACS Report and Order, of a perceived need to resolve, 
through further interpretation, the correct interpretation of the word “interoperable.”  At most that 
assertion was an interpretive rule, and hence prior notice was not required to revisit that interpretation.134  
The Supreme Court has confirmed that the adoption or modification of interpretive rules occur outside the 
APA’s notice-and-comment requirements.135
41.Effective Date.  This Report and Order will be effective thirty days after publication of a 
summary in the Federal Register.  Given the extended pendency of questions regarding the application of 
127 See Antonin Scalia & Bryan A. Garner, Reading Law: The Interpretation Of Legal Texts, 180-82 (2012) (stating 
that the “Harmonious-Reading” canon of statutory interpretation provides that “[t]he provisions of a text should be 
interpreted in a way that renders them compatible, not contradictory.”).
128 CTA 2022 IVCS Refresh Comments at 13; CTIA 2022 IVCS Refresh Comments at 12.
129 2022 IVCS Refresh Public Notice at 5.
130 Id. 
131 Id. 
132 See CTIA 2022 IVCS Refresh Reply Comments at 6 (stating that “the Commission raised the issue of what 
interoperable means, not whether it has any meaning”); CTA 2022 IVCS Refresh Reply Comments at 4 (arguing 
that the Commission “has not provided any indication that the agency is considering revising its holding [that 
‘“interoperable” cannot be read out of the statute’], and there are no pending petitions for reconsideration before the 
Commission on this issue”).
133 As noted above, the Commission’s rules already incorporate the statutory definition of “interoperable video 
conferencing service.”
134 See 5 U.S.C. 553(b)(A).
135 Perez v. Mortgage Bankers Ass’n, 575 U.S. 92, 96 (2015) (stating that the APA’s notice-and-comment 
requirement “does not apply to interpretive rules, general statements of policy, or rules of agency organization, 
procedure, or practice”).Federal Communications Commission FCC 23-50
19these requirements to video conferencing, we recognize that some service providers may need additional 
time to fully comply with this Report and Order.  For that reason, we extend the date for compliance with 
the Part 14 video conferencing service rules until one year from the effective date.  The Commission 
directs the Consumer and Governmental Affairs Bureau to announce the compliance date by subsequent 
Public Notice.
IV. NOTICE OF PROPOSED RULEMAKING
42. We propose to amend our rules to improve the accessibility of video conferencing, 
whether used for work, education, healthcare, entertainment, or other activities.136  First, to address “the 
integration of [TRS] CAs and the overall accessibility challenges of videoconferencing platforms,”137 we 
propose to adopt additional performance objectives for the accessibility of interoperable video 
conferencing services.138  We specifically propose that such performance objectives (1) include the 
provision of speech-to-text (e.g., captioning of all voice communications in a video conference) and text-
to-speech; and (2) enable the use of sign language interpreting.  We seek comment on whether additional 
amendments are needed to ensure that video conferencing is accessible.  We also seek comment on 
whether technical standards are available or could be fashioned for use as safe harbors,139 whereby certain 
performance objectives for IVCS can be satisfied by providing access to relevant forms of TRS.140   
43. Second, we propose to amend our Part 64 rules to provide that the TRS Fund can be used 
to support the provision of TRS for video conferencing users—whether or not the video conferencing 
platform can be accessed via a NANP telephone call.141  In addition, we propose certain modifications to 
our rules to specify the conditions under which the TRS Fund will support the provision of TRS with 
video conferencing.
A. Amending Part 14 to Improve the Accessibility of Video Conferencing
1. Performance Objectives
44. Section 716 of the Act directs the Commission to adopt “performance objectives to 
ensure the accessibility, usability, and compatibility of advanced communications services.”142  To 
implement this requirement, the Commission in 2011 adopted general performance objectives specifying 
that (1) input, control, and mechanical functions are “locatable, identifiable, and operable” by people with 
disabilities and that (2) “[a]ll information necessary to operate and use the product” is available to people 
136 The proposals in this Notice of Proposed Rulemaking are applicable to those services that fit the statutory 
definition of “interoperable video conferencing service.”  See 47 U.S.C. § 153(27); 47 CFR § 14.10(m) 
(incorporating the statutory definition); see also supra note 99 (noting that a service that provides real-time video 
and audio communications only from one user would not meet the definition of “interoperable video conferencing 
service”).  In this Notice of Proposed Rulemaking, when we refer to “video conferencing” or “video conferences,” 
we mean video conferencing or video conferences that involve the use of an interoperable video conferencing 
service, as defined.  
137 DAC Video Conferencing Report at 5; see also id. at 6 (providing a detailed recommendation).
138 See 47 U.S.C. § 617(e)(1)(A); 47 CFR § 14.21.    
139 See 47 U.S.C. § 617(e)(1)(D).
140 See DAC Video Conferencing Report at 5 (recommending that the Commission “facilitate the development of an 
application programming interface (API) or other standardized technical mechanism to allow TRS providers to 
directly interconnect to video conferencing platforms” and “work with all stakeholders to ensure that TRS users can 
use standard user interfaces on all video conferencing platforms to join their preferred TRS provider to a video 
conference, in real-time”).
141 See id. at 5 (recommending that the Commission “[c]larif[y] the legal ability of TRS providers to seek 
compensation for service provided for video conferences from the TRS Fund”); see also id. at 6 (providing 
additional explanation of this recommendation).
142 47 U.S.C. § 617(e)(1)(A).Federal Communications Commission FCC 23-50
20with disabilities.”143  For example, ACS must be “[o]perable without hearing,” which is defined to mean 
“[p]rovide at least one mode that does not require user auditory perception.”144  These general 
performance objectives are applicable to IVCS as well as other types of ACS.
45. We believe that the Commission’s Part 14 performance objectives have encouraged 
innovative and effective approaches to achieve accessibility for covered equipment and services.  
However, given the seismic shift in how we communicate, and based on this proceeding’s record and the 
Disability Advisory Committee Report, we seek comment on whether to amend the rules to define more 
specific objectives for making IVCS accessible.145 We note that some IVCS providers have added 
accessibility features to their products in response to consumer need during the COVID-19 pandemic.146  
We seek comment on the effectiveness of these features in providing accessibility, the extent of their 
availability, their ease of use, and how they could be improved.  We also seek comment on what other 
features may be necessary to make IVCS accessible and how the current performance objectives could be 
modified or supplemented to ensure that such features are provided if achievable. 
46.DAC Recommendations.  As the Disability Advisory Committee has explained, without 
the ability to have other participants’ audio communications converted to text or sign language, as 
appropriate, and to have their own text or sign language communications converted to speech, a person 
who is deaf or hard of hearing or has a speech disability may not be able to effectively participate in a 
video conference.147  The Committee recommends that the Commission ensure “at a minimum” that video 
conferencing platforms:
•Include built-in closed captioning functionality that is available to all 
users, including to users with free accounts if the platform provides 
such accounts;
•Fully integrate support for TRS CAs, including video, audio, 
captioning, and text communication; and 
•Allow users, including CAs, to control the activation and customize 
the appearance of captions and video interpreters, including caption 
activation, size, color, background, layout, and positioning, pinning 
and multi-pinning, side-by-side views, hiding non-video participants, 
including ASL interpreters, [Certified Deaf Interpreters], other 
interpreters, and cued language transliterators, and exercise this 
control on their own clients without reliance on video conference 
hosts.148
47. We propose to amend the Part 14 performance objectives to address these 
recommendations and promote innovative future solutions for making IVCS accessible.  Consistent with 
section 716 of the Act,149 our proposals would permit IVCS providers to choose whether to satisfy their 
accessibility obligations by including certain features as native applications or by “using third party 
applications, peripheral devices, software, hardware, or CPE that is available to the consumer at nominal 
143 47 CFR § 14.21(b).  These performance objectives provide a definition of “accessible” for purposes of the Part 
14 rules.  Other performance objectives define “usable” and “compatible.”  Id. § 14.21(c), (d).     
144 Id. § 14.21(b).
145 See, e.g., AARO 2022 IVCS Refresh Reply Comments at 15-17.
146 See CTIA 2022 IVCS Refresh Comments at 7-8.
147 See, e.g., AARO 2022 IVCS Refresh Reply Comments at 15-17.
148 DAC Video Conferencing Report at 6; see also AARO 2021 CVAA Refresh Comments at 14-15 (urging similar 
measures); AARO 2022 IVCS Refresh Comments at 21 (same).
149 47 U.S.C. § 617(b)(2). Federal Communications Commission FCC 23-50
21cost150 and that individuals with disabilities can access.”151  
48.Captions.  We propose to adopt, as a performance objective specific to IVCS, the 
provision of captions for the audio communications in video conferences.152  As AARO has explained, for 
people who are deaf or hard of hearing, “a lack of captions can make meaningful interaction 
impossible.”153  Some video conferencing platforms offer captions, which are typically provided via 
ASR.154  However, according to the Disability Advisory Committee, captions are not available on all 
platforms, or on all video conferences for platforms that do provide them, and where they are available 
they may be of “insufficient quality to ensure functional equivalence.”155  
49. As explained in the 2022 CVAA Report to Congress, automatic captioning, when 
available, sometimes produces incomplete or delayed transcriptions, while the delays inherent in live 
captioning can lead to “cognitive overload” as users try to follow poorly synchronized visual and textual 
conversations.156  In addition, because voice conversations go quickly and it may be difficult to 
immediately identify who is speaking, video conferences may cause some people who are deaf or hard of 
hearing to lose vital portions of voice communications.157  Finally, as the Commission has noted with 
regard to automatic captioning in other forms of TRS, some research indicates that ASR technology may 
show algorithmic bias in the accuracy with which it transcribes voices, particularly in the transcription of 
certain speakers.158
150 “Nominal cost” means that “any fee for third-party software or hardware accessibility solutions [shall] be ‘small 
enough so as to generally not be a factor in the consumer’s decision to acquire a product or service that the 
consumer otherwise desires.’”  2011 ACS Order, 26 FCC Rcd at 14621, para. 152.
151 47 U.S.C. § 617(b)(2)(B).  We note that IVCS providers must maintain records of their efforts to ensure that their 
services and products are accessible, 47 CFR § 14.31(a), and the rules do not provide an exemption from this 
requirement for service providers who rely on third-party applications or equipment to achieve accessibility.
152 Concerns about user interface control of caption placement and other aspects of accessibility features are 
discussed below. See infra paras. 58-59.
153 AARO 2022 IVCS Refresh Comments at 8.
154 DAC Video Conferencing Report at 2-3.  See, e.g., Zoom Support, https://support.zoom.us/hc/en-
us/articles/8158738379917-Managing-automated-captions (last visited May 16, 2023) (“These [automatic caption] 
options can be enabled and used by participants to easily follow the conversations or to meet accessibility 
requirements.”); Microsoft, https://support.microsoft.com/en-us/office/use-live-captions-in-a-teams-meeting-
4be2d304-f675-4b57-8347-cbd000a21260 (last visited May 16, 2023) (“Use live captions in a Teams meeting.”).
155 DAC Video Conferencing Report at 2-3; see also AARO 2022 IVCS Refresh Comments at 9-10.
156 2022 CVAA Report to Congress, para. 23.
157 Mark Ray, Why Remote Work Can Be Hard For Hard-Of-Hearing People, Forbes (Mar. 29, 2022), 
https://www.forbes.com/sites/nextavenue/2021/09/02/why-remote-work-can-be-hard-for-hard-of-hearing-
people/?sh=76a3d4c46d71) (writing that “people with hearing loss rely more on nonverbal information than their 
peers . . . . They can miss visual clues, such as when a colleague is about to speak, and fall behind”).
158 Internet Protocol Captioned Telephone Service Compensation; Telecommunications Relay Services and Speech-
to-Speech Services for Individuals with Hearing and Speech Disabilities; Misuse of Internet Protocol (IP) 
Captioned Telephone Service; CG Docket Nos. 22-408, 03-123, 13-24, Notice of Proposed Rulemaking and Order 
on Reconsideration, FCC 22-97, para. 16 & n.43 (Dec. 22, 2022) (citing Allison Koenecke et al., “Racial disparities 
in automated speech recognition,” Proceedings of the National Academy of Sciences, Vol. 117 No. 14 (2020), 
https://www.pnas.org/doi/10.1073/pnas.1915768117 (studying “state-of-the-art ASR systems” developed by five 
major tech companies and finding an average word error rate of 35% for black speakers compared to 19% for white 
speakers)); see also Joshua L. Martin and Kelly Elizabeth Wright, “Bias in Automatic Speech Recognition: The 
Case of African American Language,” Applied Linguistics (2022), https://academic.oup.com/applij/advance-
article/doi/10.1093/applin/amac066/6901317 (discussing the impact of bias in ASR in employment and healthcare 
contexts).  Federal Communications Commission FCC 23-50
2250. We propose to amend section 14.21 of our rules to make clear that captioning is an 
essential component of accessibility in the context of IVCS.  Section 14.21(b)(2)(iv) currently specifies 
that accessibility includes “[p]rovid[ing] auditory information through at least one mode in visual form 
and, where appropriate, in tactile form.”159  As noted above, however, the record indicates that not every 
IVCS offers captioning, and that where captioning is offered, the quality is often uneven.  Therefore, we 
propose to amend section 14.21(b)(2)(iv) to read (with proposed new text shown in bold): 
14.21(b)(2)(iv):  Availability of auditory information. Provide auditory 
information through at least one mode in visual form and, where 
appropriate, in tactile form.  For interoperable video conferencing 
services, provide at least one mode with captions that are accurate 
and synchronous.  The accuracy and latency of such captions should 
be at minimum comparable to that provided on TRS Fund-
supported captioned telephone services. 
51. We seek comment on this proposal.  Does this language provide an appropriate level of 
specificity, given, on the one hand, the need for effective guidance on what accessibility requires, and on 
the other, the need to allow flexibility in implementation160 and innovative solutions, and to avoid 
mandatory technical standards?161  Is this level of quality sufficient to provide a functionally equivalent 
experience for all users, including users of color or users with accents?  Alternatively, we invite comment 
on the extent to which current performance objectives, such as section 14.21(b)(2)(i), already require that 
IVCS provide an appropriate level of caption quality.162  How can the FCC promote improvements in 
ASR technology to address any existing algorithmic bias?
52. In some instances, the host of a video conference may prefer (or have a legal obligation) 
to use another captioning service—be it live captioning or automatic speech recognition—rather than the 
IVCS provider’s captioning feature.  According to the Disability Advisory Committee:
When out-of-band interpreters, transliterators, or captioners can be 
secured, many video conferencing platforms do not provide sufficient 
accessibility features to ensure that they can be integrated properly in a 
video conference to ensure accessibility.  Some video conferencing 
platforms have problems properly joining and integrating caption streams 
to be displayed on streams, requiring users to open a separate web 
159 47 CFR § 14.21(b)(2)(iv).
160 See 47 U.S.C. § 617(a)(2), (b)(2).
161 See id. § 617(e)(1)(D).  The Commission has a pending proceeding on quantifying minimum standards for the 
quality of captions provided by TRS Fund-supported captioned telephone services (CTS and IP CTS) and 
establishing methods of measuring caption quality.  See Misuse of Internet Protocol (IP) Captioned Telephone 
Service; Telecommunications Relay Services and Speech to Speech Services for Individuals with Hearing and 
Speech Disabilities; Structure and Practices of the Video Relay Service Program, CG Docket Nos. 13-24, 03-123, 
and 10-51, Report and Order, Order on Reconsideration, and Further Notice of Proposed Rulemaking, 35 FCC Rcd 
10866, 10898-903, paras. 66-91 (2020) (2020 IP CTS Order).  Pending completion of that proceeding, this proposed 
performance objective states that caption quality should be generally comparable to that offered by TRS Fund-
supported services.  In the future, with the adoption of metrics for CTS and IP CTS by the Commission, such 
metrics could serve as a safe-harbor technical standard for IVCS as well.
162 See 47 CFR § 14.21(b)(2)(i) (“Operable without vision.  Provide at least one mode that does not require user 
vision.”); see also id. § 14.21(b)(2)(ii) (“Operable with low vision and limited or no hearing.  Provide at least one 
mode that permits operation by users with visual acuity between 20/70 and 20/200, without relying on audio 
output.”); id. § 14.21(b)(2)(iii) (“Operable with little or no color perception.  Provide at least one mode that does not 
require user color perception.”).Federal Communications Commission FCC 23-50
23browser or application to view captions.163  
53. To address this concern, we seek comment on whether to specify that IVCS enable the 
use of alternative captioning methods, such as Communication Access Realtime Translation (CART).164  
Similarly, should IVCS be compatible with TRS Fund-supported captioning, so that such captioning can 
be displayed in a video conference if requested by a TRS user?165  Is there a commonly used technology 
that would enable the display of, e.g., CART or IP CTS captioning to all participants in a video 
conference?  Would the adoption of such a performance objective be consistent with section 716(b)(2), 
which allows covered service providers to meet their accessibility obligations either natively or by using 
third party applications or equipment?166 
54.Text-to-Speech.  To ensure that IVCS is operable by people with disabilities who need to 
communicate by text, we propose to amend section 14.21(b)(1)(ix), which specifies that ACS be operable 
in “at least one mode that does not require user speech,”167 to read (with proposed new text shown in 
bold):
14.21(b)(1)(ix):  Operable without speech. Provide at least one mode that 
does not require user speech.  For interoperable video conferencing 
services, provide at least text-to-speech functionality.
We seek comment on this proposal.  Would text-to-speech and captions, along with compatibility with 
refreshable braille displays or other peripheral devices,168 make IVCS accessible for people who are 
deafblind and for people with speech disabilities who cannot or do not use Speech-to-Speech relay service 
(STS)?169  Should we also specify that IVCS support the use of IP Relay, and would such a specific 
performance objective be consistent with the flexible compliance approach permitted by section 
716(b)(2)?170  Is there an effective means for users to connect with and use IP Relay in video conferences?  
55.Sign Language Interpreting.  We also propose to adopt, as a performance objective, that 
IVCS enable the provision of sign language interpreting, such as through a third-party interpreting service 
163 DAC Video Conferencing Report at 3.
164 CART “is the instant translation of the spoken word into English text using a stenotype machine, computer, and 
realtime software.”  NCRA, The Association for Court Reporters and Captioners, Captioning Matters, 
https://www.ncra.org/captioningmatters (last visited May 16, 2023).
165 See DAC Video Conferencing Report at 6 (recommending that the Commission “ensure at a minimum that video 
conferencing platforms . . . [f]ully integrate support for TRS CAs, including video audio, captioning, and text 
communication”).
166 See 47 U.S.C. § 617(b)(2) (“A provider of services may satisfy the requirements of paragraph (1) . . . by (A) 
ensuring that the services that such provider offers are accessible to and usable by individuals with disabilities 
without the use of third party applications, peripheral devices, software, hardware, or customer premises equipment; 
or (B) if such provider chooses, using third party applications, peripheral devices, software, hardware, or customer 
premises equipment that is available to the consumer at nominal cost and that individuals with disabilities can 
access.”). 
167 47 CFR § 14.21(b)(ix) (“Operable without speech. Provide at least one mode that does not require user speech.”).
168 See 47 CFR § 14.21(d) (stating that “[t]he term compatible shall mean compatible with peripheral devices and 
specialized customer premises equipment . . .”).
169 STS is a form of TRS “that allows individuals with speech disabilities to communicate with voice telephone users 
through the use of specially trained CAs who understand the speech patterns of persons with speech disabilities and 
can repeat the words spoken by that person.”  47 CFR § 64.601(41).  STS is currently provided only through state-
certified relay service programs.
170 See DAC Video Conferencing Report at 6 (recommending that the Commission “ensure at a minimum that video 
conferencing platforms . . . [f]ully integrate support for TRS CAs, including video audio, captioning, and text 
communication”).Federal Communications Commission FCC 23-50
24or a VRS provider.  According to the Disability Advisory Committee, “many video conferencing 
platforms do not provide sufficient accessibility features to ensure that [interpreters] can be integrated 
properly in a video conference.”171  Further, at present, video conferencing platforms generally are not 
configured to allow the connection of VRS CAs to a video conference, except through a voice-only dial-
in connection.  As the committee explains, the need to connect a VRS CA through a dial-up connection 
poses multiple difficulties for the user, including the need to use two separately connected devices, 
splitting attention between the two in a way that appears to fall short of functionally equivalent 
participation in a video conference.172  However, some companies are developing ways to enable VRS 
CAs to have a video presence on a video conferencing platform, enabling a solution to these problems.173          
56. To provide guidance on how to make video conferencing accessible to people who use 
sign language, we propose to add a new performance objective to section 14.21 of our rules to specify that 
accessibility for IVCS includes enabling an effective video connection for sign language interpreters, 
including VRS CAs, so that they can be pinned and viewed by those who use such services.174  We seek 
comment on this proposal and its costs and benefits.  We also seek comment on the following language 
for this proposed performance objective:
14.21(b)(4)(i):  Sign language interpretation.  Interoperable video 
conferencing services shall enable the use of sign language 
interpretation, including the transmission of user requests for sign 
language interpretation to providers of video relay service and other 
entities and the provision of sufficient video quality to support sign 
language communication.175  
To ensure that providers of video remote interpreting (VRI) and VRS can connect with an IVCS 
provider’s platform, should we also specify in this performance objective that IVCS providers make 
technical specifications available on their websites, indicating how to make use of the relevant 
capabilities?  Are there other forms of visual communication that this rule should cover for use on video 
conferences?  For example, Cued English uses hand shapes, hand placements, and non-manual signals on 
the mouth to provide a transliteration of spoken English for some individuals with hearing disabilities.176  
How would requiring the ability to connect interpreters or transliterators for additional forms of visual 
communication (if procured, e.g., by the host or organizer of a video conference) affect the costs and 
benefits of this proposed rule?
171 Id. at 3.
172 Id. at 3-4 (noting that the use of two separate devices “introduces significant cognitive load” that can cause 
confusion, fatigue, or otherwise decrease a user’s ability to fully participate in a video conference.)
173 See, e.g., Letter from John T. Nakahata, Counsel to Sorenson, to Marlene H. Dortch, Secretary, FCC, CG Docket 
Nos. 10-51 and 03-123 (filed Mar. 10, 2023) (reporting demonstration of VRS integration with Zoom IVCS).  
Sorenson has now made available to its customers an application that allows its VRS CAs to participate in a Zoom 
conference call.  See Sorenson-for-Zoom (instructions for application to integrate Sorenson VRS CAs on a Zoom 
conference call). 
174 DAC Video Conferencing Report at 6; see also AARO 2021 CVAA Refresh Comments at 14-15 (recommending 
a similar measure); AARO 2022 IVCS Refresh Comments at 21 (same). 
175 Cf. Section 508 and 225 Guidelines, § 412.7; https://www.access-board.gov/ict/#412.7 (“Where ICT provides 
real-time video functionality, the quality of the video shall be sufficient to support communication using sign 
language”.).
176 See Letter from Nicole Dugan, National Cued Speech Association, to Marlene H. Dortch, Secretary, FCC, CG 
Docket Nos. 21-140 and 10-213 (filed June 2, 2023); AARO 2022 IVCS Refresh Comments at 20-21 (urging the 
Commission to “mandate the inclusion of essential accessibility features . . . including the appearance of cued 
language transliterators”).Federal Communications Commission FCC 23-50
2557. We also seek comment on whether additional performance objectives should be specified 
for IVCS to address other accessibility concerns.  For example, are the current Part 14 performance 
objectives sufficient to ensure that people with disabilities other than hearing and speech disabilities can 
effectively participate in video conferences? 
58.User Interface Controls.  The Disability Advisory Committee and some commenters 
raise a concern that video conferencing platforms do not provide certain user interface controls needed for 
accessibility.177  To address these concerns, the committee recommends that the Commission ensure that 
such platforms:
Allow users, including CAs, to control the activation and customize the 
appearance of captions and video interpreters, including caption 
activation, size, color, background, layout, and positioning, pinning and 
multi-pinning, side-by-side views, hiding non-video participants, 
including ASL interpreters, [Certified Deaf Interpreters], other 
interpreters, and cued language transliterators, and exercise this control 
on their own clients without reliance on video conference hosts.
59. Section 14.21(b) of our rules generally requires that the control functions necessary for a 
user to operate a covered service or product be accessible.178  We invite comment on the extent to which 
the existing section 14.21(b) performance objectives already require control functions that would address 
the committee's recommendation.  If not, would adding a performance objective such as the following 
effectively and appropriately address those concerns?
14.21(b)(4)(ii): Interoperable video conferencing services shall 
provide user interface control functions that permit users to adjust 
the display of captions, speakers and signers, and other features for 
which user interface control is necessary for accessibility.
Should we identify additional kinds of user interface controls that are necessary for accessibility?179  We 
invite commenters to recommend language for performance objectives that would provide appropriate 
guidance in this area.   
60.Costs and benefits.  We seek comment on the costs and benefits of the above proposals.  
What benefits would result, and what costs would IVCS providers and other affected entities incur to: 
(a) enable captioning of video conferences;
(b) provide text-to-speech capabilities;
(c) enable a video connection for sign language interpreters and VRS CAs;
(d) improve user interface controls; and
(e) address other possible performance objectives discussed above or in responsive comments?
61. How should we quantify such incremental costs?  How should we compare those costs 
177 See DAC Video Conferencing Report at 6; see also AARO 2021 CVAA Refresh Comments at 14-15 (urging 
similar measures); AARO 2022 IVCS Refresh Comments at 21 (same).
178 See 47 CFR § 14.21(b)(1) (providing that “control . . . functions shall be locatable, identifiable, and operable” in 
each mode listed in the subparagraphs of that provision); see also id. § 14.21(b)(2) (providing that all “information 
necessary to operate and use the product, including but not limited to, text, static or dynamic images, icons, labels, 
sounds, or incidental operating cue” shall be accessible); id. § 14.21(b)(3) (“The term usable shall mean that 
individuals with disabilities have access to the full functionality and documentation for the product.”).
179 See, e.g., Media Bureau Seeks Comment on Closed Captioning Display Settings Proposal, MB Docket No. 12-
108, Public Notice, DA 23-66 (MB Jan. 24, 2023) (seeking comment on proposal that when the Commission is 
determining whether specific closed captioning settings are readily available, it should consider the following 
factors:  proximity, discoverability, previewability, and consistency and persistence).  Federal Communications Commission FCC 23-50
26with the benefits to IVCS users?  Are there cost savings we should consider—such as costs that could be 
incurred by video conference hosts or participants to provide captioning in the absence of platform-
provided captioning?  Further, IVCS providers may view accessibility not only as a public obligation, but 
also as a market opportunity.180  We seek comment on this view. 
62. In addition to describing and (where possible) quantifying the benefits that would result 
from meeting all the performance objectives proposed above, we invite comment on the extent to which 
particular performance objectives are “achievable,” either at present or in the foreseeable future.181  We 
stress that each of the amendments proposed above, if adopted, would remain subject to the general 
condition that a provider or manufacturer need not meet the objective if it is not achievable to do so.  
Therefore, we may adopt new or modified performance objectives even if they are not immediately 
achievable for every provider.  However, we can better assess the likely benefits of our proposals if there 
is evidence as to whether or not a performance objective is likely to be achievable, for at least some 
covered entities, within the foreseeable future.
63.Legal Authority.  We believe the Act provides legal authority for the above proposals.  
Section 716 of the Act requires providers of ACS and manufacturers of equipment used with ACS, 
including “interoperable video conferencing service,” to make their services and equipment accessible to 
and usable by individuals with disabilities, unless that is not achievable.182  The Act directs the 
Commission, in broad terms, to adopt implementing regulations that, among other things, “include 
performance objectives to ensure the accessibility, usability, and compatibility of advanced 
communications services”183 and “determine the obligations under this section of manufacturers, service 
providers, and providers of applications or services accessed over service provider networks.”184  We 
believe our proposals fall within this broad grant of authority and are consistent with other provisions of 
section 716, including the allowance for flexible implementation through either native or third-party 
applications,185 the prohibition on mandating technical standards,186 and the condition that compliance is 
not required if it is not achievable.187  We seek comment on this analysis.
64. We also seek comment on whether there are other sources of authority supporting the 
above proposals.  For example, in 2007 the Commission found that it had authority, ancillary to section 
180 Ken Krechmer, The role of technical standards in enabling the future, The Bridge:  50th Anniversary Issue, 
National Academy of Engineering (Feb. 22, 2021), https://www.nae.edu/248425/The-Role-of-Technical-Standards-
in-Enabling-the-Future. 
181 See 47 U.S.C. § 617(a)(1), (b)(1) (requiring that covered equipment and services be accessible to and usable by 
people with disabilities “unless the requirements of this subsection are not achievable”); id. § 617(c) (providing that 
“whenever the requirements of subsections (a) or (b) are not achievable, a manufacturer or provider shall ensure that 
its equipment or service is compatible with existing peripheral devices or specialized  customer premises 
equipment commonly used by individuals with disabilities to achieve access, unless the requirement of this 
subsection is not  achievable”); 47 CFR § 14.20(a)(1), (2), (3) (corresponding provisions of the Commission’s rules); 
see also id. § 14.10(b) (defining “achievable” as “with reasonable effort or expense, as determined by the 
Commission,” and listing four factors to be considered in making such a determination).  
182 47 U.S.C. § 617(a)(1), (b)(1).  Further, whenever that requirement is not achievable, a service provider shall 
ensure that its service “is compatible with existing peripheral devices or specialized customer premises equipment 
commonly used by individuals with disabilities to achieve access,” unless this requirement too is not achievable.  Id. 
§ 617(c).  A manufacturer of equipment used for IVCS is similarly required to make its products accessible to and 
usable by people with disabilities, unless it is not achievable to do so.  Id. § 617(a)(1).
183 Id. § 617(e)(1)(A).
184 Id. § 617(e)(1)(C).
185 Id. § 617(a)(2), (b)(2).
186 Id. § 617(e)(1)(D).
187 Id. § 617(a)(1), (b)(1).Federal Communications Commission FCC 23-50
27225 of the Act, to require interconnected providers of VoIP service to provide access to TRS.188  Could 
the Commission also find that it has authority ancillary to section 225, or other provisions, to require 
video conferencing service providers to provide TRS access to interoperable video conferences?  If so, 
what would be the bases for such a finding?        
2. Safe Harbor Technical Standards
65. Section 716 of the Act provides that the Commission shall not adopt mandatory technical 
standards for ACS accessibility.189  However, the Commission may adopt technical standards “as a safe 
harbor for such compliance if necessary to facilitate the manufacturer’s and service providers’ 
compliance.”190  We seek comment on whether technical standards are available (or in development)— 
e.g., WebRTC191 or portions thereof—that could serve as safe harbors for IVCS compliance with one or 
more applicable performance objectives, including the additional performance objectives proposed above,  
whereby a performance objective can be satisfied if an IVCS complies with the technical standard.192 
66. We invite any commenter who proposes that a technical standard be recognized as a safe 
harbor to discuss the costs and benefits of the proposal, and how the Commission would verify 
compliance with the standard.  In general, are there costs or benefits to innovation of recognizing certain 
technical standards as safe harbors?  Given the pace of technological innovation, how often should a safe 
harbor be updated, or should it be designated to expire after a date certain?    
67. We also seek comment on how the Commission can assist with or promote the 
development of safe harbor technical standards in this area.  For example, there are numerous IVCS 
providers, each with a specific technology configuration, and there are multiple VRS providers as well.  
Would substantial costs be saved if all companies adhered to a common technical standard for integrating 
interpreters and VRS CAs into video conferences?  How could the Commission facilitate the development 
of a useful standard? 
B. Providing TRS in Video Conferences
1. Authorizing the Integrated Provision of TRS in Video Conferences 
68. Responding to the Disability Advisory Committee’s recommendations, we propose to 
amend our rules to clarify that the integrated provision of TRS to enable functionally equivalent 
participation in video conferences can be supported by the Interstate TRS Fund.193  Just as the TRS Fund 
188 See IP-Enabled Services et al., WC Docket No. 04-36 et al., Report and Order, 22 FCC Rcd 11275, 11291-97, 
paras. 32-43 (2007) (IP-Enabled Services).
189 47 U.S.C. § 617(e)(1)(D).
190 Id.
191 WebRTC, short for “Web Real-Time Communications,” is an open-source internet standard that allows for real-
time video communications through a user’s internet browser, foregoing the need for plug-ins or standalone third-
party software.  On January 26, 2021, the World Wide Web Consortium and the Internet Engineering Task Force 
announced WebRTC as an official standard.  Although designed as a tool for internet browsers, WebRTC 
applications are now also being developed for mobile and Internet of Things devices.  See Huib Kleinhout, WebRTC 
is now a W3C and IETF Standard (Jan. 26, 2021) https://web.dev/webrtc-standard-announcement/#:~:text=A%20
brief%20overview%20of%20the,cases%2C%20and%20future%20of%20WebRTC.&text=The%20process%20
of%20defining%20a,consistency%20and%20compatibility%20across%20browsers; W3C/IETF Press Release, 
https://www.w3.org/2021/01/pressrelease-webrtc-rec.html.en (last visited May 16, 2023).
192 Section 716(e)(1)(D) of the CVAA provides that the Commission “shall . . . not mandate technical standards, 
except that the Commission may adopt technical standards as a safe harbor for such compliance if necessary to 
facilitate the manufacturers’ and service providers’ compliance” with the accessibility and compatibility 
requirements in Section 716.  47 U.S.C. § 617(e)(1)(D).
193 DAC Video Conferencing Report at 5-6.Federal Communications Commission FCC 23-50
28has long been used to support the provision of TRS with audio-only teleconferencing, we believe it is 
necessary and appropriate, as a general matter, that the TRS Fund be used to support the provision of TRS 
with video conferencing.  
69.Legal Authority.  We tentatively conclude that section 225 of the Act authorizes the 
Commission to support the integrated provision of TRS in video conferences, without any need for either 
the TRS user or the CA to place a dial-up, voice-only call to the video conferencing platform.  By 
“integrated provision of TRS” in a video conference, we mean an arrangement whereby communication 
between the CA (or automated equivalent) and video conference participants, whether by voice, text, or 
sign-language video, takes place on the video conferencing platform (where it can be available to all 
participants), rather than through a separate dial-up connection.  The Act defines telecommunications 
relay services as:
telephone transmission services that provide the ability for an individual 
who is deaf, hard of hearing, deaf-blind, or who has a speech disability to 
engage in communication by wire or radio with one or more individuals, 
in a manner that is functionally equivalent to the ability of a hearing 
individual who does not have a speech disability to communicate using 
voice communication services by wire or radio.194 
Applying this definition, we tentatively conclude that when the provision of a relay service is integrated 
with a video conferencing platform (without using a dial-up, voice-only connection), the provision of 
such service to an eligible TRS user is a “telephone transmission service” that enables “communication 
by wire or radio . . . in a manner that is functionally equivalent to the ability of a hearing individual who 
does not have a speech disability to communicate using voice communication services by wire or radio.”  
70. As indicated by the text quoted above, section 225 defines TRS in terms of its purpose—
to enable people with hearing or speech disabilities to “communicat[e] by wire or radio” in a manner that 
is functionally equivalent to how people without such disabilities use “voice communication services.”  
Both “radio communication” and “wire communication” are broadly defined in the Act as “the 
transmission . . . of writing, signs, signals, pictures and sounds of all kinds . . . including all 
instrumentalities, facilities, apparatus, and services (among other things, the receipt, forwarding, and 
delivery of communications) incidental to such transmission.”195  These definitions include wire or radio 
communication using Internet Protocol.196  Further, we believe that interoperable video conferencing 
service, which is defined to include audio communication, is appropriately characterized as a “voice 
communication service” for purposes of section 225.    
71. While “telephone transmission service” is not defined in the Act, the Commission has 
given this term a similarly broad interpretation.  As the Commission explained in 2002, the use of this 
phrase to define TRS is “constrained only by the requirement that such service provide a specific 
functionality,” namely the ability to communicate by wire or radio in a manner functionally equivalent to 
voice communication.197  In its prior decisions authorizing new forms of TRS, the Commission has found 
194 47 U.S.C. § 225(a)(3) (emphasis added); see also, e.g., 2002 IP Relay Declaratory Ruling, 17 FCC Rcd at 7783, 
para. 10 (citing pre-CVAA language of Section 225).
195 47 U.S.C. § 153(40), (59).
196 See, e.g., Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and 
Speech Disabilities, CC Docket No. 98-67, Report and Order and Further Notice of Proposed Rulemaking, 15 FCC 
Rcd 5140, 5152-54, paras. 21-27 (2000) (2000 TRS Order) (allowing TRS Fund compensation for VRS); 2007 IP 
CTS Declaratory Ruling, 22 FCC Rcd at 387-90, paras. 19-26.
197 2002 IP Relay Declaratory Ruling, 17 FCC Rcd at 7783, para. 10.  Further, section 225 directs the Commission 
to “ensure that regulations prescribed to implement this section encourage, consistent with Section 7(a) of this Act, 
(continued….)Federal Communications Commission FCC 23-50
29that Internet-based relay services are not limited to a specific technical configuration.  For example, when 
finding IP CTS to be a compensable form of TRS, the Commission emphasized that the service could be 
initiated, set up, and provided in numerous ways, including using specific telephone equipment or IP-
enabled devices, and various combinations of the PSTN and IP-enabled networks.198  Similarly, when the 
Commission approved compensation for VRS, it noted that the service “is under development using a 
number of equipment configurations and…[o]ne [VRS] equipment configuration, for example, involves 
the use of personal computer and videoconferencing equipment along with access to broadband 
transmission services.”199  Further, the Commission has not interpreted “telephone transmission service” 
as requiring the use of telephone numbers.  For example, VRS users were not assigned NANP numbers 
until 2008.200
72. We seek comment on the foregoing tentative conclusion and interpretation of our 
authority under section 225.  Among other things, we seek comment on whether anything in section 225 
or elsewhere in the Act indicates that our authority in this context is limited to making TRS available only 
with voice services that rely on the use of NANP telephone numbers.  How could such a restrictive 
interpretation be squared with the broad language of the statutory definition of TRS? 
73.  Below, we seek comment on how to modify the Commission’s TRS rules to facilitate 
such integration, ensure the appropriate use of VRS with video conferencing, and prevent waste, fraud, 
and abuse.  First, we propose and seek comment on measures that specifically address the integration of 
VRS with video conferencing.  Then, we seek comment on whether additional rule amendments are 
needed to specifically address the integration of other types of TRS with video conferencing.  Finally, we 
propose to amend certain generally applicable TRS rules to address the integrated provision of TRS 
regardless of type.
2. Integrating the Provision of VRS with Video Conferencing 
74. We tentatively conclude that the integrated provision of VRS with video conferencing is 
often necessary to enable sign-language users to communicate in a functionally equivalent manner.201  
First, the only alternative for connecting a VRS CA to a video conference—using a dial-up, voice-only 
connection—is often unavailable.202  Second, the need to connect a VRS CA through a dial-up connection 
poses multiple difficulties for the user.203  For example, the VRS user must navigate between two 
separately connected devices and user interfaces—one to participate in the video portion of the 
conference and the other to communicate with the VRS CA—and this can cause confusion, fatigue, and 
(Continued from previous page)  
the use of existing technology and do not discourage or impair the development of improved technology.”  47 
U.S.C. § 225(d)(2).
198 2007 IP CTS Declaratory Ruling, 22 FCC Rcd at 388.  
199 2000 TRS Order, 15 FCC Rcd at 5152-53.
200 See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities; E911 Requirements for IP-Enabled Services Providers, CG Docket No. 03-123 and WC Docket No. 
05-196, 23 FCC Rcd 11591, 11594, para. 4 (2008) (prior to assignment of 10-digit telephone numbers, VRS users 
were assigned a “dynamic” Internet address).
201 By “integrated provision of VRS” in a video conference, we mean an arrangement whereby a CA is included as a 
participant in the video conference and all communication between the CA and the participants takes place on the 
video conferencing platform rather than through a separate connection.
202 DAC Video Conferencing Report at 2.  Assuming the video conferencing platform allows a dial-up connection, it 
is usually the video conference organizer or host who determines whether a dial-up option is provided.  Similarly, 
the conference organizer or host may or may not hire a sign language interpreter to provide communication 
assistance for a video conference.
203 Id. at 3-4.Federal Communications Commission FCC 23-50
30other barriers to effective communication.204  We seek comment on this tentative conclusion.
75. The active development and deployment of technological solutions for the integrated 
provision of VRS in a video conference205 has crystallized a number of issues regarding the application of 
our TRS rules to such integration.  Therefore, we propose to amend our rules, as set forth below, to 
facilitate such integration, ensure the appropriate use of VRS with video conferencing, and prevent waste, 
fraud, and abuse.    
76. In addition, we invite the submission of comments describing in detail any ongoing 
efforts by VRS providers and IVCS providers to enable the integration of VRS with IVCS, and how far 
their development has progressed.  We seek comment on the extent to which the integration methods and 
technologies currently being developed or deployed are usable (or can be made usable) with more than 
one video conferencing platform or more than one VRS provider.  What steps can the Commission take to 
encourage or assist with the development of standardized or open-architecture solutions, so that IVCS 
providers, TRS providers and the TRS Fund do not needlessly incur duplicative costs to support multiple 
solutions unique to each video conferencing platform and VRS provider?  What changes in the TRS 
interoperability rule, or other Commission rules, would promote wider availability of effective technical 
solutions in this area?  To the extent that technological solutions are feasible, should we not only 
authorize, but also require VRS providers to provide VRS with IVCS on an integrated basis?  
3. VRS and Video Conferencing—User Validation and Call Detail 
77. To collect compensation from the TRS Fund, a VRS provider must validate that the 
person using a video connection to place or receive a VRS call is a registered VRS user.206  Ordinarily, a 
person’s status as an eligible user is verified by means of the NANP telephone number from which or to 
which a call is placed.  By contrast, video conference participants typically enter a video conference via 
the Internet (e.g., by clicking the link provided by the host of the video conference) without dialing from a 
line associated with a telephone number.207  Further, VRS users may connect to a video conference 
without first contacting their VRS provider.  We seek comment on how VRS providers can most 
efficiently and effectively confirm a video conference participant’s eligibility for VRS when the user has 
not joined the video conference by placing a call from a NANP telephone number.
78. For example, should we amend our rules to specify that, to validate the integrated 
provision of VRS in a video conference, information may be entered in a video conferencing application 
by a registered user and transmitted by the IVCS provider to a VRS provider, along with a request to 
provide a CA?  If so, what information should be provided?  Would a user’s NANP telephone number 
suffice—even though it is not actually being used to connect with the video conference?  Or should we 
require a log-in ID and password?  Should we allow the provision of integrated VRS in video conferences 
pursuant to an enterprise registration, and if so, would the telephone number associated with an enterprise 
videophone suffice for validating such use?208  Are there other methods of validation that we should 
permit in the video conferencing context?     
204 Id. at 3.  In addition, the CA who, unlike other participants, is limited to an audio connection, is unable to read 
documents or other text that may be displayed, interpret facial expressions, or attend to other visual cues on which 
video conference participants often rely for effective communication.  See id.
205 See, e.g., Sorenson March 2023 Zoom Ex Parte; Sorenson-for-Zoom.
206 See 47 CFR § 64.615(a)(1), (2).
207 As discussed earlier, while some video conferencing platforms may allow a participant to connect via a voice-
only, dial-up connection, the availability of such a connection for a particular video conference is up to the 
conference host or organizer.
208 See 47 CFR § 64.611(a)(6) (registration requirements for enterprise videophones).Federal Communications Commission FCC 23-50
3179. We also seek comment on how our rules should address video conferences that are 
initiated informally, without an advance invitation, by one person dialing the telephone number, entering 
an email address, pressing an icon or otherwise contacting one or more other parties using a service such 
as GoogleMeet or FaceTime.  Are there currently available or in development any technologies for 
integrating a CA with this type of video conference?  Do the existing TRS rules and procedures suffice to 
verify, for these kinds of video conferences, that the caller or called party is a registered VRS user?  
Would this scenario require any changes to our TRS rules?  
80. In addition, the VRS provider will need to be able to collect and provide an appropriate 
call detail record (CDR) to submit to the TRS Fund administrator.  Because our rules may apply 
differently to video conferences in a number of respects,209 we propose to require that call detail records 
submitted by VRS providers identify, as such, video conferences in which VRS is provided on an 
integrated basis.  What other information should we require VRS providers to collect and submit to the 
TRS Fund administrator to identify, for billing purposes, the integrated provision of VRS in a video 
conference?  What routing information is available for the TRS Fund administrator to verify the presence 
of the VRS user and the CA or CAs in a video conference?  Are originating and terminating URLs 
needed, and if so, how can they be collected?  Alternatively, is it sufficient to provide the user’s phone 
number or log-in, in lieu of the originating URL?  How would VRS providers comply with the 
requirement to employ an automated record keeping system to capture call record data?  How would VRS 
providers and the TRS Fund administrator identify non-compensable international calls?  How would 
VRS providers verify that, based on the parties involved, the provision of TRS in a video conference is 
eligible for TRS Fund compensation?210  In addition, we seek comment generally on what measures VRS 
providers should be required to take to prevent misuse of VRS or waste, fraud, and abuse of the TRS 
Fund in the context of video conferencing.
4. VRS and Video Conferencing—CA-Related Issues
81.Multiple VRS Providers.  There may be a number of situations in which more than one 
VRS CA participates in a video conference.  This could occur, for example, if two or more participants 
send service requests to different providers.  We seek comment on whether our TRS rules should apply 
differently in this respect to a video conference than to a teleconference.211  Given that any VRS provided 
on an integrated basis will be available to all participants, are any restrictions warranted on the number of 
different providers who may provide VRS in a single video conference?    
82.Multiple CAs from a Single VRS Provider.  We also seek comment on whether to amend 
our rules to authorize a single VRS provider to assign multiple CAs for a video conference in certain 
circumstances (and to receive additional compensation from the TRS Fund for minutes involving multiple 
CAs).  First, two or more VRS users may each request service from the same VRS provider on the same 
video conference.  In an analogous teleconference where two or more users have connected through VRS, 
compensation would be paid for multiple calls—with each user’s connection through a CA being treated 
as a separate call.  However, in a video conference with integrated VRS, unlike a teleconference, it is 
possible for all participants to be served by one CA.  In such cases, should the TRS Fund support the 
provision of a separate CA for each user, or, to prevent waste (and potential confusion among video 
conference participants), should we limit the number of CAs provided, and if so, based on what criteria?  
209 For example, as discussed in the next section, for certain kinds of video conferencing calls a VRS provider may 
be compensated for the provision of a team of two CAs simultaneously handling a call.
210 For example, a video conference involving only VRS users does not require a CA to relay the conversation and 
so would not be eligible for TRS Fund compensation.  See Telecommunications Relay Services and Speech-to-
Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123, Report and Order 
and Further Notice of Proposed Rulemaking, 34 FCC Rcd 8483, 8487, paras. 10-11 (2019) (2019 TRS Definition 
Order).
211 In a multi-party teleconference involving at least one hearing user, our rules do not restrict the number of 
different TRS providers whose services may be used by various parties to the call.Federal Communications Commission FCC 23-50
3283. Second, in certain kinds of video conferences, it may be desirable for two CAs to 
participate in the call, working as a team—even if only one participant has requested VRS.212  Under the 
current TRS Fund compensation scheme, additional compensation is not paid to support multiple CAs in 
a teleconference if only one participant has connected through VRS.  However, video conferences may 
often involve dynamic interaction among multiple participants.213  Should we amend our rules to allow a 
VRS provider to earn additional compensation for providing more than one CA in certain video 
conferencing scenarios, and if so, how should those situations be defined?  For example, are there 
professional interpreter guidelines or best practices on which we could rely, that define when multiple 
ASL interpreters should be present at a meeting?214  To what extent are guidelines for community 
interpreting applicable in the VRS context?215  Are there any situations where the TRS Fund should 
support more than two CAs from a single VRS provider?216
84.Multiple VRS Users.  We propose that, in the ordinary case, if the VRS user who 
requested service leaves a video conference, or is disconnected, before the session ends, then the billable 
period has ended and the CA should leave the video conference.217  We seek comment on this proposal 
and on what, if any, exceptions should be allowed.  For example, if other registered VRS users are 
participating in the same video conference, who were being assisted by the same CA, should the initial 
CA be permitted to stay on the video conference for a limited period to ensure continuity of service, and if 
so, for how long?  Are other flexible alternatives available to ensure seamless VRS for other eligible users 
or ensure a smooth transition between CAs, while minimizing any risk of waste, fraud, or abuse?  Are 
there any other issues that may arise when multiple VRS users and other participants are present in the 
same IVCS call, and how should they be resolved?218
85.Call Takeover Issues.  VRS CAs generally must stay on a call for a minimum of 10 
minutes, after which they may be replaced by another CA.219  We seek comment on whether to adjust this 
timeframe for the provision of VRS in video conferences.  If so, what timeframe would be reasonable?    
86. In addition, to ensure a seamless takeover between CAs from the same VRS provider 
during a video conference, is it desirable for a replacement CA to join the video conference and observe 
212 See, e.g., The Registry for Interpreters for the Deaf (RID), Team Interpreting, Standard Practice Paper, 
https://nvrc.org/wp-content/uploads/2011/07/Team_Interpreting_SPP.pdf (last visited May 16, 2023) (RID Standard 
Practice Paper).
213 According to one ASL interpreting service, a team of two interpreters may be recommended “based on the 
dynamics of the interactions and number of participants involved. . . . For example:  highly interactive meetings, or 
legal requests, with multiple Deaf participants.”  LinguabeeLearn, What is team interpreting and when is a team 
needed? (Nov. 5, 2019), https://learn.linguabee.com/what-is-team-interpreting-and-when-is-a-team-needed/.
214 RID states that factors to be considered in deciding whether to provide team interpreting include: (1) the length 
and complexity of the assignment; (2) unique needs of the persons being served; (3) physical and emotional 
dynamics of the setting; and (4) avoidance of repetitive stress injuries for interpreters.  RID Standard Practice 
Paper.    
215 For example, length of an assignment may be a less relevant factor for VRS because interpreters can be more 
efficiently substituted for one another when they do not need to be physically present at a meeting.  
216 We also propose a more generally applicable rule amendment (not limited to the video conferencing context) to 
address the use of multiple CAs in calls between users of different forms of TRS.  See infra paras. 108-11.
217 In the context of an ordinary VRS call or conference call, if the TRS user is voluntarily or involuntarily 
disconnected from the call, he or she must initiate another call with a new CA.
218 See 47 CFR § 64.604(a)(1)(vi) (“TRS providers must make best efforts to accommodate a TRS user’s requested 
CA gender when a call is initiated and, if a transfer occurs, at the time the call is transferred to another CA.”).
219 See id. § 64.604(a)(1)(v).  CAs answering and placing an STS call shall stay with the call for a minimum of 20 
minutes.Federal Communications Commission FCC 23-50
33or acquire background information for some period of time before taking over from the first CA?  If so, 
what would be a reasonable transition period?  Is there a standard timeframe that VRS providers should 
adhere to, or should it be left to the discretion of the CAs or the VRS user?  Are there professional 
guidelines or best practices that shed light on this question?  Should a VRS provider be compensated for 
each CA’s time while both the initial and replacement CAs are on the call?  How can we encourage 
uninterrupted VRS call takeovers during video conferences, while not unduly burdening the TRS Fund 
and Fund contributors?
5. VRS and Video Conferencing—Privacy Screen Rule
87. We propose to modify our rules to allow flexibility for VRS users and CAs to turn off 
video while participating in a video conference.  Our current rules prohibit a VRS CA from enabling a 
visual privacy screen or similar feature during a VRS call and require the CA to disconnect a VRS call if 
the caller or called party enables a visual privacy screen or similar feature for more than five minutes or is 
otherwise unresponsive or unengaged for more than five minutes.220  A “visual privacy screen” is defined 
as “[a] screen or any other feature that is designed to prevent one party or both parties on the video leg of 
a VRS call from viewing the other party during a call.”221  The Commission adopted this rule in 2011 as 
one of numerous measures aimed at halting the epidemic of fraud and abuse then plaguing the VRS 
program.  The rule’s stated purpose was to stop “illicit schemes that result in calls ‘running’ without any 
communication between the parties for the sole purpose of fraudulently billing the Fund.”222
88. In a multi-party video conference, however, a participant may turn off his or her video 
camera for various reasons that may not indicate lack of engagement with the discussion.  For example, in 
some video conferences, the host may request that all participants turn off their videos unless speaking, to 
make it easier for participants who are deaf to view a sign language interpreter.223  Or, an interpreter may 
stop his or her video when a second interpreter is present and is interpreting a particular person’s voice or 
signing.  Further, on a video conference where one or more participants are speaking at length, 
participants who are deaf (like other participants) may choose to turn off their videos until it is their turn 
to speak.
89. We propose to allow VRS CAs to continue providing relay services integrated with a 
multi-party video conference when the VRS user who requested service has turned off his or her video 
connection for more than five minutes, as long as at least one other party is continuing to speak and the 
VRS user is still connected to the video conference.  Under our proposed amendment, if five minutes 
elapse in which no party on a multi-party video conference is responsive or engaged in conversation, the 
VRS CA shall follow the current procedure, i.e., announce that VRS will be terminated and leave the 
video conference.  We propose to define “multi-party video conference” as a video conference with three 
or more participants, excluding VRS CAs and any other participant providing an accommodation for a 
participant.  We also propose to allow VRS CAs to turn off their video connections when taking turns 
relaying conversation with another VRS CA on a multi-party video conference.  We seek comment on 
these proposals.  Are there other steps we should take to ensure that modifying this rule does not lead to 
misuse of TRS or fraudulent billing to the TRS Fund?  More generally, are there other precautions we 
should take to prevent the inappropriate or excessive provision of TRS in video conferences, with the 
intention of increasing a TRS provider’s compensable minutes? 
6. Integrating Other Types of TRS with Video Conferencing
90. We seek comment generally on the need to facilitate the integration of non-VRS types of 
220 See id. § 64.604(a)(6).
221 Id. § 64.601(a)(52).
222 2011 VRS Call Practices Order, 26 FCC Rcd at 5567, para. 40.
223 Sorenson Petition at 4-5.Federal Communications Commission FCC 23-50
34TRS with video conferencing and on the existence and progress of any efforts to develop technology to 
enable such integration.  To the extent that such integration is needed and feasible, should we adopt 
service-specific rule changes, e.g., amendments analogous to those proposed above for VRS, to address 
the integration of other types of TRS with video conferencing?  What rule changes would facilitate the 
integrated provision of each type of TRS with video conferencing, ensure the appropriate use of these 
TRS Fund-supported services in that context, and prevent waste, fraud, and abuse?
91.IP Relay.  We seek comment on the extent to which the integrated provision of IP Relay 
in video conferences would facilitate functionally equivalent communication.  Would such integrated 
provision of IP Relay enhance functionally equivalent communication in video conferences for those 
segments of the TRS-eligible population served by IP Relay, such as persons who are deafblind and 
persons with speech disabilities?224  Have methods and technologies been developed to enable such 
integrated provision of IP Relay?  Could the needs of these communities be served more efficiently or 
effectively if IVCS providers make available text-to-speech and speech-to-text (captioning) functionality, 
pursuant to Part 14 of our rules?  Alternatively, would IP Relay be needed for certain populations to 
effectively participate in a video conversation in a way that is functionally equivalent?
92. If the integrated provision of IP Relay with video conferencing is achievable, what 
service-specific amendments to our rules would facilitate such integration, ensure the appropriate 
provision of IP Relay in this context, and prevent waste, fraud, and abuse?  How can we ensure that only 
registered IP Relay users can use IP Relay in a video conference?  Would the same sign-on procedure and 
request for a CA work in the context of IP Relay as for VRS?  Are there CA-related issues for IP Relay 
similar to those proposed above for VRS?  
93.IP CTS.  We seek comment on the extent to which the integrated provision of IP CTS in 
video conferences would facilitate functionally equivalent communication for IP CTS users.  Have 
methods and technologies been developed to enable such integrated provision of IP CTS?  We note that 
IVCS providers are permitted to meet the Part 14 performance objective of providing auditory 
information in visual form225 either by implementing a captioning solution on the platform itself or by 
using third-party solutions available to consumers at nominal cost.226  Some IVCS providers currently 
offer captioning.  To the extent that technology is developed for integrating IP CTS with video 
conferencing, are IVCS providers likely to implement such technology, either to comply with Part 14 or 
to provide an additional captioning option for users?  If the integrated provision of IP CTS with video 
conferencing is achievable, what rule changes would ensure appropriate use of such services in that 
context, while preventing waste, fraud, and abuse?  
94.Non-Internet-Based TRS.  We seek comment on whether and how the Commission 
should amend its rules to facilitate the provision in video conferences of non-Internet-based TRS—Text 
Telephone (TTY)-based TRS, Captioned Telephone Service (CTS), and Speech-to-Speech Relay 
(STS).227  These services, offered through state TRS programs, are intended for use on an ordinary 
224 As the Commission has noted, “IP Relay can be enhanced with adaptive technologies such as refreshable Braille 
displays and screen readers, making it particularly useful for consumers who are deafblind.”  Telecommunications 
Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities; Petition for 
Rulemaking of Sprint Corporation, CG Docket No. 03-123, RM-11820, Report and Order, FCC 22-48, para. 13 
(2022).  Also, “some people with speech disabilities may prefer to use IP Relay, a text-based service that does not 
involve any voice communications by registered users, rather than speech-to-speech relay service (STS).”  Id.
225 See 47 CFR § 14.21(b)(2)(iv).
226 See id. § 14.20(a)(3).  
227 For TTY-based TRS a user calls a relay center and types the number to be called.  The CA makes the telephone 
call and then relays the call between the parties by speaking what a text user types, and typing what a voice 
telephone user speaks.  For STS, a CA (who is specially trained in understanding a variety of speech disorders) 
repeats what the caller says in a manner that makes the caller’s words clear and understandable to the called party. 
CTS is similar to IP CTS, with captions being provided over the telephone network instead of the Internet.Federal Communications Commission FCC 23-50
35telephone line.  While users of these services may be able to participate in an IVCS call over a dial-up 
connection (where available), it is unclear whether or how these forms of TRS could be integrated with 
video conferencing platforms.  Further, given the availability of IP CTS and IP Relay, which provide the 
functionality of CTS and TTY-based TRS for users with Internet access, it seems unlikely that there 
would be significant demand for integrated provision of these services in Internet-based video 
conferences.  We seek comment on this assumption.  STS, however, has no Internet-based equivalent.  
For STS, would enabling the CA, as well as the user, to participate in the video portion of a video 
conference permit more effective communication for the STS user?  If so, have methods and technologies 
been developed to enable such integrated provision of STS?  What service-specific rule changes would 
facilitate such provision of STS, ensure appropriate use of STS in that context, and prevent waste, fraud, 
and abuse?
7. Rules Applicable to All TRS 
95. In the paragraphs below, we seek comment on proposed rule amendments that would be 
applicable both to VRS and to any other form of TRS that is integrated with video conferencing.
96.Confidentiality.  We propose to amend our TRS confidentiality rule228 to address the 
video conferencing context.  Specifically, we propose to amend the rule to expressly prohibit CAs from 
disclosing non-relayed content that is communicated in a video conference, or maintaining records of 
such content beyond the duration of the video conference.  We also propose to amend the confidentiality 
rule to codify our current practice that the rule expressly applies to TRS providers as well as CAs, so that 
the rule explicitly covers TRS calls (including but not limited to video conferences) where TRS is 
provided via automatic speech recognition or other automatic processes, without the involvement of a 
CA.229
97. The rule currently states that “CAs are prohibited from disclosing the content of any 
relayed conversation regardless of content, and … from keeping records of the content of any 
conversation beyond the duration of a call, even if to do so would be inconsistent with state or local 
law.”230  Some features of video conferences are not explicitly addressed by this rule.  For example, a CA 
may become aware of “sidebar” conversations between two or more video conference participants 
(whether in speech or sign language) that the CA concludes are not intended to be communicated to other 
participants.  Or the CA may review “chat” conversation or PowerPoints and other presentation material 
that the CA is not asked to relay to participants.  Therefore, such content would not be included in 
“relayed conversation.”  
98. The rule we propose would protect this content from disclosure and would require TRS 
providers and CAs to destroy any notes or records of such content upon termination of the call.231  We 
228 47 CFR § 64.604(a)(2).
229 See Misuse of Internet Protocol (IP) Captioned Telephone Service; Telecommunications Relay Services and 
Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket Nos. 13-24 and 01-
123, Report and Order, Declaratory Ruling, Further Notice of Proposed Rulemaking, and Notice of Inquiry, 33 FCC 
Rcd 5800, 5832, para. 60 (2018) (stating that IP CTS providers relying on ASR, rather than CAs, must adhere to 
TRS confidentiality rule); Telecommunications Relay Services and Speech-to-Speech Services for Individuals with 
Hearing and Speech Disabilities, CG Docket No. 03-123, Memorandum Opinion and Order, 35 FCC Rcd 4568, 
4572, para. 8 (CGB 2020) (stating that ASR-only IP CTS provider must maintain confidentiality of calls). 
230 47 CFR § 64.604(a)(2)(i).  There is a limited exception for Speech-to-Speech CAs:  “STS CAs may retain 
information from a particular call in order to facilitate the completion of consecutive calls, at the request of the user. 
The caller may request the STS CA to retain such information, or the CA may ask the caller if he wants the CA to 
repeat the same information during subsequent calls.  The CA may retain the information only for as long as it takes 
to complete the subsequent calls.”  Id.
231 For example, if a CA keeps notes during a call of, e.g., party names, specialized vocabulary, such notes must be 
destroyed at the end of the call.Federal Communications Commission FCC 23-50
36seek comment on this proposal.  Are additional amendments to our confidentiality rule necessary to 
protect the privacy of participants?  For example, should we also restrict CAs from disclosing the 
identities or other personal information regarding the participants in a video conference?  Should any of 
the proposed restrictions on non-relayed content be applicable to other types of calls? 
99.Exclusivity Contracts.  Consistent with the DAC’s recommendation,232 we propose to 
prohibit exclusivity arrangements between TRS providers and IVCS providers.  In general, an exclusivity 
arrangement is an express or implied agreement between a TRS provider and an IVCS provider that has 
the purpose or effect of preventing other providers from offering similar services to consumers.233  Such 
exclusivity arrangements may deprive consumers of the opportunity to rely on their chosen provider when 
using video conferencing services, contrary to the Commission’s policy.234  Similarly, such exclusivity 
arrangements also may deprive conference hosts of the opportunity to select their preferred IVCS 
provider.  What are the costs and benefits of exclusivity arrangements between TRS providers and IVCS 
providers?  What types of arrangements should we prohibit as de facto exclusivity agreements?  Are there 
any arrangements of this kind that should be allowed, e.g., because they would provide net economic 
benefits in this context?  Should we also prohibit exclusivity arrangements between TRS providers and 
manufacturers or suppliers of video conferencing equipment or software?  Should the Commission 
require that all contracts between TRS providers and IVCS service providers (or suppliers of video 
conferencing equipment or software) be available for inspection?  
100.TRS vs. Other Accessibility Measures.  We note that video conferencing can function as a 
substitute for in-person meetings as well as teleconferences.  Historically, the Commission has prohibited 
the use of TRS for in-person meetings.235  Further, many employers, educational institutions, health care 
providers, government agencies, and other entities currently provide ASL interpreting, captioning and 
other accommodations—either voluntarily or to fulfill obligations under the Americans with Disabilities 
Act or other laws236—to ensure that persons with hearing and speech disabilities can fully participate in 
meetings, classes, and other activities.  In these contexts, dedicated ASL interpreters, captioners, and 
others may be trained and gain experience in a specific subject matter and may have the opportunity to 
prepare in advance for a scheduled meeting or class.  We seek comment on the extent to which such 
accommodations, as well as accessibility features that may be available on a video conferencing 
platform,237 may be more effective than TRS in making video conferences accessible.238  Would the 
232 DAC Video Conferencing Report at 5.
233 See, e.g., Exclusive Service Contracts for Provision of Video Services in Multiple Dwelling Units and Other Real 
Estate Developments, MB Docket No. 07-51, Report and Order and Further Notice of Proposed Rulemaking, 22 
FCC Rcd 20235 (2007) (banning exclusive service contracts between cable operators and MDUs).
234 See Structure and Practices of the Video Relay Service Program; Telecommunications Relay Services and 
Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket Nos. 10-51 and 03-
123, 32 FCC Rcd 5891, 5908-10, paras. 34-36 (2017) (2017 VRS Compensation Order), aff’d sub nom. Sorenson 
Communications, LLC v. FCC, 897 F.3d 214 (2018); 2013 VRS Reform Order, 28 FCC Rcd at 8699, para. 200.
235 See Federal Communications Commission Clarifies That Certain Telecommunications Relay Services (TRS) 
Marketing and Call Handling Practices Are Improper and Reminds That Video Relay Service (VRS) May Not Be 
Used as a Video Remote Interpreting Service, Public Notice, 20 FCC Rcd 1471, 1474 (2005) (stating that, as a 
service providing access to the telephone network, VRS may not be used to interpret for two persons in the same 
location) (2005 TRS Practices Public Notice); 2019 TRS Definition Order, 34 FCC Rcd at 8487, paras. 10-11 
(explaining when the use of two TRS CAs on a call is compensable).
236 See, e.g., 42 U.S.C. § 12112(b)(5) (nondiscrimination in employment).
237 See supra Part IV.A.
238 See 28 CFR §§ 35.160(b)(2), 36.303(c)(ii) (“The type of auxiliary aid or service necessary to ensure effective 
communication will vary in accordance with the method of communication used by the individual; the nature, 
length, and complexity of the communication involved; and the context in which the communication is taking 
place.”).Federal Communications Commission FCC 23-50
37universal availability of TRS in video conferences reduce the incentives of video conference organizers 
and hosts to provide more effective forms of accessibility?  For example, is there a risk that the 
availability of integrated VRS in a video conference will dissuade organizers or hosts from voluntarily 
offering more effective ASL interpreting services, and if so, what steps should the Commission take to 
mitigate that risk?  More generally, how can the Commission ensure that the use of TRS in video 
conferences does not detract from the effective implementation of ADA and other legal requirements?  
101. Further, as stewards of the TRS Fund, we have an obligation to prevent waste and ensure 
that TRS is available in the most efficient manner.239  When a non-TRS accessibility solution has been 
made available by a video conference organizer or an IVCS provider, are there steps the Commission 
should take to prevent unnecessary and potentially confusing provision of a redundant TRS solution?  For 
example, if a video conference organizer employs or contracts for an ASL interpreting or captioning 
service, whether in fulfillment of legal obligations or voluntarily, should TRS Fund compensation be 
denied for the integrated provision of VRS in that video conference?  How would such a restriction be 
effectuated as a practical matter?  For instance, should we require a VRS provider that offers integrated 
VRS to ensure that when VRS is requested for a video conference, the organizer or host is prompted to 
confirm whether or not ASL interpretation is being separately provided?  To limit unnecessary requests 
for VRS, should we require IVCS providers to make available a symbol that call organizers can activate 
in a call invitation or notice to indicate that ASL interpreters will be supplied on the call?
102. As a related matter, we tentatively conclude that TRS providers must decline requests to 
reserve a TRS CA in advance of a scheduled video conference.  The provision of ASL interpreting, 
captioning, and other assistance by prior reservation is a different kind of service, which is available from 
other sources, such as VRI services.  The Commission has long held that the role of TRS is to be 
available for calls consumers choose to make, when they choose to make them, i.e., to be the “dial tone” 
for a call that requires assistance for effective communication.240  For this reason, the Commission 
requires TRS providers to handle service requests in the order in which they are received, in accordance 
with “speed-of-answer” standards.241  As a consequence, the Commission has found that the practice of 
permitting TRS users to reserve in advance a time at which a CA will handle a call is inconsistent with the 
nature of TRS and the functional equivalency mandate.242  Allowing TRS CAs to be reserved in advance 
for certain kinds of calls, such as video conferences, would raise the risk that service to other users would 
be degraded.  We seek comment on this tentative conclusion.  
8. Costs and Benefits
103. We seek comment on the costs and benefits of each of the proposed rule amendments and 
other possible changes discussed above, including:
(a) Authorizing the integrated provision of VRS and other types of TRS with video 
conferences; 
(b) Specifying modified methods of VRS user validation and call detail recording for video 
conferences;
(c) Addressing the use of multiple VRS CAs, service to multiple VRS users, and call 
takeover in video conferences;
239 47 U.S.C. § 225(b)(1).
240 See 2000 TRS Order, 15 FCC Rcd at 5165-66; Telecommunications Relay Services and Speech-to-Speech 
Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123, Report and Order and 
Declaratory Ruling, 22 FCC Rcd 20140, 20176, para. 96 (2007); Telecommunications Relay Services and Speech-to-
Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 03-123, Declaratory Ruling, 
20 FCC Rcd 1466, 1469, para. 8 (CGB 2005).
241 See 2000 TRS Order, 15 FCC Rcd at 5165-66, paras. 60-63; 47 CFR § 64.604(b)(2).
242 2005 TRS Practices Public Notice, 20 FCC Rcd 1471.Federal Communications Commission FCC 23-50
38(d) Changes to the privacy screen rule; 
(e) Changes to our TRS confidentiality rules; 
(f) Prohibiting exclusivity agreements between TRS providers and IVCS providers, 
equipment manufacturers, and software suppliers; and
(g) Preventing disincentives for and duplication of the provision of accommodations by 
video conference organizers and providers.
104. We also seek comment on the specific costs that providers of each type of TRS (as 
opposed to IVCS providers and other parties) would incur to provide service in video conferences on an 
integrated basis.  For example, we seek estimates of the research and development costs incurred by TRS 
providers to develop, and engineering costs to build, test, maintain, and update, those aspects of 
integration solutions in which a TRS provider is involved.  We also seek estimates of the costs TRS 
providers would incur to adapt their TRS operations (for example, by adjusting call routing protocols) to 
the integrated provision of TRS in video conferences, in accordance with our proposed rules.  To what 
extent could there be offsetting cost savings?  We also request that interested parties identify which costs 
would be appropriately identified as start-up or one-time costs, and which costs would be recurring.   
105. How is demand for VRS and other forms of TRS likely to change as a result of 
integrating TRS with video conferencing?  What is the projected impact of such increased use on costs 
and revenues for TRS providers?  To what extent could increases in TRS minutes of use due to 
integration of TRS with video conferencing off-set increased costs to provide such service?     
106.TRS Fund Compensation.  In general, we anticipate that allowable costs incurred by TRS 
providers to provide service that is integrated with video conferencing will be recovered pursuant to the 
Commission’s current processes.  That is, such costs will be reported annually by providers along with 
other allowable costs243 and will be recovered pursuant to compensation formulas determined in the 
relevant compensation proceedings for each form of TRS.244  However, we seek comment on any changes 
in cost categories that may be needed to reflect the costs of integration with IVCS platforms.  Will the 
provision of TRS on video conferencing platforms require changes to the forms on which TRS providers 
annually report cost and demand to the TRS Fund administrator?  Are additional limits on allowable costs 
needed to protect against waste, fraud, and abuse in the TRS program?
107. At least one VRS provider indicates it is already able to provide VRS with one IVCS 
provider on an integrated basis.245  Absent a mandate, any additional costs incurred by VRS providers to 
provide such service, if significantly higher than costs reported to the Administrator and reflected in 
applicable compensation formulas, would not be recoverable under our current guidelines for exogenous 
cost recovery.246  To encourage VRS providers to develop methods and technologies for providing VRS 
integrated with video conferencing, should the Commission provide a mechanism for additional cost 
recovery from the TRS Fund?  
C. Amendment of the Commission’s Rule on Multiple CAs 
108. Section 64.604(c)(14) of the Commission’s rules authorizes additional TRS Fund 
compensation for the involvement of multiple CAs in handling specified types of calls between two or 
more TRS users.247  We propose to amend this provision to state generally that compensation may be paid 
243 See 47 CFR § 64.604(c)(5)(iii)(D)(1) (describing annual cost data to be provided to TRS Fund administrator).
244 See, e.g., 2017 VRS Compensation Order, 32 FCC Rcd 5891.
245 See, e.g., Sorenson March 2023 Zoom Ex Parte; Sorenson-for-Zoom.
246 For example, one of the criteria for recovery of exogenous costs for VRS and IP CTS provides that the additional 
costs must result from new TRS service requirements or other causes beyond the provider’s control.  2017 VRS 
Compensation Order, 32 FCC Rcd at 5925, para. 66 (addressing exogenous cost recovery for VRS); 2020 IP CTS 
Order, 35 FCC Rcd at 10886, para. 39 (addressing exogenous cost recovery for IP CTS).
247 47 CFR § 64.604(c)(14).Federal Communications Commission FCC 23-50
39for the use of multiple CAs to handle TRS calls between users of different types of TRS where more than 
one CA is needed to handle the call.
109. Adopted in 2014, section 64.604(c)(14) currently states that compensation is authorized 
for the provision of multiple CAs to handle TRS calls between two or more users of captioned telephone 
service—CTS or IP CTS248—and for calls between a captioned telephone service user and a user of TTY-
based TRS or VRS.249  
110. The Commission adopted this provision in 2014 to codify certain existing practices 
brought to its attention, whereby compensation was paid for the use of multiple CAs to handle certain 
types of calls.250  Subsequently, the Commission amended the definition of “telecommunications relay 
service” to reflect the statutory definition of that term as amended by the CVAA.251  The amended 
definition provides that TRS enables functionally equivalent communication between “an individual who 
is deaf, hard of hearing, deaf-blind, or who has a speech disability” and “one or more individuals.”252  In 
proposing this amendment, the Commission explained that the revised definition “will allow 
compensation from the TRS Fund for relay calls involving two or more persons using different forms of 
relay services, including calls whose handling may require more than one CA.”253  However, in adopting 
the amended definition of TRS, the Commission did not modify the multiple-CA rule to reflect its stated 
intent regarding compensation for calls handled by multiple CAs.  As a result, some categories of calls 
that qualify as TRS under the amended statutory definition and that may warrant multiple CAs, are not 
currently addressed by the multiple-CA rule.254
111. We propose to amend the multiple-CA rule to broaden its scope, to more fully reflect the 
Commission’s stated intent in adopting the amended definition of TRS.  Under the proposed amendment, 
the rule would state that compensation may be paid for more than one CA to handle, among other 
categories, “[c]alls between users of different types of relay services where more than one CA is 
warranted.”255  We seek comment on this proposal.
248 Id. § 64.604(c)(14)(i).
249 Id. § 64.604(c)(14)(ii), (iii).
250 Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities; Waivers of iTRS Mandatory Minimum Standards, CG Docket No. 03-123, Order, Declaratory Ruling, 
and Further Notice of Proposed Rulemaking, 29 FCC Rcd 10697, 10718-19, para. 49 & n.189 (2014) (Multiple 
Relay Calls Order or TRS Definition Further Notice).
251 See 2019 TRS Definition Order, 34 FCC Rcd at 8487, para. 10.
252 47 CFR § 64.601(a)(43); see also 47 U.S.C. § 225(a)(3); CVAA, § 103(a).  Before enactment of the CVAA, TRS 
was defined as enabling functionally equivalent communication between “an individual who has a hearing 
impairment or speech impairment” and “an individual who does not have a hearing impairment or speech 
impairment.” 47 U.S.C. § 225(a)(3) (2009) (emphasis added).
253 TRS Definition Further Notice, 29 FCC Rcd at 10725, para. 65; see also id. at 10725, para. 64 (citing the 
legislative history of the CVAA); TRS Definition Order, 34 FCC Rcd at 8487, para. 10 (explaining that by revising 
the definition of TRS, the Commission “formally confirm[s] what our program administration already recognizes in 
practice—that in some instances, achieving communication between two individuals who have speech or hearing 
disabilities requires more than one type of relay service”).
254 For example, the current rule does not address when the use of two CAs is appropriate for calls between users of 
IP Relay and other forms of TRS.
255 Section 64.604(c)(14)(i) remains necessary to allow compensation for calls between users of the same captioning 
service.  See Multiple Relay Calls Order, 29 FCC Rcd at 10718-19, para. 49.Federal Communications Commission FCC 23-50
40D. Advancing Diversity, Equity, Inclusion, and Accessibility
112. The Commission, as part of its continuing effort to advance digital equity for all,256 
including people of color, persons with disabilities, persons who live in rural or Tribal areas, and others 
who are or have been historically underserved, marginalized, or adversely affected by persistent poverty 
or inequality, invites comment on any equity-related considerations257 and benefits, if any, that may be 
associated with the proposals and issues discussed herein.  Specifically, we seek comment on how our 
proposals may promote or inhibit advances in diversity, equity, inclusion, and accessibility.
V. ORDER
113. In this Order, we grant to all certified VRS providers a limited, partial waiver of the 
privacy screen rule258 to allow VRS users and CAs to turn off their videos during a video conference, 
subject to the conditions described below.  Pending Commission action on the proposals in this Notice, 
grant of this waiver will allow VRS providers flexibility to begin providing VRS integrated with video 
conferencing service without unduly disrupting current video conferencing practices. 
114. The privacy screen rule prohibits a VRS CA from enabling a visual privacy screen or 
similar feature during a VRS call and requires the CA to disconnect a VRS call if the caller or called party 
enables a visual privacy screen or similar feature for more than five minutes or is otherwise unresponsive 
or unengaged for more than five minutes.259  A “visual privacy screen” is defined as “[a] screen or any 
other feature that is designed to prevent one party or both parties on the video leg of a VRS call from 
viewing the other party during a call.”260   
115.Waiver Standard.  A Commission rule may be waived for “good cause shown.”261  In 
particular, a waiver is appropriate where the particular facts make strict compliance inconsistent with the 
public interest.262  In addition, we may take into account considerations of hardship, equity, or more 
effective implementation of overall policy on an individual basis.263  Good cause for a waiver may be 
found if special circumstances warrant a deviation from the general rule and such deviation will serve the 
public interest.264
256 Section 1 of the Communications Act of 1934 as amended provides that the FCC “regulat[es] interstate and 
foreign commerce in communication by wire and radio so as to make [such service] available, so far as possible, to 
all the people of the United States, without discrimination on the basis of race, color, religion, national origin, or 
sex.”  47 U.S.C. § 151.
257 The term “equity” is used here consistent with Executive Order 13985 as the consistent and systematic fair, just, 
and impartial treatment of all individuals, including individuals who belong to underserved communities that have 
been denied such treatment, such as Black, Latino, and Indigenous and Native American persons, Asian Americans 
and Pacific Islanders and other persons of color; members of religious minorities; lesbian, gay, bisexual, 
transgender, and queer (LGBTQ+) persons; persons with disabilities; persons who live in rural areas; and persons 
otherwise adversely affected by persistent poverty or inequality.  See Exec. Order No. 13985, 86 Fed. Reg. 7009, 
Executive Order on Advancing Racial Equity and Support for Underserved Communities Through the Federal 
Government (Jan. 20, 2021).
258 47 CFR § 64.604(a)(6).
259 Id.
260 Id. § 64.601(a)(52).
261 Id. § 1.3.
262 Northeast Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990).
263 WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969), cert. denied, 409 U.S. 1027 (1972); Northeast 
Cellular, 897 F.2d at 1166.
264 Northeast Cellular, 897 F.2d at 1166.Federal Communications Commission FCC 23-50
41116. As Sorenson explains, in a video conference, a participant may turn off his or her video 
camera for various reasons that may not indicate lack of engagement with the discussion—e.g., if the host 
requests that all participants turn off their videos unless speaking, to make it easier for participants who 
are deaf to view a sign language interpreter.265  Or, an interpreter may stop his or her video when a second 
interpreter is present and is interpreting a particular person’s voice or signing.  We agree with Sorenson 
that granting this limited waiver would “allow VRS users to use interactive video conferencing services 
without their video being activated beyond the current five-minute limitation, so that they can continue to 
receive VRS interpretation services for the duration of the interactive video conference, in the same 
manner as hearing users.”266  
117. We find good cause for granting this waiver, pending action on our proposed amendment 
of the privacy rule, to expedite the provision of integrated VRS in video conferences, so that VRS users 
can make full use of this increasing essential mode of communication “in a manner that is functionally 
equivalent to the ability of [a person without hearing or speech disabilities] to communicate using voice 
communication services.”267  As discussed above, video conferencing has become an essential means of 
communication for many Americans, and the record indicates that the integrated provision of VRS in 
video conferences is often necessary to enable sign-language users to communicate in a functionally 
equivalent manner.268  Absent a waiver, the privacy screen rule would substantially restrict the ability of 
VRS providers to explore promising technologies for the provision of such integrated VRS.
118. This waiver, which applies to all certified VRS providers, shall terminate one year from 
the date of this Order, or on the effective date of Commission amendments to section 64.604(a)(6), 
whichever is earlier.  The scope of the waiver is limited to “multi-party video conferences,” i.e., video 
conferences involving three or more participants, not including persons providing TRS or other 
accessibility services.  
119. To ensure that the TRS Fund administrator is able to effectively review the provision of 
integrated VRS in video conferences pursuant to this waiver, we require, as a condition of this limited 
waiver of section 64.604(a)(6), that a provider identify in its monthly compensation requests every video 
conference call in which VRS is provided on an integrated basis.  Further, a provider shall provide the 
TRS Fund administrator with all information reasonably requested to determine TRS Fund payments and 
the compensability of such video conference calls.269  In addition, given that IVCS-VRS integration 
solutions are still under development, we believe that consumers should be made aware of any limitations 
of such applications and should be able to contact the VRS provider immediately if the expected 
connection fails.  Therefore, as an additional condition on grant of this waiver, we require each VRS 
provider to prominently display a notice to its VRS consumers connecting to video conferencing services 
with this application stating that:
•This application for connecting to video conferencing services is in development and its 
features and functions may change as development continues;
•At this time, this application allows connections with only [name applicable IVCS 
265 Sorenson Petition at 4-5.
266 See id. at 9.
267 47 U.S.C. § 225(a)(3).
268 As discussed above, this is because the only current alternative for connecting a VRS CA to a video conference—
using a dial-up, voice-only connection—is often unavailable, and such connections pose multiple difficulties for 
VRS users.  See supra para. 74.
269 See 47 CFR § 64.604(c)(5)(iii)(D)(1) (“TRS providers seeking compensation from the TRS Fund shall provide 
the administrator with true and adequate data . . . reasonably requested to determine the TRS Fund revenue 
requirements and payments.”); see also supra Part IV.B.3 (seeking comment on the type of call detail needed to 
support requests for compensation for the provision of VRS integrated with video conferences).Federal Communications Commission FCC 23-50
42providers] and not to all video conferencing services; and,
•Consumers should contact a [name of VRS provider] representative at 
EMAIL/NUMBER if they cannot connect to a [name applicable IVCS provider] video 
conference with the application or if the application fails during a [name applicable IVCS 
provider] video conference after an initial connection.
This notice shall remain in place until termination of this waiver.
VI. PROCEDURAL MATTERS
120.Regulatory Flexibility Act.  The Regulatory Flexibility Act of 1980, as amended 
(RFA),270 requires that an agency prepare a regulatory flexibility analysis for notice and comment 
rulemakings, unless the agency certifies that “the rule will not, if promulgated, have a significant 
economic impact on a substantial number of small entities.271  In the Report and Order, the Commission 
declines to adopt rule changes and therefore a Final Regulatory Flexibility Analysis has not been 
performed.  The Commission seeks comment on potential rule and policy changes contained in the Notice 
of Proposed Rulemaking (Notice), and accordingly, has prepared an Initial Regulatory Flexibility 
Analysis (IRFA).  The IRFA is set forth in Appendix C.  Written public comments are requested on the 
IRFA.  Comments must be filed by the deadlines for comments on the Notice indicated on the first page 
of this document and must have a separate and distinct heading designating them as responses to the 
IRFA.
121.Congressional Review Act.  The Commission has determined, and the Administrator of 
the Office of Information and Regulatory Affairs, Office of Management and Budget, concurs, that this 
rule is non-major under the Congressional Review Act, 5 U.S.C. § 804(2).  The Commission will send a 
copy of this Report and Order, Notice of Proposed Rulemaking, and Order to Congress and the 
Government Accountability Office pursuant to 5 U.S.C. § 801(a)(1)(A).272
122.Paperwork Reduction Act Analysis.  The Report and Order does not contain new or 
modified or proposed information collections subject to the Paperwork Reduction Act of 1995 (PRA).273  
Therefore, it does not contain any new or modified information collection burden for small business 
concerns with fewer than 25 employees, pursuant to the Small Business Paperwork Relief Act of 2002.274
123.Initial Paperwork Reduction Act of 1995 Analysis.  The Notice of Proposed Rulemaking 
may contain new or modified information collection(s) subject to the PRA.275  If the Commission adopts 
any new or modified information collection requirements, they will be submitted to the Office of 
Management and Budget (OMB) for review under section 3507(d) of the PRA.  OMB, the general public, 
and other federal agencies are invited to comment on the new or modified information collection 
requirements contained in this proceeding.  In addition, pursuant to the Small Business Paperwork Relief 
Act of 2002,276 we seek specific comment on how we might “further reduce the information collection 
burden for small business concerns with fewer than 25 employees.”277 
124.Comments.  Pursuant to sections 1.415 and 1.419 of the Commission’s rules, interested 
270 The RFA, 5 U.S.C. §§ 601-602, was amended by the Small Business Regulatory Enforcement Fairness Act of 
1996 (SBREFA), Pub. L. No. 104-121, Title II, 110 Stat. 857 (1996).
271 5 U.S.C. §§ 603, 605(b).
272 Id. § 801(a)(1)(A).
273 Paperwork Reduction Act of 1995, 44 U.S.C. §§ 3501-3520 (2016).
274 44 U.S.C. § 3506(c)(4).
275 Public Law 104-13.
276 Public Law 107-198.
277 44 U.S.C. § 3506(c)(4).Federal Communications Commission FCC 23-50
43parties may file comments on or before the dates indicated on the first page of this document.278  
Comments may be filed using the Commission’s Electronic Comment Filing System (ECFS).279    
•Electronic Filers:  Comments may be filed electronically using the Internet by accessing the 
ECFS:  https://www.fcc.gov/ecfs/filings.  
•Paper Filers:  
oParties who choose to file by paper must file an original and one copy of each filing.  If 
more than one docket or rulemaking number appears in the caption of this proceeding, 
filers must submit two additional copies for each additional docket or rulemaking 
number.
oFilings can be sent by hand or messenger delivery, by commercial overnight courier, or 
by first-class or overnight U.S. Postal Service mail.  All filings must be addressed to the 
Commission’s Secretary, Office of the Secretary, Federal Communications Commission.
Currently, the Commission does not accept any hand delivered or messenger delivered filings as a 
temporary measure taken to help protect the health and safety of individuals, and to mitigate the 
transmission of COVID-19.  In the event that the Commission announces the lifting of COVID-19 
restrictions, a filing window will be opened at the Commission’s office located at 9050 Junction Drive, 
Annapolis Junction, MD 20701.280   
oCommercial overnight mail (other than U.S. Postal Service Express Mail and Priority 
Mail) must be sent to 9050 Junction Drive, Annapolis Junction, MD 20701.
oU.S. Postal Service first-class, Express, and Priority mail may be addressed to 45 L 
Street, NE, Washington, DC 20554. 
oDuring the time the Commission’s building is closed to the general public and until 
further notice, if more than one docket or rulemaking number appears in the caption of a 
proceeding, paper filers need not submit two additional copies for each additional docket 
or rulemaking number; an original and one copy are sufficient.
125.Ex Parte Rules.  The proceeding the Notice of Proposed Rulemaking initiates shall be 
treated as a “permit-but-disclose” proceeding in accordance with the Commission’s ex parte rules.281  
Persons making ex parte presentations must file a copy of any written presentation or a memorandum 
summarizing any oral presentation within two business days after the presentation (unless a different 
deadline applicable to the Sunshine period applies).  Persons making oral ex parte presentations are 
reminded that memoranda summarizing the presentation must (1) list all persons attending or otherwise 
participating in the meeting at which the ex parte presentation was made, and (2) summarize all data 
presented and arguments made during the presentation.  If the presentation consisted in whole or in part of 
the presentation of data or arguments already reflected in the presenter’s written comments, memoranda 
or other filings in the proceeding, the presenter may provide citations to such data or arguments in his or 
her prior comments, memoranda, or other filings (specifying the relevant page and/or paragraph numbers 
278 47 CFR §§ 1.415, 1.419.
279 See FCC, Electronic Filing of Documents in Rulemaking Proceedings, 63 Fed. Reg. 24121 (May 1, 1998).
280 See FCC Announces Closure of FCC Headquarters Open Window and Change in Hand-Delivery Policy, Public 
Notice, 35 FCC Rcd 2788 (OMD 2020), https://www.fcc.gov/document/fcc-closesheadquarters-open-window-and-
changes-hand-delivery-policy.
281 47 CFR § 1.1200 et seq.Federal Communications Commission FCC 23-50
44where such data or arguments can be found) in lieu of summarizing them in the memorandum.  
Documents shown or given to Commission staff during ex parte meetings are deemed to be written ex 
parte presentations and must be filed consistent with section 1.1206(b).  In proceedings governed by 
section 1.49(f) or for which the Commission has made available a method of electronic filing, written ex 
parte presentations and memoranda summarizing oral ex parte presentations, and all attachments thereto, 
must be filed through the electronic comment filing system available for that proceeding, and must be 
filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf).  Participants in this proceeding should 
familiarize themselves with the Commission’s ex parte rules.
126.People with Disabilities:  To request materials in accessible formats for people with 
disabilities (Braille, large print, electronic files, audio format), send an e-mail to fcc504@fcc.gov or call 
the Consumer and Governmental Affairs Bureau at 202-418-0530.
127.Availability of Documents.  Comments, reply comments, and ex parte submissions will be 
available via ECFS.  Documents will be available electronically in ASCII, Microsoft Word, and/or Adobe 
Acrobat.  When the FCC Headquarters reopens to the public, these documents will also be available for 
public inspection during regular business hours in the FCC Reference Center, Federal Communications 
Commission, 45 L Street NE, Washington, DC  20554.
128.Additional Information.  For additional information on this proceeding, contact William 
Wallace, Disability Rights Office, Consumer and Governmental Affairs Bureau, at 202-418-2716, or 
William.Wallace@fcc.gov.
VII. ORDERING CLAUSES
129. Accordingly, IT IS ORDERED that, pursuant to sections 1, 2, 3, and 716 of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 151, 152, 153, 617, the foregoing Report and 
Order IS ADOPTED.
130. IT IS FURTHER ORDERED that the Report and Order SHALL BE EFFECTIVE 30 
days after publication of a summary in the Federal Register.
131. IT IS FURTHER ORDERED that the date for complying with the Report and Order 
SHALL BE one year and 30 days after publication of a summary in the Federal Register.  The Consumer 
and Governmental Affairs Bureau shall announce the compliance date by subsequent Public Notice.
132. IT IS FURTHER ORDERED that the Office of the Managing Director, Performance and 
Program Management, SHALL SEND a copy of this Report and Order in a report to be sent to Congress 
and the Government Accountability Office pursuant to the Congressional Review Act, 5 U.S.C. § 
801(a)(1)(A).
133. IT IS FURTHER ORDERED that, pursuant to sections 1, 2, 3, (4)(i), (4)(j), 225, and 716 
of the Communications Act of 1934, as amended, 47 U.S.C. §§ 151, 152, 153, 154(i), 154(j), 225, and 
617, the foregoing Notice of Proposed Rulemaking IS ADOPTED.
134. IT IS FURTHER ORDERED that, pursuant to applicable procedures set forth in sections 
1.415 and 1.419 of the Commission’s Rules, 47 CFR §§ 1.415, 1.419, interested parties may file 
comments on the Notice of Proposed Rulemaking on or before 30 days after publication in the Federal 
Register, and reply comments on or before 60 days after publication in the Federal Register.
135. IT IS FURTHER ORDERED that Sorenson’s Petition for Limited Waiver of the Privacy 
Screen Rule is GRANTED to the extent specified herein. 
136. IT IS FURTHER ORDERED that, pursuant to sections 1, 2, 4(i), 4(j), and 225 of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 151, 152, 154(i), 154(j), and 225, the foregoing 
ORDER IS ADOPTED.
137. IT IS FURTHER ORDERED that, pursuant to sections 1, 2, 4(i), 4(j), and 225 of the 
Communications Act of 1934, as amended, and section 1.3 of the Commission’s Rules, 47 CFR § 1.3, the Federal Communications Commission FCC 23-50
45restrictions on use of privacy screens with Video Relay Service in section 64.604(a)(6) of the 
Commission’s rules, 47 CFR § 64.604(a)(6), are TEMPORARILY WAIVED to the extent set forth in the 
Order, for one year or until the effective date of Commission action amending this provision, whichever is 
earlier.
138. IT IS FURTHER ORDERED that, pursuant to sections 1.4(b) and 1.103(a) of the 
Commission’s rules, 47 CFR §§ 1.4(b) and 1.103(a), the ORDER SHALL BE EFFECTIVE upon release.
139. IT IS FURTHER ORDERED that the Commission’s Office of the Secretary, Reference 
Information Center, SHALL SEND a copy of the Report and Order, Notice of Proposed Rulemaking, and 
Order, including the Initial Regulatory Flexibility Analysis, to the Chief Counsel for Advocacy of the 
Small Business Administration.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
SecretaryFederal Communications Commission FCC 23-50
46APPENDIX A 
List of Commenters
The complete record in this proceeding is available in the Commission’s Electronic Comment Filing 
System located at https://www.fcc.gov/ecfs/.
Commenters on the 2011 IVCS Further Notice
Implementation of Sections 716 and 717 of the Communications Act of 1934, as Enacted by the Twenty-
First Century Communications and Video Accessibility Act of 2010; Amendments to the Commission’s 
Rules Implementing Sections 255 and 251(a)(2) of the Communications Act of 1934, as Enacted by the 
Telecommunications Act of 1996; Accessible Mobile Phone Options for People who are Blind, Deaf-
Blind, or Have Low Vision, CG Docket No. 10-213, WT Docket No. 96-198, CG Docket No. 10-145, 
Report and Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 14557 (2011) (2011 IVCS 
Further Notice)
Comments
Abbreviation Commenter
ACB American Council of the Blind
APTS Association of Public Television Stations
AT&T AT&T Services, Inc.
ATIS Alliance for Telecommunications Industry Solutions
CEA Consumer Electronics Association
Citrix Online
CSDVRS CSDVRS, LLC
CTA Consumer Electronics Association
Consumer Groups Telecommunications for the Deaf and Hard of Hearing, Inc., et al
DirecTV DirecTV and DISH Network, LLC
ESA Entertainment Software Association
Harry Brown
Larry Goldberg
Net Coalition
ITI Information Technology Industry Council 
Jonathan Eckrich
Michigan PSC Michigan Public Service Corporation
Microsoft Corporation
Motorola Motorola Solutions, Inc.
NAB National Association of Broadcasters
NCTA National Cable and Telecommunications Association
RERC-IT/RERC-TA Rehabilitation Engineering Research Centers on Universal Interface & 
Information Technology Access (RERC-IT) and Telecommunications Access 
(RERC-TA)
TDI Telecommunications for the Deaf and Hard of Hearing, Inc.Federal Communications Commission FCC 23-50
47Tech America
TIA Telecommunications Industry Association
Time Warner Time Warner Cable, Inc.
T-Mobile T-Mobile USA
Verizon
Verizon Wireless
Voice on the Net Coalition
The Walt Disney Company
Words+ Words+, Inc. and Compusult Systems, Inc.
Reply Comments
Abbreviation Commenter
AAPD American Association of People with Disabilities
ACA American Cable Association
ACB American Council of the Blind
AFB American Federation for the Blind
AT&T AT&T Services, Inc.
CEA Consumer Electronics Association
CTIA CTIA – The Wireless Association
Cristina Hartmann
ESA Entertainment Software Association
Hamilton Relay Hamilton Relay, Inc. and Purple Communications, Inc.
Gillian Green
Microsoft Corporation
NAB National Association of Broadcasters
NCTA National Cable and Telecommunications Association
Nintendo Nintendo of America, Inc.
RERC-TA Rehabilitation Engineering Research Center on Telecommunications Access
Sprint Sprint Nextel Corporation
TDI Telecommunications for the Deaf and Hard of Hearing, Inc., et al
T-Mobile T-Mobile USA
Verizon
Verizon WirelessFederal Communications Commission FCC 23-50
48Commenters on the 2021 CVAA Refresh Public Notice
Consumer and Governmental Affairs, Media, And Wireless Telecommunications Bureaus Seek Update On 
Commission’s Fulfillment of The Twenty-First Century Communications and Video Accessibility Act, GN 
Docket No. 21-140, Public Notice, 36 FCC Rcd 7108 (2021) (2021 CVAA Refresh Public Notice)
Comments
Abbreviation Commenter
AAI Alliance for Automotive Innovation
AARO Accessibility Advocacy and Research Organizations (AARO):  
Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), American 
Association of the DeafBlind (AADB), American Deafness and Rehabilitation 
Association (ADARA), Association of Late-Deafened Adults (ALDA), 
California Coalition of Agencies Serving the Deaf and Hard of Hearing 
(CCASDHH), Cerebral Palsy and Deaf Organization (CPADO), 
Communications Service for the Deaf (CSD), Conference of Educational 
Administrators of Schools and Programs for the Deaf (CEASD), Cuesign, Inc., 
Deaf Seniors of America (DSA), Hearing Loss Association of America (HLAA), 
HEARD, National Association of the Deaf (NAD), National Black Deaf 
Advocates (NBD), National Cued Speech Association (NCSA), National 
Hispanic Latino Association of the Deaf (NHLAD), Northern Virginia Resource 
Center for Deaf and Hard of Hearing Persons (NVRC), Registry of Interpreters 
for the Deaf (RID), Rehabilitation Engineering Research Center on Technology 
for the Deaf and Hard of Hearing, Gallaudet University (DHH-RERC), 
Rehabilitation Engineering Research Center on Universal Interface & 
Information Technology Access (IT-RERC), Rehabilitation Engineering 
Research Center for Wireless Inclusive Technologies, Georgia Institute of 
Technology (Wireless RERC), and RIT/NTID Center on Access Technology 
(CAT)
ACA Connects America’s Communications Association
ACB American Council of the Blind
AFB American Federation for the Blind
CTA Consumer Technology Association
CTIA CTIA – The Wireless Association
ITI Information Technology Industry Council
NAB National Association of Broadcasters
NCTA NCTA – Internet & Television Association
NFB National Federation of the Blind
Reply Comments
Abbreviation Commenter
AARO Accessibility Advocacy and Research Organizations (AARO):  
Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), American 
Association of the DeafBlind (AADB), American Deafness and Rehabilitation 
Association (ADARA), Association of Late-Deafened Adults (ALDA), 
California Coalition of Agencies Serving the Deaf and Hard of Hearing Federal Communications Commission FCC 23-50
49(CCASDHH), Cerebral Palsy and Deaf Organization (CPADO), 
Communications Service for the Deaf (CSD), Conference of Educational 
Administrators of Schools and Programs for the Deaf (CEASD), Cuesign, Inc., 
Deaf Seniors of America (DSA), Hearing Loss Association of America (HLAA), 
HEARD, National Association of the Deaf (NAD), National Black Deaf 
Advocates (NBD), National Cued Speech Association (NCSA), National 
Hispanic Latino Association of the Deaf (NHLAD), Northern Virginia Resource 
Center for Deaf and Hard of Hearing Persons (NVRC), Registry of Interpreters 
for the Deaf (RID), Rehabilitation Engineering Research Center on Technology 
for the Deaf and Hard of Hearing, Gallaudet University (DHH-RERC), 
Rehabilitation Engineering Research Center on Universal Interface & 
Information Technology Access (IT-RERC), Rehabilitation Engineering 
Research Center for Wireless Inclusive Technologies, Georgia Institute of 
Technology (Wireless RERC), and RIT/NTID Center on Access Technology 
(CAT)
ACA Connects America’s Communications Association
CTA Consumer Technology Association
NAB National Association of Broadcasters
Sorenson Sorenson Communications, LLC
Wireless RERC Rehabilitation Engineering Research Center for Wireless Inclusive Technologies
Zoom Zoom Video Communications, Inc.
Commenters on the 2022 IVCS Refresh Public Notice
Consumer and Governmental Affairs Bureau Seeks to Refresh the Record on Interoperable Video 
Conferencing Services, CG Docket No. 10-213, DA 22-463 (Apr. 27, 2022) (2022 IVCS Refresh Public 
Notice)
Comments
Abbreviation Commenter
AARO Accessibility Advocacy and Research Organizations (AARO):  
Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), American 
Association of the DeafBlind (AADB), American Deafness and Rehabilitation 
Association (ADARA), Association of Late-Deafened Adults (ALDA), 
California Coalition of Agencies Serving the Deaf and Hard of Hearing 
(CCASDHH), Cerebral Palsy and Deaf Organization (CPADO), 
Communications Service for the Deaf (CSD), Conference of Educational 
Administrators of Schools and Programs for the Deaf (CEASD), Cuesign, Inc., 
Deaf Seniors of America (DSA), Hearing Loss Association of America (HLAA), 
HEARD, National Association of the Deaf (NAD), National Black Deaf 
Advocates (NBD), National Cued Speech Association (NCSA), National 
Hispanic Latino Association of the Deaf (NHLAD), Northern Virginia Resource 
Center for Deaf and Hard of Hearing Persons (NVRC), Registry of Interpreters 
for the Deaf (RID), Rehabilitation Engineering Research Center on Technology 
for the Deaf and Hard of Hearing, Gallaudet University (DHH-RERC), 
Rehabilitation Engineering Research Center on Universal Interface & 
Information Technology Access (IT-RERC), Rehabilitation Engineering 
Research Center for Wireless Inclusive Technologies, Georgia Institute of Federal Communications Commission FCC 23-50
50Technology (Wireless RERC), and RIT/NTID Center on Access Technology 
(CAT)
ACB American Council of the Blind
AFB American Federation for the Blind
ClearCaptions ClearCaptions, LLC
CTA Consumer Technology Association
CTIA CTIA – The Wireless Association
PPI Prison Policy Initiative
Reply Comments
Abbreviation Commenter
AARO Accessibility Advocacy and Research Organizations (AARO):  
Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), American 
Association of the DeafBlind (AADB), American Deafness and Rehabilitation 
Association (ADARA), Association of Late-Deafened Adults (ALDA), 
California Coalition of Agencies Serving the Deaf and Hard of Hearing 
(CCASDHH), Cerebral Palsy and Deaf Organization (CPADO), 
Communications Service for the Deaf (CSD), Conference of Educational 
Administrators of Schools and Programs for the Deaf (CEASD), Cuesign, Inc., 
Deaf Seniors of America (DSA), Hearing Loss Association of America (HLAA), 
HEARD, National Association of the Deaf (NAD), National Black Deaf 
Advocates (NBD), National Cued Speech Association (NCSA), National 
Hispanic Latino Association of the Deaf (NHLAD), Northern Virginia Resource 
Center for Deaf and Hard of Hearing Persons (NVRC), Registry of Interpreters 
for the Deaf (RID), Rehabilitation Engineering Research Center on Technology 
for the Deaf and Hard of Hearing, Gallaudet University (DHH-RERC), 
Rehabilitation Engineering Research Center on Universal Interface & 
Information Technology Access (IT-RERC), Rehabilitation Engineering 
Research Center for Wireless Inclusive Technologies, Georgia Institute of 
Technology (Wireless RERC), and RIT/NTID Center on Access Technology 
(CAT)
ACB American Council of the Blind
AFB American Federation for the Blind
CTA Consumer Technology Association
CTIA CTIA – The Wireless Association
Richard Lorenzo Ray
Sorenson Sorenson Communications, LLC
ZP Better Together ZP Better Together, LLCFederal Communications Commission FCC 23-50
51Commenters on Accessibility of Communications Technologies (2022 CVAA Biennial Report) 
Consumer and Governmental Affairs Bureau Seeks Comment on the Accessibility of Communications 
Technologies for the 2022 Biennial Report Required by the Twenty-First Century Communications and 
Video Accessibility Act, CG Docket No. 10-213, Public Notice, DA 22-160 (CGB Feb. 16, 2022) 
(Assessment Public Notice)
Abbreviation Commenter
ACB American Council of the Blind
AFB American Foundation for the Blind
CACP Center for Advanced Communications Policy 
CTA Consumer Technology Association
CTIA CTIA - The Wireless Association
DHH CAO Comments by Deaf and Hard of Hearing Consumer Advocacy Organizations 
were filed on behalf of Telecommunications for the Deaf and Hard of Hearing, 
Inc., American Association of the DeafBlind, Association of Late-Deafened 
Adults, Center on Access Technology, Communication Service for the Deaf, 
Conference of Educational Administrators of Schools and Programs for the Deaf, 
Deaf Seniors of America, Hearing Loss Association of America, National 
Association of the Deaf, Northern Virginia Resource Center of Deaf and Hard of 
Hearing Persons, Registry of Interpreters for the Deaf, and the Rehabilitation 
Engineering Research Center on Technology for the Deaf and Hard of Hearing.
HBDE Hawaii Broadband & Digital Equity Office et al.
Commenters on the Tentative Findings for the 2022 CVAA Biennial Report to Congress 
Consumer and Governmental Affairs Bureau Seeks Comment on Tentative Findings for the 2022 Twenty-
First Century Communications and Video Accessibility Act Biennial Report, CG Docket No. 10-213, 
Public Notice, DA 22-661 (CGB June 22, 2022) (Tentative Findings Public Notice)
Abbreviation Commenter
CACP Center for Advanced Communications Policy 
CTA Consumer Technology Association
NFB National Federation of the Blind
Commenters on the Sorenson Waiver Petition
Consumer and Governmental Affairs Bureau Seeks Comment On Sorenson Communications, LLC’s 
Petition for a Limited Waiver of the Privacy Screen Rule for Video Relay Service, CG Docket Nos. 03-
123 and 10-51, Public Notice, DA 23-28 (CGB Jan. 12, 2023)
Abbreviation Commenter
AARO Accessibility Advocacy and Research Organizations (AARO):  
Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), 
Communication Service for the Deaf (CSD); Hearing Loss Association of 
America (HLAA); National Association of the Deaf (NAD); Rehabilitation 
Engineering Research Center on Technology for the Deaf and Hard of Hearing, 
Gallaudet University (DHH-RERC)Federal Communications Commission FCC 23-50
52APPENDIX B
Proposed Rules
The Federal Communications Commission proposes to amend 47 CFR parts 14 and 64 as follows:
PART 14 – ACCESS TO ADVANCED COMMUNICATION SERVICES AND EQUIPMENT BY 
PERSONS WITH DISABILITIES 
1. The authority citation for part 14 continues to read as follows: 
Authority: 47 U.S.C. 151–154, 255, 303, 403, 503, 617, 618, 619 unless otherwise noted. 
2. Amend § 14.21 by revising paragraphs (b)(1)(ix) and (b)(2)(iv) and adding paragraph 
(b)(4) to read as follows:
§ 14.21 Performance Objectives.
* * * * *
(b) * * *
(1) * * *
(ix) Operable without speech.  Provide at least one mode that does not require user speech.  For 
interoperable video conferencing services, provide at least text-to-speech capability.
* * * * *
(2) * * *
(iv) Availability of auditory information.  Provide auditory information through at least one mode in 
visual form and, where appropriate, in tactile form.  For interoperable video conferencing services, 
provide at least one mode with captions that are accurate and synchronous.  The accuracy and latency of 
such captions should be comparable to that provided on TRS Fund-supported captioned telephone 
services.  
* * * * *
(4) Interoperable Video Conferencing Service.  
(i) Sign language interpretation.  Interoperable video conferencing services shall enable the use of sign 
language interpretation, including the transmission of user requests for sign language interpretation to 
providers of video relay service and other entities and the provision of sufficient video quality to support 
sign language communication. 
(ii) User interface.  Interoperable video conferencing services shall provide user interface control 
functions that permit users to adjust the display of captions, speakers and signers, and other features for 
which user interface control is necessary for accessibility.
PART 64 - MISCELLANEOUS RULES RELATING TO COMMON CARRIERS 
3. The authority citation for part 64 continues to read as follows: 
Authority: 47 U.S.C. 151, 152, 154, 201, 202, 217, 218, 220, 222, 225, 226, 227, 227b, 228, 251(a), 
251(e), 254(k), 255, 262, 276, 403(b)(2)(B), (c), 616, 617, 620, 1401–1473, unless otherwise noted; Pub. 
L. 115–141, Div. P, sec. 503, 132 Stat. 348, 1091. 
4. The authority citation for subpart F continues to read as follows: 
Authority: 47 U.S.C. 151–154; 225, 255, 303(r), 616, and 620.  Federal Communications Commission FCC 23-50
535. Amend § 64.601(a) by:
a. Redesignating paragraphs (a)(21) through (24) as paragraphs (a)(22) through (25), and 
adding new paragraph (a)(21); 
b. Redesignating paragraphs (a)(25) and (26) as paragraphs (a)(27) and (28), and adding 
new paragraph (a)(26);
c. Redesignating paragraphs (a)(27) through (50) as paragraphs (a)(30) through (53), and 
adding new paragraph (29); and 
d. Redesignating paragraphs (a)(51) through (55) as paragraphs (a)(55) through (59); and 
adding new paragraph (a)(54).
The additions read as follows: 
§ 64.601 Definitions and provisions of general applicability.
(a) * * *
(21) Integrated VRS.  The provision of VRS in a video conference whereby the CA is included as a 
participant in the video conference and communication between the CA and the participants takes place 
on the video conferencing platform rather than through a separate connection.
* * * * *
(26) Interoperable video conference service (IVCS).  Has the meaning defined in part 14 of this chapter.
* * * * *
(29) Multi-party video conference.  A video conference call with three or more participants, excluding 
VRS CAs and any other participant providing an accommodation for a participant.
* * * * *
(54) Video conference.  A session of IVCS involving two-way real-time communication between two or 
more IVCS users.
* * * * *
6. Amend § 64.604 by: 
a. Revising paragraphs (a)(2)(i) and (a)(6);
b. Adding paragraph (c)(5)(iii)(D)(2)(xi);
c. Revising paragraphs (c)(5)(iii)(E)(2), (c)(13)(i)(C), and (c)(14);
d. Adding paragraph (c)(15); and
e. Revising paragraph (d).
The revisions and additions read as follows:
§ 64.604 Mandatory minimum standards.
(a) * * * 
(2) * * *
(i) Except as authorized by section 705 of the Communications Act, 47 U.S.C. 605, TRS providers and 
CAs are prohibited from disclosing the content of any relayed conversation (and any non-relayed content 
communicated in a video conference) regardless of content, and with a limited exception for STS CAs, 
from keeping records of the content of any conversation (and any non-relayed content communicated in a 
video conference) beyond the duration of a call, even if to do so would be inconsistent with state or local 
law. STS CAs may retain information from a particular call in order to facilitate the completion of Federal Communications Commission FCC 23-50
54consecutive calls, at the request of the user. The caller may request the STS CA to retain such 
information, or the CA may ask the caller if he wants the CA to repeat the same information during 
subsequent calls. The CA may retain the information only for as long as it takes to complete the 
subsequent calls. 
* * * * *
(6) Visual privacy screens/idle calls. 
(i) Except as provided in paragraph (a)(6)(ii)(A) of this section, a VRS CA may not enable a visual 
privacy screen or similar feature during a VRS call.  Except as provided in paragraph (a)(6)(ii)(B) of this 
section, a VRS CA must disconnect a VRS call if the caller or the called party to a VRS call enables a 
privacy screen or similar feature for more than five minutes or is otherwise unresponsive or unengaged 
for more than five minutes, unless the call is a 9-1-1 emergency call or the caller or called party is 
legitimately placed on hold and is present and waiting for active communications to commence.  Prior to 
disconnecting the call, the CA must announce to both parties the intent to terminate the call and may 
reverse the decision to disconnect if one of the parties indicates continued engagement with the call.
(ii) A VRS CA providing integrated VRS in a multi-party video conference:
(A) May temporarily turn off the CA’s video camera when engaged in team interpreting, if the other CA 
is actively providing ASL interpretation;
(B) May stay connected to the video conference if the VRS user who requested service has turned off the 
user’s camera, as long as that user stays connected to the video conference; and
(C) If five minutes elapse in which no party is responsive or engaged in conversation, the CA shall 
announce that VRS will be terminated and shall disconnect from the video conference.
* * * * *
(c) * * * 
(5) * * *
(iii) * *  *
(D) * * * 
(2) * * *
(xi) For the provision of integrated VRS in a video conference, in lieu of the information specified in 
paragraphs (v) and (vi) of this section, a VRS provider may submit information, in accordance with 
instructions issued by the administrator, that sufficiently identifies the VRS user requesting service and 
the video conference in which service was provided. 
* * * * *
(E) * * *
(2) TRS minutes of use for purposes of cost recovery from the TRS Fund are defined as the minutes of 
use for completed interstate or Internet-based TRS calls placed through the TRS center beginning after 
call set-up and concluding after the last message call unit.  For video conferences, a VRS provider’s TRS 
minutes of use begin when a VRS CA is connected to a video conference and two or more participants are 
actively present, and ends when the CA disconnects from the video conference or when fewer than two 
participants are actively present, whichever is earlier.  
* * * * *
(14) TRS calls requiring the use of multiple CAs.  TRS Fund compensation may be paid for more than one 
CA to handle the following types of calls: 
(i) VCO-to-VCO calls between multiple captioned telephone relay service users, multiple IP CTS users, Federal Communications Commission FCC 23-50
55or captioned telephone relay service users and IP CTS users; 
(ii) Calls between users of different types of relay services for which more than one CA is warranted;
and
(iii) Video conferences where more than one CA is warranted.
(15) Exclusivity Agreements.  A TRS provider may not enter into an agreement or any other arrangement 
with an IVCS provider if such agreement or arrangement would give the TRS provider exclusive access 
among TRS providers to the IVCS provider’s facilities or such agreement or arrangement would give the 
IVCS provider exclusive access among IVCS providers to the TRS provider’s service via a video 
connection.
(d) The applicable requirements of § 9.14 of this chapter and §§ 64.611, 64.615, 64.621, 64.631, 64.632, 
64.644, 64.5105, 64.5107, 64.5108, 64.5109, and 64.5110 are to be considered mandatory minimum 
standards.
7. Amend § 64.615 by revising paragraph (a)(1)(i) to read as follows: 
§ 64.615 TRS User Registration Database and administrator.
(a) * * *
(1) * * * 
(i) Validation shall occur during the call setup process, prior to the placement of the call, except that 
validation of the provision of integrated VRS in a video conference shall occur prior to the connection of 
a VRS CA to the video conference.
* * * * *
8. Add § 64.644 to subpart F to read as follows:
§ 64.644 Provision of Integrated VRS in Video Conferences
(a) A VRS provider may provide integrated VRS in a video conference upon request by a registered VRS 
user (or by a person authorized by a registered enterprise VRS user).  
(b) A VRS provider providing integrated VRS in a video conference shall:
(i) Collect from the party requesting service sufficient information to confirm the requesting party’s 
registration for VRS pursuant to the applicable requirements of §§ 64.611 and 64.615; and
(ii) Terminate the CA’s connection to the video conference no later than when the requesting VRS user 
disconnects from the video conference.
(c) A VRS provider may assign more than one CA to participate in a multi-party video conference.Federal Communications Commission FCC 23-50
56APPENDIX C
Initial Regulatory Flexibility Analysis
1. As required by the Regulatory Flexibility Act of 1980, as amended (RFA),1 the 
Commission has prepared this Initial Regulatory Flexibility Analysis (IRFA) of the possible significant 
economic impact on a substantial number of small entities by the policies and rules proposed in the 
Notice of Proposed Rulemaking (Notice).  Written public comments are requested on this IRFA.  
Comments must be identified as responses to the IRFA and must be filed by the deadline for comments 
on the Notice provided in the item.  The Commission will send a copy of the entire Notice, including this 
IRFA, to the Chief Counsel for Advocacy of the Small Business Administration (SBA).2  In addition, the 
Notice and the IRFA (or summaries thereof) will be published in the Federal Register.3
A. Need for, and Objective of, Proposed Rules
2. In the Notice, the Commission proposes to amend its rules to improve the accessibility of 
Interoperable Video Conferencing Services (IVCS), a form of Advanced Communication Service (ACS).4  
First, the Commission proposes to amend its Part 14 rules, which govern accessibility of ACS.  The 
Commission proposes to add performance objectives that specifically enable the accessibility of IVCS.5  
The Commission proposes that such performance objectives include the provision of (1) speech-to-text 
(captioning) capabilities; (2) text-to-speech capabilities; and (3) enabling of American Sign Language 
(ASL) interpreting.  The Commission seeks comment on whether additional Part 14 amendments are 
needed to ensure that video conferencing is accessible.  The Commission also seeks comment on whether 
technical standards are available or could be fashioned for use as safe harbors.6
3. Second, the Commission proposes to amend its Part 64 rules governing TRS to provide 
that the Interstate TRS Fund can be used to support the integrated provision of relay service in video 
conferences—whether or not the video conferencing platform can be accessed via a dial-up telephone 
call.7  In addition, the Commission proposes to modify its rules to facilitate such integration, ensure the 
appropriate use of VRS with video conferencing, and prevent waste, fraud, and abuse.8  
B. Legal Basis
4. The authority for this proposed rulemaking is contained in sections 1, 2, 3, (4)(i), (4)(j), 
225, and 716 of the Communications Act of 1934, as amended, 47 U.S.C. §§ 151, 152, 153, 154(i), 
154(j), 225, 617.
C. Description and Estimate of the Number of Small Entities Impacted
5. The RFA directs agencies to provide a description of, and where feasible, an estimate of 
the number of small entities that may be affected by the proposed rules and policies, if adopted.9  The 
RFA generally defines the term “small entity” as having the same meaning as the terms “small business,” 
1 See 5 U.S.C. § 603.  The RFA, see id. §§ 601-612, was amended by the Small Business Regulatory Enforcement 
Fairness Act of 1996 (SBREFA), Pub. L. No. 104-121, Title II, 110 Stat. 857 (1996).
2 See 5 U.S.C. § 603(a).
3 Id.
4 See id. § 153(1) (defining ACS); Notice, paras. 42-67.
5 See 47 CFR Pt. 14 (accessibility of ACS).
6 See 47 U.S.C. § 617(e)(1)(D) (authorized Commission to adopt technical standards as safe harbors).
7 See 47 CFR § 64.604(c)(5)(iii) (establishing Interstate TRS Fund).
8 See Notice, paras. 68-107.
9 Id. § 603(b)(3). Federal Communications Commission FCC 23-50
57“small organization,” and “small governmental jurisdiction.”10  In addition, the term “small business” has 
the same meaning as the term “small business concern” under the Small Business Act.11  A “small 
business concern” is one which: (1) is independently owned and operated; (2) is not dominant in its field 
of operation; and (3) satisfies any additional criteria established by the SBA.12
6. If the proposed rules are adopted, the rules will affect the obligations of providers of 
IVCS and providers of TRS.  These services can be included within the broad economic category of All 
Other Telecommunications.  
7.All Other Telecommunications.  This industry is comprised of establishments primarily 
engaged in providing specialized telecommunications services, such as satellite tracking, communications 
telemetry, and radar station operation.13  This industry also includes establishments primarily engaged in 
providing satellite terminal stations and associated facilities connected with one or more terrestrial 
systems and capable of transmitting telecommunications to, and receiving telecommunications from, 
satellite systems.14  Providers of Internet services (e.g. dial-up ISPs) or voice over Internet protocol 
(VoIP) services, via client-supplied telecommunications connections are also included in this industry.15  
The SBA small business size standard for this industry classifies firms with annual receipts of $35 million 
or less as small.16  U.S. Census Bureau data for 2017 show that there were 1,079 firms in this industry that 
operated for the entire year.17  Of those firms, 1,039 had revenue of less than $25 million, and 15 firms 
had annual receipts of $25 million to $49,999,999.18  Based on this data, the Commission estimates that 
the majority of “All Other Telecommunications” firms can be considered small.
D. Description of Projected Reporting, Recordkeeping, and Other Compliance 
Requirements
8. The proposed changes for which comment is sought in the Notice, if adopted, would 
impose new or modified reporting, recordkeeping or other compliance obligations on certain small 
entities that provide IVCS or TRS. 
9.ACS Recordkeeping.  The Commission’s existing rules require that each manufacturer of 
equipment (including software) used to provide ACS and each provider of such services not otherwise 
exempt maintain, in the ordinary course of business and for a reasonable period, records documenting the 
10 Id. § 601(6). 
11 Id. § 601(3) (incorporating by reference the definition of “small-business concern” in the Small Business Act, 15 
U.S.C. § 632).  Pursuant to 5 U.S.C. § 601(3), the statutory definition of a small business applies “unless an agency, 
after consultation with the Office of Advocacy of the Small Business Administration and after opportunity for public 
comment, establishes one or more definitions of such term which are appropriate to the activities of the agency and 
publishes such definition(s) in the Federal Register.” 
12 15 U.S.C. § 632. 
13 See U.S. Census Bureau, 2017 NAICS Definition, “517919 All Other Telecommunications,” 
https://www.census.gov/naics/?input=517919&year=2017&details=517919.
14 Id.
15 Id.
16 See 13 CFR § 121.201, NAICS Code 517919 (as of 10/1/22, NAICS Code 517810). 
17 See U.S. Census Bureau, 2017 Economic Census of the United States, Selected Sectors: Sales, Value of Shipments, 
or Revenue Size of Firms for the U.S.: 2017, Table ID: EC1700SIZEREVFIRM, NAICS Code 517919, 
https://data.census.gov/cedsci/table?y=2017&n=517919&tid=ECNSIZE2017.EC1700SIZEREVFIRM&hidePrevie
w=false. 
18 Id.  The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that 
meet the SBA size standard.  We also note that according to the U.S. Census Bureau glossary, the terms receipts and 
revenues are used interchangeably, see https://www.census.gov/glossary/#term_ReceiptsRevenueServices.Federal Communications Commission FCC 23-50
58efforts taken by such manufacturer or service provider to implement Sections 255 and 716 including: (1) 
information about the manufacturer's or provider's efforts to consult with individuals with disabilities; (2) 
descriptions of the accessibility features of its products and services; and (3) information about the 
compatibility of such products and services with peripheral devices or specialized customer premise 
equipment commonly used by individuals with disabilities to achieve access.19
10.ACS Reporting.   The Commission’s existing rules require that an officer of each 
manufacturer of equipment (including software) used to provide ACS and an officer of each provider of 
such services submit to the Commission an annual certificate that records are being kept in accordance 
with the above recordkeeping requirements, unless such manufacturer or provider has been exempted 
from compliance with Section 716 under applicable rules.20
11.ACS Compliance Costs.  Because of the diverse manufacturers of equipment used to 
provide ACS and diverse providers of ACS that may be subject to Section 716, the multiple general and 
entity-specific factors used in determining, whether for a given manufacturer (or service provider) 
accessibility for a particular item of ACS equipment (or a particular service) is achievable, and the 
various provisions of Section 716 and the proposed rules on when and to what extent accessibility must 
be incorporated into a given item of ACS equipment or service, it is difficult to estimate the costs of 
compliance for those small entities that may not be covered by a waiver, should the Commission choose 
to apply any such waivers.21 Accordingly, the Notice seeks comment on the costs of compliance with 
these proposed rules.
12.TRS Amendments.  The proposed amendments to the Commission’s rules governing TRS 
are designed to facilitate the use of TRS Communications Assistants in video conferences, ensure the 
appropriate use of TRS with video conferencing, and prevent waste, fraud, and abuse.  These 
modifications would only apply to the extent that users of a specific small entity TRS provider participate 
in video conference calls.  Otherwise, the TRS compliance requirements would remain unchanged.
E. Steps Taken to Minimize Significant Impact on Small Entities, and Significant 
Alternatives Considered
13. The RFA requires an agency to describe any significant, specifically small business, 
alternatives that it has considered in reaching its proposed approach, which may include the following 
four alternatives (among others): “(1) the establishment of differing compliance or reporting requirements 
or timetables that take into account the resources available to small entities; (2) the clarification, 
consolidation, or simplification of compliance and reporting requirements under the rule for such small 
entities; (3) the use of performance rather than design standards; and (4) an exemption from coverage of 
the rule, or any part thereof, for such small entities.22
14. The achievability factors referenced in Section D above serve to mitigate adverse impacts 
and reduce burdens on small entities who provide ACS. The Commission makes determinations about 
what is achievable for an ACS provider by giving four factors equal weight.23  Two of these factors take 
into account the resources available to covered entities and may have a direct impact on small entities and 
their compliance obligations.  The second factor allows consideration of the technical and economic 
impact on the operation of the manufacturer or provider and on the operation of the specific equipment or 
19 See 47 CFR § 14.31(a).
20 See id. § 14.31(b).
21 See id. § 14.3 (exemption for customized equipment or services); id. § 14.5 (waivers for multipurpose services 
and equipment); id. § 14.20 (general obligations subject to achievability). 
22 5 U.S.C. § 603(c)(1)-(4).
23 See 47 CFR § 14.10(b) (definition of “achievable”).Federal Communications Commission FCC 23-50
59service in question.24  The third factor reviews the type of operations of the manufacturer or provider.25  In 
addition, consideration of the first factor (the nature and cost of the steps needed to meet the requirements 
with respect to the specific equipment or service in question)26 and the fourth factor (the extent to which 
the service provider or manufacturer in question offers accessibility services or equipment containing 
varying degrees of functionality and features, and offered at different price points)27 would benefit all 
entities subject to Section 716, including small entities.
15. The existing and proposed requirements would apply equally to all IVCS providers and 
are necessary to ensure video conferencing is accessible to persons with disabilities.  The amendments to 
the TRS rules will only apply to the extent a small entity TRS provider allows its users to participate in 
integrated IVCS calls.  Any burdens on small entities will be offset by the potential for increased revenues 
by increasing the types of calls and minutes of use that a TRS provider handles.
16. The Notice seeks comment from all interested parties.  Small entities are encouraged to 
bring to the Commission’s attention any specific concerns they may have with the proposals outlined in 
the Notice.  The Commission expects to consider the economic impact on small entities, as identified in 
comments filed in response to the Notice, in reaching its final conclusions and taking action in this 
proceeding.
F. Federal Rules Which Duplicate, Overlap, or Conflict With, the Commission’s 
Proposals
17. None.
24 Id. § 14.10(b)(2).
25 Id. § 14.10(b)(3).
26 Id. § 14.10(b)(1).
27 Id. § 14.10(b)(4).Federal Communications Commission FCC 23-50
60STATEMENT OF
CHAIRWOMAN JESSICA ROSENWORCEL
Re:Access to Video Conferencing, CG Docket No. 23-161; Implementation of Sections 716 and 717 of 
the Communications Act of 1934, as Enacted by the Twenty-First Century Communications and 
Video Accessibility Act of 2010, CG Docket No. 10-213; Telecommunications Relay Services and 
Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 
03-123; Petition of Sorenson Communications, LLC for a Limited Waiver of the Privacy Screen 
Rule, Report and Order, Notice of Proposed Rulemaking, and Order (June 8, 2023)
It was a little over a decade ago that I was asked to go to the White House to attend the signing 
ceremony for the Twenty-First Century Communications and Video Accessibility Act.  It was a gathering 
I will always remember.  For starters, when I was there, I got to meet Stevie Wonder, who is not just a 
legendary musician but also a tireless champion for access to communications technology for people with 
disabilities.  I also will never forget this day because I had the privilege of working on this historic civil 
rights legislation when I served as counsel on the Senate Commerce Committee.  And signed, sealed, and 
delivered, there is in fact a signed copy of this legislation on my office wall.
The Twenty-First Century Communications and Video Accessibility Act was historic because it 
updated the Americans with Disabilities Act for the digital age.  It put in law the fundamental idea that 
when technology changes, our accessibility policies need to evolve and keep pace.
When I sat in the White House that day, I never could have imagined the global pandemic that 
would come ten years later.  It was impossible to understand then just how vulnerable we were to Covid 
and how dramatically a new pathogen would move our lives online.  When physical doors closed and 
group events were cancelled during the pandemic, the virtual spaces provided by conferencing 
platforms—like Zoom, Teams, and WebEx—became an essential way to connect for work, school, 
health, and simple contact with family and friends.  If you want evidence, just look right here at the 
Federal Communications Commission.  For two years, we held our monthly open meeting—like the one 
we are at today—over a video conferencing platform.  
While we have moved back to in-person meetings, the role video conferencing platforms play in 
modern life has expanded.  It is one of those changes we take with us out of the pandemic.  But for people 
with disabilities this shift has been especially challenging.  That’s because inconsistent accessibility 
features on these platforms have not always made it possible to communicate.  
We are changing this today.  We start by clarifying that under the Twenty-First Century 
Communications and Video Accessibility Act, “interoperable video conferencing services” must comply 
with our accessibility rules.  On top of that, we propose new rules to further improve the accessibility of 
video conferencing services with performance objectives and also propose that our Telecommunications 
Relay Services fund should support the integration of relay services with video conferencing platforms.  
This effort is consistent with the law.  It is also aligned with the fundamental idea behind it—that 
when technology changes our accessibility policies need to evolve and keep pace.  That principle was 
apparent for all at the White House signing ceremony.  We give it new meaning today.  
The progress we are making here would not be possible without the work of organizations like 
Telecommunications for the Deaf and Hard of Hearing, the National Association of the Deaf, 
Communication Service for the Deaf, the Hearing Loss Association of America, the American Council of 
the Blind, the American Foundation for the Blind, the National Federation of the Blind, Gallaudet 
University’s Technology Access Program, and many other organizations representing those with 
disabilities.  We are blessed to have their interest and assistance in this effort.
I want to thank the staff who made this order and rulemaking possible, including Bob Aldrich, 
Edyael Casaperalta, Darryl Cooper, Eliot Greenwald, Joshua Mendelsohn, Ike Ofobike, Alejandro Roark, Federal Communications Commission FCC 23-50
61Michael Scott, Ross Slutsky, William David Wallace, and Dana Warrick from the Consumer and 
Governmental Affairs Bureau; Terry Cavanaugh, Michele Ellison, Richard Mallen, and William 
Richardson from the Office of General Counsel; Patrick Brogan, Rachel Kazan, Kim Makuch, Mark 
Montano, Michelle Schaefer, Emily Talaga, Kimberly Wild, and Andrew Wise from the Office of 
Economics and Analytics; Soumitra Das and Andrew Mulitz from the Office of the Managing Director; 
Sharon Lee from the Enforcement Bureau; and Matthew G. Baker, Kirk Burgee, Jodie Griffin, and Terri 
Natoli from the Wireline Competition Bureau.Federal Communications Commission FCC 23-50
62STATEMENT OF COMMISSIONER GEOFFREY STARKS 
Re: Access to Video Conferencing, CG Docket No. 23-161; Implementation of Sections 716 and 717 of 
the Communications Act of 1934, as Enacted by the Twenty-First Century Communications and 
Video Accessibility Act of 2010, CG Docket No. 10-213; Telecommunications Relay Services and 
Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, CG Docket No. 
03-123; Petition of Sorenson Communications, LLC for a Limited Waiver of the Privacy Screen 
Rule, Report and Order, Notice of Proposed Rulemaking, and Order (June 8, 2023) 
I frequently speak about the necessity of a high-speed broadband connection in today’s world.  
One of the reasons this is so critical is the rise in video conferencing.  From Zoom parent-teacher 
conferences, to WebEx telehealth calls, to Teams work meetings, web-based video conferencing is now 
one of the primary ways we communicate, in both our personal and professional lives. 
So we must make sure that video conferencing is accessible to everyone.  The FCC is charged 
with ensuring that individuals who are deaf, hard of hearing, deafblind, or who have speech disabilities 
can communicate in a manner that is functionally equivalent to those without such disabilities.  Too often, 
as we’ve heard from our Disability Advisory Committee, that isn’t the case with video conferencing.  
Today, we take an important step to change this.  We find that all services that meet Congress’ definition 
of “interoperable video conferencing service” must be accessible to and usable by people with disabilities.  
With this important finding made, we propose performance objectives these services must meet: 
captioning, text-to-speech, and sign language interpreting, including integration with video relay service, 
or VRS.  I am glad to see that this item also takes on the critical issue of making sure that speech 
recognition systems are game-ready to transcribe the speech of all types of speakers, including those with 
accents.  
I look forward to seeing how this record develops, and to continuing to hear from the disability 
community on these issues as this process moves forward.  My thanks to the Commission staff who 
worked on this item; it has my full support. 