The National Association of the Deaf along with other consumer groups representing individuals with hearing or speech disabilities developed a Telecommunications Relay Service Policy Statement defining “functional equivalency.” Functional equivalency is a cornerstone of Title IV of the Americans with Disabilities Act and requires that Telecommunication Relay Services provided for individuals with hearing and speech disabilities be functionally equivalent to voice telephone services. This policy statement will be used by Consumer Groups as the standard filter through which every TRS program action proposed or taken by the Federal Communications Commission (FCC) and TRS providers is assessed. We also urge the FCC to use this important document to help evaluate its past, pending, and future decisions that impact telecommunications relay services. The Consumer Groups define functional equivalency in the context of using relay service as follows:
“Persons receiving or making relay calls are able to participate equally in the entire conversation with the other party or parties and they experience the same activity, emotional context, purpose, operation, work, service, or role (function) within the call as if the call is between individuals who are not using relay services on any end of the call.”
The Consumer Groups submitted a list of ten core functional equivalency principles to the FCC that represent their expectations for high quality, empowering telecommunications relay services:
TRS must provide full benefit to all parties on a call, regardless of the complexity and/or cost.
The TRS experience for an individual who is deaf, hard of hearing, deaf-blind or speech-disabled must, at the minimum, be equivalent to that of a call between two hearing persons on the telephone network or over the Internet.
TRS users must be offered the ability to enjoy high quality relay services using mainstream products and services.
TRS equipment and services must be accessible and address the diverse needs of individuals who are deaf, hard of hearing, deaf-blind or speech-disabled.
Interoperable communication must be readily available and achieved with anyone, anytime, anywhere.
Vendors must be motivated to bring products to market that keep pace with mainstream technological advancements, and are continually improving the relay experience.
TRS users must have a wide selection of choices regarding equipment and software interfaces as well as hardware options, TRS program services and methods of making or receiving relay calls.
Emergency calls made through TRS must fully satisfy the safety and security needs of TRS users.
TRS users must receive prompt, comprehensive customer care service from their relay providers in their preferred communication modality.
The commitment to uphold the integrity of the TRS Fund must be fully maintained
“While we have made much progress over the years, there is still much work to do before we achieve true functional equivalency in the context of using relay service. The NAD hopes that this Consumer Groups’ policy statement will serve as a guide for everyone involved with this important mission” said NAD Presidnet Bobbie Beth Scoggins.
Click here to download the full Consumer Groups Telecommunications Relay Service Policy Statement.