By Danielle Applegate

In recognition of the landmark 30th anniversary of the passage of the Americans with Disabilities Act (ADA), the Federal Communications Commission (FCC) shined a spotlight on how accessible communications has evolved in the past three decades. The Clear2Connect Coaltion celebrates many of these milestones, including the passage of the Telecommunications Act of 1996 and the Twenty-First Century Communications and Video Accessibility Act (CVAA) of 2010. We thank the FCC for their ongoing commitment to communication access.

However, two milestones listed in the FCC’s ADA 30 reflection are of deep concern to the Clear2Connect Coalition: authorization and conditional certifications of two captioned telephone service providers that use only automatic speech recognition technology (ASR). The FCC determined in June 2018 that ASR is permissible to deliver IP CTS based on a study conducted by the MITRE Corporation. The Clear2Connect Coalition has questioned the validity of that study because it was conducted in optimal lab conditions not representative of real-life telephonic communication, was not peer-reviewed, had a small sample size, and used varied testing methods for different technologies, rendering comparisons invalid. ASR-only service cannot be determined to meet the requirement of functional equivalence guaranteed by the Americans with Disabilities Act (ADA) based on this flawed study. As such, ASR-only captioned telephone service should not be recognized as a true accessibility milestone until and unless quality metrics and standards are put in place to ensure accurate, unbiased captioning.

As we look ahead to the next 30 years, the Clear2Connect Coalition remains committed to advocating for communication access for all Americans.

Danielle Applegate is the Vice President of VetsFirst which is a program of the United Spinal Association that assists veterans and their eligible family members in obtaining the benefits they are entitled to, deserve and need. VetsFirst is a member of the Clear2Connect Coalition.