On October 23, 2024, the FCC released a Notice of Inquiry (NOI) seeking public input on potential updates to customer service standards for cable operators, and whether these standards should extend to voice and broadband service providers. The inquiry focuses on improving customer service experiences, including enhancing accessibility for consumers with disabilities. The Commission is particularly interested in understanding the current landscape of customer service practices and identifying areas that may require regulatory action.
Key Areas of Inquiry Include:
- Simple Cancellation:
- The FCC seeks input on whether service providers offer clear and direct cancellation methods, particularly whether these methods are equally accessible to all customers, including those with disabilities.
- Should there be more than one way to cancel, and should one of those methods match the way the service was originally subscribed to?
- The FCC is considering whether these protections should extend beyond individual consumers to include enterprise clients as well.
- Access to Live Representatives:
- The FCC is investigating whether service providers offer live customer support within reasonable timeframes and if current accessibility standards are adequate for customers with disabilities.
- Commenters are invited to address whether customers with disabilities, such as those with hearing or speech impairments, can easily reach support representatives using accessible services like Telecommunications Relay Service (TRS).
- The potential impact of AI technologies on access to live representatives is also under review. Could AI enhance or hinder accessibility?
- Installations, Outages, and Service Calls:
- Should existing standards for cable installations and repairs be updated to ensure accessibility for individuals with disabilities, and should these standards extend to voice and broadband services?
- Automatic Service Renewals and Price Increases:
- The FCC seeks feedback on whether consumers are given adequate notice and opportunities to opt out of service renewals, especially whether this process is accessible to individuals with disabilities.
Accessibility Focus
The NOI emphasizes the accessibility of customer service for individuals with disabilities and non-native English speakers, including those whose primary language is American Sign Language (ASL). The FCC is particularly interested in learning how service providers are meeting their obligations under Section 255 of the Communications Act and the 21st Century Communications and Video Accessibility Act (CVAA), which require services to be accessible and usable for people with disabilities. There is concern that some carriers may not be offering customer service channels that accommodate the unique communication needs of individuals with hearing or speech disabilities who rely on TRS.
This inquiry represents an opportunity for the FCC to discover whether current customer service practices align with their legal obligations regarding “usability” under these statutes. Should the FCC uncover gaps in accessibility, this could lead to enforcement proceedings against non-compliant entities and/or regulatory updates aimed at improving customer service channels for people with disabilities.
Comments are due by November 22, 2024 and Reply comments are due by December 9, 2024.
For further assistance or to discuss filing comments on this proceeding, please contact Jonathan Marashlian at jsm@commlawgroup.com or the attorney assigned to your account. For any disability access questions, please contact Michal Nowicki at mjn@commlawgroup.com.