Telecommunications Relay Service: FCC Should Strengthen Its Management of Program to Assist Persons with Hearing or Speech Disabilities
Highlights
What GAO Found
Since 2002, the overall minutes of use and costs for the Telecommunications Relay Service (TRS) program have grown significantly due to the advent of Internet-based forms of TRS and increased usage by the deaf and hard-of-hearing communities. Program data show that total TRS minutes have grown from about 53 million in “rate year” (July-to-June) 2002–2003 to about 249 million in rate year 2013–2014, an almost five-fold increase. Total TRS costs have grown from about $104 million in the 2002–2003 rate year to about $818 million in the 2013–2014 rate year, an almost eight-fold increase. These increases stem from the popularity of new forms of TRS that use the Internet—such as Video Relay Service (VRS) and Internet Protocol Captioned Telephone Service—and the growth in consumers' use of them, according to FCC, some providers, and one consumer group that GAO interviewed.
The purpose of the TRS program under federal law is to provide persons who are deaf or hard of hearing or have a speech disability with telecommunications services that are “functionally equivalent” to those provided to persons without a hearing or speech disability, but FCC has not established specific performance goals to guide its efforts. FCC has established some performance measures for TRS in the form of minimum performance standards for TRS providers, such as regulations requiring that TRS communications assistants must answer 85 percent of TRS calls (except VRS) within 10 seconds; however, these standards are not linked to higher-level performance goals. By establishing performance measures before establishing performance goals, FCC may be spending time and resources on efforts not well linked to key dimensions of the program. Because of the lack of specific TRS performance goals—and specific performance measures crafted around those goals—it is difficult to determine in an objective, quantifiable way if TRS is making available functionally equivalent telecommunications services, and it is difficult for FCC to manage the program in a proactive, results-oriented manner.
FCC has designed some internal controls for the TRS program, but lacks a comprehensive internal-control system to manage program risks. To address fraud, FCC has designed numerous controls to address compliance risks. For example, FCC eliminated the ability of TRS providers to use subcontractors in 2011 and strengthened TRS's provider-certification rules and user registration rules in 2013. Internal control standards call for the completion of a risk assessment to identify and analyze program risks. FCC's last risk assessment, in 2013, was a one-page document that did not comprehensively identify programmatic risks. A robust risk assessment would help FCC identify risks to providing functionally equivalent services and inform the development of the overall internal-control system. Internal control standards also call for effective external communications to groups that can impact the program, such as TRS's users and providers. FCC's program policies are spread across numerous reports and orders. Six of 10 TRS providers told us they experienced difficulties understanding TRS rules. FCC has sought comment on how best to reorganize its rules to improve clarity, but has not yet adopted any such changes. Doing so could improve FCC's communication of TRS rules and procedures to the deaf community and the companies providing services.
Why GAO Did This Study
TRS allows persons with hearing or speech disabilities to place and receive telephone calls, often with the help of a communications assistant who acts as a translator or facilitator between the two parties having the conversation. FCC is the steward of the TRS program and the federal TRS Fund, which reimburses TRS providers.
GAO was asked to examine FCC's management of the TRS program. This report examines, among other things, (1) changes in TRS services and costs since 2002, (2) FCC's TRS performance goals and measures and how they compare with key characteristics of successful performance goals and measures, and (3) the extent to which the design of the program's internal control system identifies and considers program risks. GAO analyzed 2002 through 2014 service and cost data, compared TRS performance goals and measures to key characteristics of successful performance goals and measures, compared the design of the TRS's internal control system with GAO's standards for internal control, and interviewed officials from FCC, the 10 companies providing interstate TRS, and associations representing the deaf and hard of hearing.
Recommendations
GAO recommends that FCC develop specific TRS performance goals and measures, conduct a robust program risk assessment, and improve the communication of TRS's rules and procedures. In commenting on a draft of this report, FCC agreed with the recommendations and discussed actions it plans to take to implement them.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Federal Communications Commission | To improve performance management of the Telecommunications Relay Service, the Chairman of the Federal Communications Commission should develop specific performance goals and measures for the TRS program. FCC should establish goals that would guide its efforts on major program dimensions--for example, consider goals and performance measures related to, but not limited to, service quality or competition among providers. |
The Telecommunication Relay Service (TRS) allows persons with hearing or speech disabilities to place and receive telephone calls, often with the help of a communications assistant who acts as a translator or facilitator between the two parties having the conversation. The Federal Communications Commission (FCC) is the steward of the TRS program and the federal TRS Fund, which reimburses TRS providers. In 2015, we found that FCC had not established specific TRS performance goals to guide its efforts to ensure that telecommunications services available to persons with a hearing or speech disabilities are "functionally equivalent" to those provided to persons without such disabilities. Although FCC had developed some important performance output measures through its minimum standards for the TRS program, best practices for successful management of a program call for a well-balanced set of outcome and output measures that link to specific program performance goals. Lacking specific TRS performance goals--and specific performance measures crafted around those goals--it was difficult to determine in an objective, quantifiable way if TRS was making available functionally equivalent telecommunications services, and it was difficult for FCC to manage the program in a proactive, results-oriented manner. We recommended that that FCC develop specific performance goals and measures for the TRS program that would guide its efforts on major program dimensions. In 2020, we confirmed that FCC had established the goals and metrics for its TRS program. Specifically, these goals and metrics measure (1) the availability of TRS services, (2) the efficiency of the TRS program, (3) the quality of service, and (4) the market share for each TRS service and the number of entities providing service, which addresses competition and ratemaking. In addition, FCC provided an initial tracking report that documented FCC's tracking of these metrics quarterly or annually depending on the metric. The development of these performance goals and measures for TRS will also enable FCC to determine whether it has met the program's purpose of providing functionally equivalent services. TRS-specific performance goals and measures will help ensure that FCC is managing the program in a proactive, result-oriented manner and, ultimately, that the TRS program is meeting its overall purpose of providing functionally equivalent telecommunications services to persons who are deaf, hard of hearing, or have speech disabilities.
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| Federal Communications Commission | To improve performance management of the Telecommunications Relay Service, following the establishment of TRS's performance goals, the Chairman of the Federal Communications Commission should conduct a robust risk assessment that can help FCC design a comprehensive internal-control system. |
The Telecommunication Relay Service (TRS) allows persons with hearing or speech disabilities to place and receive telephone calls, often with the help of a communications assistant who acts as a translator or facilitator between the two parties having the conversation. FCC is the steward of the TRS program and the federal TRS Fund, which reimburses TRS providers. In 2015, FCC had designed some internal controls for the TRS program, particularly with respect to program compliance. However, FCC lacks a comprehensive internal control system to manage TRS program risks. It is clear from FCC's agency-wide plans and program-specific orders that combating fraud is a priority, and FCC has designed a number of controls to do so. Internal control standards call for a risk assessment that will identify risks, both internal and external, and analyze the risks for possible effects. According to documents provided by FCC, the last risk assessment of the TRS program was conducted in 2013. FCC's risk assessment of the TRS program was a one-page document that did not comprehensively identify risks or considerations of all interaction between FCC and external parties. We found that the risk assessment focused on fraud, waste, and abuse and did not look at other risks to achieving the provision of functionally equivalent telecommunications for persons who are deaf, hard of hearing, or have speech disabilities. Without a robust risk assessment of the TRS program, FCC may not be able to identify and address the relevant risks to ensuring the provision of functionally equivalent telecommunications for people with hearing and speech disabilities. Therefore, we recommended that FCC, following the establishment of TRS's performance goals, conduct a robust risk assessment that can help it design a comprehensive internal-control system. FCC established TRS performance goals in 2020. In September 2022, FCC completed a risk assessment that found there were no significant deficiencies noted in the system of internal controls in place over the administration of the TRS Fund and identified key risks to the TRS program. With the completion of this risk assessment, FCC is in a better position to design a comprehensive internal-control system that can identify risks to providing functionally equivalent telecommunications for people with hearing or speech disabilities.
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| Federal Communications Commission | To improve performance management of the Telecommunications Relay Service, the Chairman of the Federal Communications Commission should improve FCC's communication of TRS rules and procedures to the community of individuals who are deaf, hard of hearing, or have speech disabilities and the companies providing TRS services through the creation and dissemination of a handbook, program manual, or other consolidation of TRS rules and procedures. |
The Telecommunications Relay Service (TRS) allows persons with hearing or speech disabilities to place and receive telephone calls, often with the help of a communications assistant who acts as a translator or facilitator between the two parties having the conversation. The Federal Communications Commission (FCC) is the steward of the TRS program and the federal TRS Fund, which reimburses TRS providers. In 2015, we found that FCC's TRS program policies were spread across numerous reports and orders. Six of the 10 TRS providers we interviewed told us about challenges understanding the program's rules that applied to them in part because rules for a specific type of TRS service are discussed throughout FCC orders rather than compiled in one place for each type of TRS service. Internal control standards call for effective external communications to those groups that can have an impact on programs; such groups in the case of TRS, would include TRS users and service providers. TRS rules are contained in federal regulations, and FCC program policies are explained across numerous reports and orders. Despite this issue being previously highlighted by the FCC Office of Inspector General, FCC had not improved its external communications to program users or providers through better organization of TRS rules and regulations nor provided any specific time frames for doing so. Therefore, we recommended that FCC improve communication of TRS rules and procedures with the community of individuals who are deaf, hard of hearing, or have speech disabilities and the companies providing TRS services through the creation and dissemination of a handbook, program manual, or other consolidation of TRS rules and procedures. In February 2020, FCC consolidated information of the FCC's TRS rules into a descriptive table. The table is posted for the public on FCC's web site at https://www.fcc.gov/trs-rules-descriptive-table. The table is intended to assist the public in navigating through and understanding the coverage of the TRS-related provisions of FCC's rules. By consolidating these rules, FCC will improve its communication of TRS rules with the deaf community and the companies providing services, which enhances the program's ability to provide telecommunications services that are "functionally equivalent" to the services provided to persons without hearing or speech disabilities.
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