TELECOMMUNICATIONS 

RELAY SERVICE

FCC Should Strengthen 

Its Management of 

Program to Assist Persons 

with Hearing or Speech 

Disabilities 

Report to the Honorable Jeff Sessions, 

U.S. Senate

April 2015

GAO-15-409

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-15-409, a report to the 

Honorable Jeff Sessions, U.S. Senate

April 2015

TELECOMMUNICATIONS RELAY SERVICE

FCC Should Strengthen Its Management of Program 

to Assist Persons with Hearing or Speech Disabilities

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. 

What GAO Recommends

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. 

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-ofhearing 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. 

View GAO-15-409. For more information, 

contact Mark Goldstein at (202) 512-2834 or 

goldsteinm@gao.gov.
Page i GAO-15-409 Telecommunications Relay Service

Letter 1

Background 4

Total TRS Minutes and Costs Have Grown Significantly since 

2002 due to Internet-Based TRS and Increased Usage 10

FCC Has Not Established Performance Goals and Related 

Performance Measures for the TRS Program 17

FCC Has Designed Some Internal Controls but Lacks a 

Comprehensive Internal Control System to Manage Program 

Risks 21

Stakeholders Cited Several Challenges to TRS Service Quality 

and Competition 28

Conclusions 35

Recommendations for Executive Action 36

Agency and Third-Party Comments 36

Appendix I Objectives, Scope, and Methodology 38

Appendix II Survey of Telecommunications Relay Service Providers 41

Appendix III GAO Analysis of Provider Concentration in TRS Product Markets, 

2008–2014 Rate Years 46

Appendix IV Comments from the Federal Communications Commission 47

Appendix V GAO Contact and Staff Acknowledgments 49

Table

Table 1: Provider Concentration in TRS Product Markets (annually 

as of July 1) 46

Contents
Page ii GAO-15-409 Telecommunications Relay Service

Figures

Figure 1: Description of the Six Forms of Telecommunications 

Relay Service (TRS) (as of January 1, 2015) 7

Figure 2: Total Telecommunications Relay Service Program 

Costs, 2002–2003 to 2013–2014 11

Figure 3: Percentage of Total Costs of Each Form of 

Telecommunications Relay Service in Rate Year 2013–

2014 12

Figure 4: Total Costs for Each Form of Telecommunications Relay 

Service, 2002–2003 to 2013–2014 13

Figure 5: Changes in Minutes of Use for Each Form of 

Telecommunications Relay Service, 2002–2003 to 2013–

2014 14

Figure 6: Trends in Telecommunications Relay Service (TRS) 

Cost Reimbursement Rates over Time 15
Page iii GAO-15-409 Telecommunications Relay Service

Abbreviations

ADA Americans with Disabilities Act of 1990 

ASL American Sign Language 

CA “communications assistant” 

CTS Captioned Telephone Service 

FCC Federal Communications Commission 

FMFIA Federal Managers’ Financial Integrity Act of 1982 

GPRAMA GPRA Modernization Act of 2010

HHI Herfindahl-Hirschman Index 

IP CTS Internet Protocol Captioned Telephone Service

IP Relay Internet Protocol Relay

NAD National Association of the Deaf 

NECA National Exchange Carrier Association

MARS Multi-state Average Rate Structure

OIG Office of Inspector General

RLSA Rolka Loube Saltzer Associates 

STS Speech-to-Speech Relay Service 

TRS Telecommunications Relay Service

TTY Text Telephone 

VRS Video Relay Service 

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Page 1 GAO-15-409 Telecommunications Relay Service

441 G St. N.W.

Washington, DC 20548

April 29, 2015

The Honorable Jeff Sessions

United States Senate

Dear Senator Sessions:

Persons with hearing or speech disabilities want or need to have 

telephone conversations with persons who do not have such a disability—

for example, a call to their doctor, their child’s school, or a close relative. 

The Telecommunications Relay Service (TRS) allows persons with a 

hearing or speech disability to place and receive telephone calls with the 

help of a “communications assistant,” (CA) who acts in various ways as 

an interpreter or facilitator between the two parties having the 

conversation.1 Different forms of TRS involve different technologies, 

including the use of video, the Internet, or special caption telephones. 

Section 401(a) of the Americans with Disabilities Act of 1990 (ADA)2

requires the Federal Communications Commission (FCC), the steward of 

the TRS program and the Interstate Telecommunications Relay Services 

Fund (TRS Fund),3

 to ensure that TRS is available, to the extent possible 

and in the most efficient manner, to persons in the United States with 

hearing or speech disabilities.4 TRS Fund disbursements were 

approximately $818 million in the 2013–2014 “rate year,”5

 

1

TRS is not intended for communication between two people who are deaf, hard of 

hearing, or speech disabled if both parties to the call are using the same type of relay 

service. There are circumstances in which calls between two deaf people using two 

different forms of TRS can be compensated. The different forms of TRS are explained 

later in this report.

up from about 

2

Pub. L. No. 101-336, § 401(a), 104 Stat. 327, 366 (1990), codified as amended at 47 

U.S.C. § 225. 

3

The provision of TRS services is paid for by the TRS Fund. The TRS Fund is a revolving 

fund financed through contributions made by all providers of interstate 

telecommunications services. Service provider contributions are based on a “contribution 

factor” that is set on an annual basis by FCC. 47 C.F.R. § 64.604(c)(5)(iii). These 

mandatory contributions are generally passed on to consumers as part of the cost of their 

telephone service.

4

47 U.S.C. § 225(b)(1). States provide and pay for intrastate TRS services. States usually 

recover intrastate TRS costs through a surcharge applied to the telephone bills of all 

telephone customers within a state.

5

The TRS rate year runs from July 1 to June 30 of the following year.

Letter
Page 2 GAO-15-409 Telecommunications Relay Service

$104 million in the 2002–2003 rate year, when according to FCC, Video 

Relay Service (VRS)—a popular form of TRS—began to be widely 

offered.6

In 2008, the FCC Office of Inspector General (OIG) initiated an 

investigation into VRS fraud. Several individuals eventually pleaded guilty 

to committing VRS fraud, and FCC made changes to program rules 

intended to prevent and detect fraud, waste, or abuse in the program.

You requested that we examine FCC’s management of the TRS 

program.7

1. How have the services and costs of the TRS program changed since 

2002?

This report addresses the following questions:

2. What are FCC’s performance goals and measures for the TRS 

program, and how do they compare with key characteristics of 

successful performance goals and measures?

3. To what extent does the design of the TRS program’s internal control 

system identify and consider program risks?

4. According to program stakeholders, what challenges, if any, exist in 

ensuring quality services for users and a competitive environment for 

providers?

For each of our research questions, we reviewed relevant FCC TRS 

orders and comments filed in FCC proceedings. We also conducted 

interviews with officials from the FCC; the FCC Office of Inspector 

General (OIG); Rolka Loube Saltzer Associates (RLSA), the current TRS 

Fund administrator; the National Exchange Carrier Association (NECA), 

the previous TRS Fund administrator; each of the 10 companies currently 

providing TRS; and associations representing the deaf, hard of hearing, 

and speech-disabled (referred to in this report as consumer groups). We 

analyzed these interviews to identify major themes that emerged about 

how and why TRS services have changed over time and what issues 

exist regarding quality, competition, and management of the program. To 

determine how the services and costs of the TRS program have changed 

 

6

VRS is an Internet-based form of TRS that allows persons whose primary language is 

American Sign Language (ASL) to communicate with a CA in ASL using video 

conferencing equipment. 

7

At the time of the request, Senator Sessions was the Ranking Member of the Senate 

Committee on the Budget.
Page 3 GAO-15-409 Telecommunications Relay Service

since 2002, we obtained and analyzed FCC program data on costs and 

minutes of usage from 2002 through 2014 for the six major TRS services.

We selected 2002 as the start date for our review because it was the first 

year that VRS—the service that accounts for the majority of TRS Fund 

payments—was widely offered. Based on documentation and 

conversations with FCC about how the data are collected and managed, 

we determined the cost and usage data were sufficiently reliable for the 

purposes of presenting program trends. To assess FCC’s performance 

goals and measures, we reviewed FCC documents, including strategic 

plans and performance plans, and interviewed FCC staff about the 

program’s goals and measures. We compared the goals and measures to 

key characteristics of successful goals and measures, as developed by 

GAO in previous work8 and as contained in the GPRA Modernization Act 

of 2010 (GPRAMA).9 To assess how the design of the TRS program’s 

internal control system identifies and considers program risk, we obtained 

TRS’s internal control documentation, including risk assessments, 

descriptions of control activities, and audit reports. We compared the 

design of the TRS internal control system with the requirements 

contained in GAO’s Standards for Internal Control in the Federal 

Government.

10 To obtain quantifiable information about issues related to 

TRS quality and competition, we conducted a survey of all 10 current 

TRS providers. We obtained a 100-percent response rate to our survey. 

In addition, we conducted a market concentration analysis of the six main 

forms of TRS by analyzing the number of providers for each service from 

2008 through 2014.11

 

8

GAO developed a set of key practices based on analyses of leading results-oriented 

organizations, management studies of 23 large federal departments and agencies, and a 

body of literature on management reform, strategic planning, and performance 

measurement. See GAO, Executive Guide: Effectively Implementing the Government 

Performance and Results Act, 

We also analyzed other measures of market 

concentration for the two largest forms of TRS (VRS and Internet Protocol 

Captioned Telephone Service) in terms of current compensation received 

by providers for the most recent rate years. Appendix I provides additional 

GAO/GGD-96-118 (Washington, D.C.: June 1996).

9

Pub. L. No. 111-352, 124 Stat. 3866 (2011). 

10GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00.21.3.1

(Washington, D.C.: November 1999). The scope of our audit did not include the testing of 

specific internal control activities.

11We selected 2008 as the starting year for this analysis because, according to FCC 

officials, this was the first year with complete market concentration data on all 6 forms of 

TRS.
Page 4 GAO-15-409 Telecommunications Relay Service

information about our objectives, scope, and methodology, including a list 

of the organizations we interviewed.

We conducted this performance audit from April 2014 to April 2015, in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

FCC manages and oversees the federal TRS program. FCC develops 

program rules and policies, sets annual rates for compensating providers, 

and oversees compliance with program rules. FCC contracts out the daily 

administration of the TRS Fund to a third-party administrator. NECA was 

the fund administrator from 1993 through June 2011; RLSA has been the 

administrator since July 2011. The administrator calculates proposed 

TRS compensation rates and contribution factors, collects fees, and 

handles the disbursements from the TRS Fund to TRS providers.

According to FCC officials, prior to the ADA, there was no federal 

requirement for telephone providers to offer a means for people who were 

deaf, hard of hearing, or speech disabled to access the nation’s 

telephone services, although many states provided a form of TRS at that 

time. The ADA created the first requirement for a federal program, and 

the TRS program was established in 1993 in response. The ADA requires 

that persons with hearing or speech disabilities be provided with 

telecommunications services that are “functionally equivalent” to the 

Background
Page 5 GAO-15-409 Telecommunications Relay Service

services provided to persons without hearing or speech disabilities.12 Until 

2000, text-to-voice communication using a text telephone (TTY), a text 

input device, was the only form of TRS available to users. The advent of 

Internet-based TRS technologies, however, has increased 

telecommunications options for people who are deaf and hard of hearing.

TRS is available in all 50 states, the District of Columbia, and the U.S. 

territories for local and long distance calls and some international calls. 

TRS involves no additional charges for the TRS user.13 According to FCC 

officials, FCC has plans to develop a central user-registration database, 

but currently the number of TRS users is unknown. FCC officials told us 

that there are roughly 250,000 assigned VRS numbers, but assigned 

numbers do not equate one-to-one with the number of users.14

 

1247 U.S.C. § 225. Although TRS can be considered a universal service program in that it 

seeks to make telecommunications services accessible to all citizens, specifically those 

with hearing or speech disabilities, the program is distinct from FCC’s four universal 

service programs under the Universal Service Fund. 47 U.S.C. § 254. Those programs 

are the High Cost program, which seeks to bring affordable telecommunications services 

to those in rural areas; the Low Income program, which seeks to bring affordable 

telecommunications services to low income individuals; the E-rate program, which funds 

telecommunications services to eligible schools and libraries; and the Rural Health Care 

Fund, which funds telecommunications services for rural health care providers. The 

construct of the four universal service programs are similar to TRS in that they are 

managed by FCC, but the daily administration of the Universal Service Fund is handled by 

the Universal Service Administrative Company. For more information on the Universal 

Service Fund and universal service programs, including a list of related GAO reports, see 

GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save Tax 

Dollars, and Enhance Revenue,

The 

Centers for Disease Control and Prevention’s National Center for Health 

Statistics reported in February 2014 that there are about 38-million 

individuals with hearing disabilities in the United States. Although the 

number of current TRS users is likely much lower than that, according to 

the National Association of the Deaf, this number could represent the 

number of potential users.

GAO-11-318SP (Washington D.C.: Mar. 1, 2011), 194–

197.

13According to the National Association of the Deaf, users generally pay for equipment, 

such as telephones and computers, and service, such as Internet and telephone, although 

some providers have given away telephones to encourage the deaf and hard of hearing to 

use their TRS service.

14FCC stated that some of these VRS numbers are assigned to devices with multiple 

users (e.g., a household with more than one deaf individual) and some users have more 

than one number (e.g., one number at home and another at work). 
Page 6 GAO-15-409 Telecommunications Relay Service

There are currently six main forms of TRS: Video Relay Service (VRS), 

Text Telephone (TTY), Captioned Telephone Service (CTS), Internet 

Protocol Captioned Telephone Service (IP CTS), Internet Protocol Relay 

(IP Relay), and Speech-to-Speech Relay Service (STS) (see fig. 1).
Page 7 GAO-15-409 Telecommunications Relay Service

Figure 1: Description of the Six Forms of Telecommunications Relay Service (TRS) (as of January 1, 2015)

Note: In December 2014, FCC’s Consumer and Governmental Affairs Bureau adopted a mid-year 

adjustment of the IP Relay rate for the sole provider remaining in this market. The rate is currently set 

at $1.37 for the first 300,000 minutes through June 30, 2015, and $1.67 for minutes over 300,000 

until May 31, 2015. This adjustment was made because the remaining provider asserted that it would 
Page 8 GAO-15-409 Telecommunications Relay Service

be unable to remain in this business without such rate increases and FCC was concerned that ending 

this service would harm consumers.

TRS providers include both traditional telecommunications companies, 

such as AT&T or Sprint, and companies primarily focused on providing 

TRS service, such as Convo or the Communication Axess Ability Group. 

Companies are compensated from state TRS funds for the costs of 

providing intrastate TRS and from the federal TRS Fund for the costs of 

providing interstate and Internet-based TRS. There are currently 10 TRS 

providers that are compensated from the federal TRS Fund. No single 

company offers all six forms of TRS. For example, in October 2014, six 

companies provided VRS, while three provided TTY and CTS. For all 

forms of Internet-based TRS, providers must be certified by FCC before 

they can offer service.

TRS companies provide TRS services and are then reimbursed on a perminute basis out of the TRS Fund.15

The rates for the various forms of TRS are determined in the following 

ways:

The TRS reimbursement rate varies 

by service and is typically set by FCC annually based on reported 

provider costs, which include an 11.25-percent return on capital 

investment. For example, as shown in figure 1, the 2014–2015 

reimbursement rates ranged from $1.03 per minute to $5.29 per minute 

for the different forms of TRS. In the 2013–2014 rate year, approximately 

$818 million in total reimbursements were paid out of the TRS Fund to the 

companies that provided TRS services.

16

• Text Telephone, Speech-to-Speech, Captioned Telephone 

Service, and Internet Protocol Captioned Telephone Service:

FCC uses the Multi-state Average Rate Structure (MARS) 

methodology to determine compensation. MARS uses an average of 

competitively bid state rates for intrastate TRS to determine 

predictable, fair, and reasonable costs of interstate TRS.

 

15Providers submit monthly reports of minutes to the fund administrator for compensation 

from the fund. The reports are then to be reviewed by the fund administrator to ensure that 

the minutes were handled in compliance with the Commission’s rules and orders before 

reimbursements are made. 47 C.F.R. § 64.604(c)(7)(E).

16We did not evaluate the methodologies behind how FCC established reimbursement 

rates for each TRS service.
Page 9 GAO-15-409 Telecommunications Relay Service

• Internet Protocol Relay: FCC employs a price cap regulation to 

determine the compensation rate for IP Relay.

• Video Relay Service: According to FCC, to encourage competition 

while recognizing efficiencies through economies of scale, FCC 

compensates VRS providers using a three-tiered rate structure based 

on the minutes of service provided. For January 1, 2015, through 

June 30, 2015, VRS rates are:

• Tier I rate: $5.29 per minute for minutes up to 500,000 per month;

• Tier II rate: $4.82 per minute for minutes from 500,000.1 to 

1,000,000 per month; and

• Tier III rate: $4.25 per minute for minutes over 1,000,000 per 

month.

All VRS providers are compensated at the tier I rate for their first 500,000 

minutes, but as providers become larger and provide more minutes of 

service, they are compensated at lower rates for the additional minutes. 

The three-tier rate structure is intended to reflect cost differences among 

large and small providers and encourage current entrants to remain in the 

VRS market, while improving their efficiency over time. FCC intends to 

eliminate the rate tiers over time. In its 2013 VRS Reform Order, FCC 

adopted a schedule to phase out the differences between tier I and tier II 

rates by January 2016 as part of a “glide path” toward an eventual unitary 

cost-based rate for VRS.17 According to FCC, it is seeking to replace the 

cost-of-service ratemaking approach for VRS with more market-based 

approaches, to the extent that this approach can be accomplished without 

adversely affecting the public interest and goals of the ADA. FCC 

believes that a market-based approach to providing VRS will result in 

lower costs for the TRS program.

 

17See In the Matter of Structure and Practices of the Video Relay Service Program, 

Report and Order and Further Notice of Proposed Rulemaking, 28 FCC Rcd. 8618 (2013) 

vacated in part, 765 F. 3d 37 (D.C. Cir. 2014). (VRS Reform Order). 
Page 10 GAO-15-409 Telecommunications Relay Service

According to officials from FCC, most of the TRS providers, and all of the 

consumer groups that we interviewed, the development of Internet-based 

TRS technologies and increased usage of these technologies have led to 

growth in overall program minutes and costs. TRS program data show 

that total TRS minutes have grown from about 53 million in rate year 

2002–2003 to about 249 million in rate year 2013–2014, an almost fivefold increase. Total TRS costs have grown from about $104 million in 

2002 to about $818 million in rate year 2013–2014, an almost eight-fold 

increase (see fig. 2). According to FCC, some providers, and one 

consumer group we spoke with, the development of TRS technologies 

that use the Internet—such as VRS, IP Relay, and IP CTS, along with 

consumer knowledge about them—has led to wider use of TRS services.

Since the federal TRS Fund supports the provision of Internet-based 

TRS, a rise in federal TRS costs occurred in concert with the 

development and popularity of the Internet-based services (VRS initially 

and then IP CTS). According to FCC, some providers, and one consumer 

group, other technology advancements also have increased TRS usage. 

For example, CTS and IP CTS involve the use of a telephone that 

provides people who are hard of hearing with captions of what the other 

party to the conversation is saying. CTS and IP CTS have opened the 

TRS market to a new group of users—senior citizens—some of whom 

can become increasingly unable to follow everything said in a telephone 

conversation due to hearing loss late in life. Also, two consumer groups 

noted that consumers can now use mobile phone applications to access 

most TRS, thus no longer being tied to specialized equipment in the 

home and likely further increasing total program usage.

Total TRS Minutes 

and Costs Have 

Grown Significantly 

since 2002 due to 

Internet-Based TRS 

and Increased Usage
Page 11 GAO-15-409 Telecommunications Relay Service

Figure 2: Total Telecommunications Relay Service Program Costs, 2002–2003 to 

2013–2014

Note: According to FCC officials, cost data from some TRS forms prior to July 2011 either could not 

be located or were not reliable, so these data are not part of this graphic. However, these omissions 

do not significantly affect this graphic because they were low amounts at the beginning of the TRS 

forms’ availability.

The largest portion of TRS costs are for VRS, which is used by members 

of the deaf population who communicate in American Sign Language 

(ASL). According to the National Association of the Deaf (NAD), the 

primary reason for VRS’s increased use is that it allows users to 

communicate at roughly 200 words-per-minute instead of the 60 wordsper-minute enabled by the typing of traditional TTY. In addition, according 

to NAD, ASL can be a deaf individual’s native language and, when used 

as part of a telephone conversation, provides a richer communication 

experience, much closer to that of a hearing individual. VRS requires a 

specialized CA workforce of ASL interpreters who, according to some of 

the stakeholders we spoke with, can be in low supply and can command 

fairly high salaries. These higher CA costs and, according to one 

provider, the more expensive video link between the deaf individual and 

the CA have led to VRS costs per minute that are higher than other forms 

of TRS. VRS costs grew from about $25 million in rate year 2002–2003 to 
Page 12 GAO-15-409 Telecommunications Relay Service

about $601 million in rate year 2013–2014. VRS reimbursement costs 

peaked in the 2008–2009 rate year at $621 million, which accounted for 

about 85 percent of the TRS fund at that time. In rate year 2013–2014, 

VRS accounted for about 74 percent of the $818 million in TRS 

reimbursements (see fig. 3). IP CTS is the second most reimbursed TRS 

service at about 21 percent of total TRS costs.

Figure 3: Percentage of Total Costs of Each Form of Telecommunications Relay 

Service in Rate Year 2013–2014

Although VRS costs are the largest percentage of current program costs, 

IP CTS costs are growing at the fastest rate. From rate years 2009–2010 

through 2013–2014, IP CTS grew from $9 million to $174 million, or about 

a 19-fold increase (see fig. 4). Some stakeholders we spoke with saw IP 

CTS as an area where TRS usage is likely to continue increasing as baby 

boomers age and face increased hearing loss. Today, VRS and IP CTS, 

both Internet-based technologies, account for about 95 percent of TRS 

costs. 
Page 13 GAO-15-409 Telecommunications Relay Service

Figure 4: Total Costs for Each Form of Telecommunications Relay Service, 2002–2003 to 2013–2014

Note: We did not include cost data for CTS and IP CTS prior to July 2009 in this graphic because, 

according to FCC officials, it either did not exist or was not reliable. In addition, according to FCC 

officials, prior to July 2006, STS cost data were combined with TTY cost data.

As shown in figures 4 and 5, other forms of TRS are declining or staying 

the same in terms of costs and usage. IP Relay and traditional TTY, both 

of which require the person who is deaf or hard of hearing to type his or 

her part of the conversation, are declining in both minutes of use and 

costs. IP Relay minutes have decreased from about 83 million in rate year 

2006–2007 to about 18 million in rate year 2013–2014. TTY minutes have 

decreased from about 27 million in rate year 2002–2003 to about 3 million 

in rate year 2013–2014. Similarly, total program costs for both services 

have declined as well. Officials from FCC, TRS providers, and consumer 

groups told us that the growth in popularity of VRS and IP CTS have 

contributed to a decrease in the popularity of IP Relay and TTY. VRS and 
Page 14 GAO-15-409 Telecommunications Relay Service

IP CTS allow for much quicker and more natural conversations than the 

text-based IP Relay and traditional TTY. In recent years, CTS and STS 

have remained at a steady level in both minutes of use and costs. CTS 

functions like IP CTS, but uses the traditional telephone network rather 

than the Internet. STS serves a small, discrete population with severe 

speech disabilities. As shown in figure 3, both services account for small 

percentages of the entire cost of the TRS Fund. In rate year 2013–2014, 

CTS costs accounted for about 2 percent of the fund, while total STS 

costs were less than 1 percent of the fund. Figure 5 shows changes in 

minutes of use from rate years 2002–2003 through 2013–2014 for each 

form of TRS.

Figure 5: Changes in Minutes of Use for Each Form of Telecommunications Relay 

Service, 2002–2003 to 2013–2014

Note: GAO did not include minutes of usage data for CTS and IP CTS prior to July 2009 because, 

according to FCC officials, data did not exist or were not reliable.
Page 15 GAO-15-409 Telecommunications Relay Service

The per-minute reimbursement rates for TRS have varied over time, 

although the reimbursement rate for VRS has decreased significantly.

VRS reimbursement rates decreased from about $17 per minute in 2001–

2002 to about $4.25 per minute for VRS Tier 3 in 2015 (see fig. 6). 

Nonetheless, despite this decrease in the VRS reimbursement rate, its 

costs have grown significantly over this time period due to increased 

usage as discussed previously. The reimbursements rates for other forms 

of TRS, such as CTS, IP CTS, TTY, and STS, have increased moderately 

since 2011, while rates for IP Relay have decreased.

Figure 6: Trends in Telecommunications Relay Service (TRS) Cost Reimbursement Rates over Time

Note: GAO used reimbursement rates for VRS tier III from rate year 2007-2008 through rate year 

2013-2014. Reimbursement rates for IP Relay begin in rate year 2002-2003. Reimbursement rates 

for CTS and IP CTS begin in rate year 2007-2008.
Page 16 GAO-15-409 Telecommunications Relay Service

According to FCC, one provider and one consumer group, reducing fraud 

also has played a role in reducing costs for some forms of TRS. 

According to the FCC OIG, as the FCC OIG investigated VRS fraud and 

VRS reimbursement rates decreased, VRS costs decreased from rate 

year 2008–2009 to rate year 2010-2011, as shown in figure 4, even as 

VRS minutes increased in these rate years. In addition, FCC officials 

have told us that the efforts of the FCC Enforcement Bureau and OIG 

have contributed to a decrease in IP Relay fraud and thus IP Relay costs.

For example, according to FCC officials, FCC’s Enforcement Bureau 

investigated IP Relay providers to determine whether they had 

implemented a reasonable process to verify the accuracy of users’ 

registration information.18 Similarly, the FCC OIG worked with the 

Department of Justice to investigate allegations that a TRS provider had 

submitted false claims, such as Nigerian scam calls, from foreign 

locations in provision of an IP Relay.19 The FCC OIG attributes some of 

the reductions in IP Relay costs since 2008 to these fraud reduction 

efforts. In addition to its fraud reduction efforts, FCC made TRS providers’ 

research and development costs and outreach costs no longer 

reimbursable in FCC’s June 2013 VRS Reform Order, which could also 

reduce costs for some forms of TRS.20

 

18The investigations resulted in four actions, the assessment of penalties, and repayments 

to the TRS Fund. See, e.g., Purple Communications, Inc, Notice of Apparent Liability for 

Forfeiture, 29 FCC Rcd. 5491 (2014).

19According to FCC officials, the Nigerian scam calls that took place through IP Relay 

involved the fraudulent use of stolen credit cards to order large quantities of goods from 

American merchants via the anonymity of IP Relay.

20In the Matter of Structure and Practices of the Video Relay Service Program, 28 FCC 

Rcd. 8618 (2013) (Report and Order and Further Notice of Proposed Rulemaking).
Page 17 GAO-15-409 Telecommunications Relay Service

We have previously found that results-oriented organizations commonly 

perform a number of key practices to effectively manage program 

performance.21

With regard to the TRS program, the ADA directs FCC to ensure that 

telecommunications services are available, to the extent possible and in 

the most efficient manner, to persons with a hearing or speech disability, 

and that such services are “functionally equivalent” to the 

telecommunications services available to individuals without a hearing or 

speech disability.

In particular, results-oriented organizations implement two 

key practices to lay a strong foundation for successful program 

management. First, these organizations set performance goals to clearly 

define desired program outcomes. Second, they develop performance 

measures that are clearly linked to the performance goals.

22

The Government Performance and Results Act requires agencies to 

develop a performance plan covering each program activity set forth in 

the budget, which includes developing program goals that are objective, 

quantifiable, and measurable.

All of the FCC officials with whom we spoke agreed 

that the high-level purpose of the TRS program is this provision of 

functionally equivalent telecommunications to people with hearing or 

speech disabilities, but FCC has not established specific performance 

goals to guide its efforts toward achieving that purpose. Officials told us 

that they believe that the TRS program’s rules and numerous related 

reports and orders have sufficiently identified the performance goals of 

the program. We identified some performance measures associated with 

the program, but these measures are not clearly linked to any agency or 

program performance goals and are sometimes not well defined or 

measureable. Without stated program goals, it can be challenging for 

FCC to determine the extent to which it is fulfilling the purpose of the 

program.

23

 

21GAO, Executive Guide: Effectively Implementing the Government Performance and 

Results Act.

TRS is mentioned in FCC’s most recent 

budget request and performance plan, which, for budgetary purposes, 

groups TRS with FCC’s four universal service support programs.

However, there are no stated performance goals specific to the TRS 

program. There have been performance goals for TRS in previous 

GAO/GGD-96-118. (Washington, D.C.: June 1996).

2247 U.S.C. § 225.

23Pub. L. No. 103-62, § 4, 107 Stat. 286 (1993), codified at 31 U.S.C. § 1105(a).

FCC Has Not 

Established 

Performance Goals 

and Related 

Performance 

Measures for the TRS 

Program
Page 18 GAO-15-409 Telecommunications Relay Service

performance plans. For example, in its fiscal year 2012 performance plan, 

FCC had a goal to increase access to TRS services. However, this goal 

does not appear in current performance plans, and FCC officials told us 

they were unable to determine how many unique users participated in the 

TRS program or the number of potential TRS users. Thus, no 

performance measure—or method for obtaining the measurement data—

was linked to this goal, making it difficult for FCC to demonstrate whether 

or to what extent access to services among the target populations had 

increased.

One useful practice for developing successful performance goals that we 

have identified in previous work is to create a set of goals that address 

important dimensions of a program’s performance and balance competing 

priorities.24 For example, officials told us that important dimensions of the 

program are, among other things, the quality of the services provided to 

users and the existence of competition among TRS providers. However, 

FCC has not established performance goals related to these dimensions.

For instance, FCC lacks any goal related to interpreter accuracy, which 

consumer groups we met with stressed was critical to achieving quality 

services. Accurate relay of important medical, legal, or financial calls by 

CAs was of particular concern to consumer groups with whom we spoke.

Without goals related to important dimensions of service quality, such as 

interpreter accuracy, it becomes difficult to determine if this attribute of 

functional equivalency is being met and to identify whether programmatic 

changes need to be made. FCC officials acknowledged that there is no 

interpreter accuracy goal, but stated that they believe there is no practical 

way to evaluate interpreter accuracy. However, the consumer groups and 

some service providers we met with told us that interpreter accuracy 

could be evaluated with test scripts. Similarly, with regard to the important 

program dimension of competition, different numbers of providers offer 

different forms of TRS, but FCC has no performance goals with relation to 

levels of competition or ratemaking. For example, FCC stated in its 2013 

VRS Reform Further Notice of Proposed Rulemaking that it believes there 

is a need to replace its VRS cost-of-service ratemaking with more marketbased approaches, and proposed transitioning to contract prices set 

through a competitive-bidding process, where feasible, and auctioning a 

portion of VRS traffic.25

 

24GAO, Agency Performance Plans: Examples of Practices That Can Improve Usefulness 

to Decisionmakers.

However, the proposed rulemaking set forth a 

GAO/GGD-99-69 (Washington, D.C.: February 1999).

25VRS Reform Order.
Page 19 GAO-15-409 Telecommunications Relay Service

number of questions about how such an approach would work, including 

questions about bidder qualifications and ensuring the quality of services.

Establishing performance goals around competition and ratemaking could 

help guide FCC’s efforts in these areas and improve the transparency of 

FCC’s actions, as decisions could more clearly be linked to the 

achievement of program goals.

Although FCC lacks specific performance goals, FCC does have in place 

some specific performance measures for TRS in the form of minimum 

program standards.26

• Providers shall transmit traditional TRS conversations in real time.

Compliance with the minimum standards is 

necessary for providers to receive compensation from the TRS Fund.

These performance measures include, among others, that:

• CAs must have a typing speed of at least 60 words per minute.

• Providers must have the following service functionalities: (1) call 

release, (2) speed dialing, and (3) three-way calling.

• Emergency calls must be able to be expeditiously transferred to an 

emergency services provider as if a caller had dialed 911 directly.

• TRS calls (except VRS) must be answered by CAs within 10 seconds 

85 percent of the time.

In addition, to its credit, FCC has formally established performance 

measures for the TRS Fund administrator. For example, measures such 

as the timeliness of TRS Fund collections, payments, and status reports 

to FCC, among others, are included in FCC’s contract with RLSA. 

Although FCC has established some TRS performance measures, these 

measures are not linked to any TRS or universal-service performance 

goals. By establishing performance measures before establishing 

performance goals, FCC may be spending its time and resources, and 

those of the service providers or program administrator, on efforts not well 

linked to key dimensions of the program. Also, the performance measures 

FCC is using for the program can be difficult to assess because criteria 

are lacking. For instance, other minimum standards state, among other 

things, that CAs must be “sufficiently trained” to meet the needs of 

individuals with hearing and speech disabilities; must have “competent 

 

2647 C.F.R. §.64.604.
Page 20 GAO-15-409 Telecommunications Relay Service

skills” in grammar, spelling, and interpretation of typewritten ASL; and

must possess “familiarity” with hearing and speech disability cultures, 

languages, and etiquette. These terms are not defined by FCC and, as a 

result, are difficult to measure in a consistent manner across TRS 

providers. It is up to the service providers to determine that they are 

meeting these requirements and self-certify that they are doing so.27

Thus, although FCC has 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 wellbalanced set of outcome and output measures that link to specific 

program performance goals.28 Performance measurement is critical to 

determining a program’s progress in meeting its intended outcomes and 

allowing Congress, FCC, and RLSA to assess the effectiveness of the 

TRS program and determine if operational changes are needed. Because 

of the lack of specific TRS performance goals—and specific performance 

measures that are crafted around those goals—it is difficult to determine 

in an objective, quantifiable way if TRS is fulfilling its purpose of making 

available functionally equivalent telecommunications services to persons 

with hearing and speech disabilities, and it is difficult for FCC to manage 

the program in a proactive, results-oriented manner.

 

27According to FCC officials, FCC exercises its enforcement authority to review and audit 

the accuracy of provider certifications, and takes enforcement action against providers 

that do not comply with FCC minimum standards.

28According to the Government Performance and Results Act, “outcome measures” are 

assessments of the results of a program compared to its intended purpose, and “output 

measures” are the tabulations, calculations, or recordings of activities or efforts and can 

be expressed in a quantitative or qualitative manner.
Page 21 GAO-15-409 Telecommunications Relay Service

Internal control is an integral component of an agency’s management 

process that provides reasonable assurance that the objectives of an 

agency’s program are being achieved. Program objectives can be broadly 

classified into one or more of the following categories:

• Operations: the effectiveness and efficiency of program operations;

• Reporting: the reliability of reporting for internal and external use; 

and

• Compliance: program compliance with applicable laws and 

regulations.

GAO’s Standards for Internal Control in the Federal Government

commonly referred to as the “Green Book,” defines the standards for 

internal control in the federal government.29 The Federal Managers’ 

Financial Integrity Act of 1982 (FMFIA) requires federal executive-branch 

entities to establish internal control in accordance with these standards.30

GAO has developed a tool to assist agencies in this process,31 as has 

OMB with its Circular A-123.

32

 

29GAO, Standards for Internal Control in the Federal Government, 

The Green Book identifies the following 

five components as being the highest level of the hierarchy of standards 

for internal control in the federal government:

GAO/AIMD-00.21.3.1

(Washington, D.C.: November 1999).

3031 U.S.C § 3512.

31GAO, Internal Control Management and Evaluation Tool, GAO-01-1008G (Washington, 

D.C.: August 2001).

32OMB, Management’s Responsibility for Internal Control, Circular A-123 (Washington, 

D.C.: December 2004).

FCC Has Designed 

Some Internal 

Controls but Lacks a 

Comprehensive 

Internal Control 

System to Manage 

Program Risks

An Internal Control 

System Helps Assure That 

Program Goals Are Met
Page 22 GAO-15-409 Telecommunications Relay Service

• Control Environment: The foundation for an internal control system. 

The control environment provides the discipline and structure to help 

an entity achieve its objectives.

• Risk Assessment: Assesses the risks facing the entity as it seeks to 

achieve its objectives. This assessment provides the basis for 

developing appropriate risk responses.

• Control Activities: The actions management establishes through 

policies and procedures to achieve objectives and respond to risks in 

the internal control system.

• Information and Communication: The quality of information that 

management uses to support the internal control system.

Communicating quality information is vital for an entity to run and 

control its operations.

• Monitoring: Assesses the quality of performance over time and 

ensures that the findings of audits and other reviews are promptly 

resolved.

According to the internal control standards, these five components must 

be effectively operating together in an integrated manner to provide 

assurance that operations, reporting, and compliance objectives are met.

Management is responsible for an effective internal-control system. As 

part of this responsibility, management sets the entity’s objectives, 

implements controls, and evaluates the internal control system.

FCC has designed some internal controls that focus on program 

compliance and reporting objectives. In response to TRS fraud, first 

identified by the FCC OIG audits of TRS providers, FCC implemented 

rule changes. FCC OIG officials told us that they first became suspicious 

of possible fraudulent activity in the TRS program based on particular 

reimbursement claims that they judged to be unusual. They told us that at 

the time there was insufficient scrutiny of call data for irregularities by 

NECA, the TRS Fund administrator. The FCC OIG began a formal 

investigation of the TRS program in 2008.33

 

33The Enforcement Bureau also began analyzing provider call records during this period 

and identified practices that resulted in inflated call minutes.

As a result of the joint 

investigation among FCC’s OIG, the Department of Justice, the Federal 

Bureau of Investigation, and the United States Postal Service, 26 people 

were charged in a scheme to steal more than $50 million from the TRS 

FCC Has Designed Some 

TRS Internal Controls That 

Address Compliance and 

Reporting
Page 23 GAO-15-409 Telecommunications Relay Service

Fund.34

• Prohibited per-minute reimbursement for internal calls: To 

address provider practices intended to inflate call minutes, FCC 

reiterated its policy that calls made by or to employees of VRS 

providers were not eligible for compensation from the TRS Fund on a 

per-minute basis.

FCC has addressed many of the vulnerabilities identified by the 

OIG through numerous rulemakings. For example, from 2010 through 

2013, FCC, among other things, designed control activities to address 

specific fraud risks:

35

• Eliminated subcontracting: In 2011, FCC changed the certification 

eligibility requirements for TRS providers to require that all Internetbased providers be directly certified by the FCC. Prior to this order, 

providers who were certified by FCC or by a state commission were 

allowed to subcontract some of the provision of services to third 

parties that did not have to be certified. FCC officials and other 

stakeholders told us that much of the fraud that had occurred in the 

VRS program was related to these non-certified subcontractors, 

specifically in the form of inappropriately generating minutes. Now that 

all providers are directly certified, fraud in the VRS market has 

decreased dramatically, according to FCC.36

• Strengthened certification: In 2011, FCC amended the TRS 

certification process to require that providers submit evidence 

demonstrating compliance with FCC’s rules and authorizing on-site 

inspections of providers’ facilities.37

 

34FCC, FCC Chief of Staff Praises Decisive Action to Prosecute Fraud in VRS Program,

Press Release (Washington, D.C.: Nov. 19, 2009).

In 2013, FCC further changed 

provider certification rules to require providers’ senior managers to 

35In the Matter of Structure and Practices of the Video Relay Service Program, 

Declaratory Ruling, 25 FCC Rcd. 1868, 1869-70, ¶¶ 3-5 (2010).

36The scope of our review did not include testing for fraudulent activity. The FCC OIG 

continues to conduct audits of TRS providers aimed at uncovering fraud, waste, and 

abuse in the TRS program. In March 2014, it was announced that investigations by the 

FCC OIG, the Department of Justice, and the Federal Bureau of Investigation, had led to 

VRS fraud indictments against two people, bringing the total number of people and 

business entities indicted for VRS fraud to 31.

37In the Matter of Structure and Practices of the Video Relay Service Program, Second 

Report and Order, 26 FCC Rcd. 10898 (2011). 
Page 24 GAO-15-409 Telecommunications Relay Service

sign under penalty of perjury that their companies’ claims for 

compensation from the fund were valid and that the data they 

reported were true and accurate.38 This change was implemented to 

deter fraudulent activity and further ensure that providers’ senior 

managers were diligent in verifying the information they submitted for 

reimbursement.

• Strengthened user registration rules: In 2012, the Commission 

implemented a rule that prohibited IP Relay providers from handling 

non-emergency calls made by first-time users without first verifying 

the user’s registration information.39

In addition to these controls, FCC has also implemented controls with 

regard to the TRS Fund’s administrator and routine audits of the program.

FCC better defined the role of the fund administrator in the contract it 

entered with RLSA. Among other things, the contract outlined the fund 

administrator’s roles in collecting, disbursing, and protecting TRS funds; 

in providing routine reports to FCC on the status of the fund; and in 

analyzing provider data for irregularities and withholding compensation 

when appropriate. FCC has also implemented an audit program, with 

audits conducted by the OIG, which includes periodic audits on the fund 

administrator and audits of service providers to ensure compliance with 

several TRS program rules. Since 2008, the OIG has conducted one 

Prior to this rule change, IP relay 

services entailed some degree of anonymity of end users and 

provided the technical ability to mask one’s calling location. Some 

individuals exploited this anonymity by using IP relay services to 

perpetrate scams and other types of abuse. In 2013, FCC also 

established new VRS registration rules to address the problems of 

fraud, waste, and abuse by improving the mechanism by which VRS 

users are verified. The new rule requires VRS users to register with 

each provider they use and certify that they had a qualifying disability. 

Users were also given a 10-digit number that was associated with 

their registered account. According to FCC officials, this change has 

drastically reduced the number of fraudulent calls placed through the 

TRS program.

 

38In the Matter of Structure and Practices of the Video Relay Service Program, Report and 

Order and Further Notice of Proposed Rulemaking, 28 FCC Rcd. 8618 (2013). 

39In the Matter of Misuse of Internet Protocol (IP) Relay Service; Telecommunications 

Relay Services for Individuals with Hearing and Speech Disabilities, First Report and 

Order, 27 FCC Rcd 7866, ¶ 13 n.53 (2012). 
Page 25 GAO-15-409 Telecommunications Relay Service

audit of the fund administrator and 33 audits of providers.40 OIG officials 

told us that their audits of TRS have focused on fraud and financial risks 

to the TRS Fund rather than risks related to the overall management of 

the TRS program or the quality of the relay services provided to 

customers.

FCC has designed some internal controls for the TRS program, 

particularly with respect to program compliance; however, as previously 

discussed, FCC does not have clear program performance goals. Without 

performance goals, it is difficult to create a comprehensive internal control 

system which identifies and manages the risks to achieving the program’s 

goals. 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. But the purpose of the TRS program is to provide 

functionally equivalent telecommunications to persons with hearing or 

speech disabilities. Thus, it is important that FCC’s internal control system 

be designed around identifying and addressing risks to providing 

functionally equivalent service, of which fraudulent activity would be one 

risk. We compared FCC’s control system with Green Book standards and 

found several instances where practices were not aligned. These 

instances, among others, create risks that program’s resources are not 

being effectively used to achieve the program’s purpose.

• Risk Assessment: Internal control standards call for a risk 

assessment that will identify risks, both internal and external, and 

analyze the risks for possible effects. Risk assessments are then used 

to help management formulate an approach for risk management. 

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 interactions 

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 

to persons who are deaf, hard of hearing, or have speech disabilities.

Six total risks were identified, none of which was specific to TRS. For 

example, one of the six risks identified in the TRS risk assessment 

was the “failure by management to recognize fraud in FCC programs.” 

 

40According to the OIG, 28 of these audits are complete and five are in process.

FCC Lacks a 

Comprehensive Internal 

Control System to Manage

TRS Program Risks
Page 26 GAO-15-409 Telecommunications Relay Service

While it is important that fraud risks and risks to program resources 

are identified and addressed to keep the program efficient and viable, 

the Green Book and other internal control guidance state that a risk 

assessment should identify all relevant risks posed to achieving 

program goals.41 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 to people with hearing and speech disabilities.

• Information and communication: 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,42 and FCC program policies are explained across 

numerous reports and orders. Six of 10 providers 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. As an example, we found changes affecting IP 

Relay services incorporated into the 2013 VRS Reform Order.

Specifically, among other things, the order modifies the rules so that 

all Internet-based providers are required to obtain individual user 

consent before a default provider change may occur. Thus, a provider 

of IP CTS, for example, might not know that rules for its service were 

part of a VRS order and could be unaware of changes affecting its 

company. Further, this issue was highlighted in a 2008 OIG audit of 

the program when the OIG recommended that FCC develop a TRS 

handbook for providers to supplement FCC rules and consolidate 

TRS program and administrative policies into a single reference 

guide. FCC officials told us that such a TRS handbook has not been 

created because they have prioritized other activities in managing the 

TRS program. In 2011, FCC, in observing that TRS rules had become 

“somewhat unwieldy” since 2000, sought comment on whether to 

reorganize section 64.604 of its rules, which pertains to the TRS 

program.43

 

41According to internal control standards, a precondition to risk assessment is the 

establishment of clear, consistent agency goals and objectives. As discussed, FCC has

not yet established clear performance goals for the TRS program.

FCC did not act on that proposal, but in 2013 proposed 

4247 C.F.R. Part 64, Subpart F.

4347 C.F.R. § 64.604.
Page 27 GAO-15-409 Telecommunications Relay Service

instead to revise the structure of its rules so that they are service 

specific and transmission specific, where appropriate, and sought 

comments more broadly on how best to reorganize its rules to 

improve program clarity. To date, FCC has 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.

• Monitoring. Monitoring can include, for a program like TRS that 

serves the public, the analysis of consumer complaints. Such 

complaints may indicate that deficiencies exist—deficiencies that 

could be investigated to determine any possible underlying causes.

FCC aggregates the TRS consumer complaints filed with FCC, state 

regulators, and providers, as well as aggregating complaints by 

service, complaint type, and the amount of time it takes to resolve 

them. For example, 76 percent of the 272 TRS complaints were about 

VRS. The types of TRS complaints most frequently received included 

complaints about customer service, interoperability of a consumer’s 

equipment with a service provider’s network, and “slamming” and 

“porting.”44 Subsequent to our request for any analyses FCC may 

have conducted on TRS complaints, FCC began conducting an 

analysis in August 2014 on complaints received from July 1, 2013, 

through June 30, 2014.45 According to FCC, there had not been any 

analysis like this conducted before. As a result of not routinely 

analyzing consumer complaints about TRS, FCC was missing an 

opportunity to monitor the TRS program and to proactively identify 

recurring issues, trends, and potential risks to the program and 

determine if corrective actions were needed. We have previously 

examined and noted concerns with FCC’s complaint process and 

recommended that FCC expand its outreach to consumers about this 

process and establish policies and procedures for monitoring and 

analyzing trends in consumer complaints, among other things.46

 

44In general, “slamming” occurs when a VRS provider changes a consumer’s preferred 

VRS provider without the customer’s permission. “Porting” involves changing the preferred 

VRS provider at the request of the consumer. Porting problems may arise if the exiting 

service provider is not cooperative in releasing the consumer’s telephone number to the 

consumer’s new relay service provider.

FCC 

45FCC’s analysis is available at https://apps.fcc.gov/edocs_public/attachmatch/DOC331113A1.docx. 

46See GAO, Telecommunications: FCC Needs to Improve Oversight of Wireless Phone 

Service, GAO-10-34 (Washington, D.C.: Nov. 10, 2009).
Page 28 GAO-15-409 Telecommunications Relay Service

agreed with our prior recommendation and, with regard to TRS, 

officials told us that they plan to routinely analyze TRS complaints 

going forward. In January 2015, FCC launched a new online 

consumer help center, which, according to FCC, will make it easier for 

consumers to file complaints and help streamline FCC’s process for 

synthesizing and analyzing trends in consumer complaints. Such 

analyses could help provide FCC with useful TRS data to help it make 

performance-based decisions and evaluate its efforts with regard to 

management of the TRS program.

Consumer groups and TRS providers identified, through interviews and a 

survey, the following challenges to TRS service’s quality: the lack of skillbased routing, interpreter accuracy, and decreasing TRS reimbursement 

rates.

Some of the consumer groups told us that the lack of skill-based 

routing—which would allow users making a TRS call to request a CA with 

a particular specialty, such as a medical or legal expertise—negatively 

affects TRS service quality. For example, one consumer group 

representative told us that under the current program a TRS user’s 

assignment is based on interpreter availability. The expectation that 

interpreters will be the best fit for all calls is not reasonable and can lead 

to poor communication, especially during medical or legal calls. In 

addition, 7 of the 10 providers responding to our survey said that the lack 

of skill-based routing leads to lower quality service (see app. II for our 

survey results). Some consumer groups have requested that VRS 

providers be allowed, or required, to offer skill-based routing. FCC is not 

in favor of compensating VRS providers for skill-based routing services 

due in part to a number of implementation issues. For example, FCC 

pointed out in its 2013 VRS Reform Order that skill-based routing 

implementation issues include how to reconcile a skill-based routing 

function with the requirement that VRS calls be answered in the order 

Stakeholders Cited 

Several Challenges to 

TRS Service Quality 

and Competition

Stakeholders Identified 

Challenges to Providing 

High Quality Services

Skill-Based Routing
Page 29 GAO-15-409 Telecommunications Relay Service

received, the availability of CAs to meet speed of answer requirements, 

determining the appropriate skills needed for specialized routing, and 

determining if skill-based routing should be mandatory or voluntary.47

Some consumer groups we interviewed identified interpreter accuracy as 

a TRS service quality challenge. Specifically, according to one consumer 

group, the wide range of skill levels across CAs creates the greatest 

challenge to users in obtaining accurate interpretation. They noted that 

some interpreters do not have the required skill level to ensure accuracy, 

a circumstance that can lead to misunderstandings between the two 

participants. FCC officials noted that TRS rules allow users to request a 

change in the interpreter when the user determines that effective 

communication is not occurring. FCC requires interpreters to be 

“qualified” but leaves it to the providers to make that determination.48

According to providers, decreasing the amount that TRS providers are 

reimbursed for their services can affect a company’s ability to hire and 

retain qualified interpreters. For example, 8 of 10 providers responding to 

our survey indicated that the current TRS reimbursement rates make it 

much more difficult to hire and retain qualified interpreters. Decreases in 

TRS reimbursement rates, according to one provider, have led some 

providers to find ways to cut costs by hiring less skilled—and therefore 

less expensive—CAs. However, there appears to be disagreement 

between VRS providers and FCC about whether VRS reimbursement 

rates are set at appropriate levels. According to the 2013 VRS Reform 

Order, in setting TRS Fund compensation rates for VRS for the 2010–11 

fund year, FCC found that in the prior 4 years—where the rates had been 

set based on providers’ projected costs—providers had been 

overcompensated by more than $2.00 per minute as a result of a reliance 

FCC 

officials told us that some providers employ only certified interpreters to 

meet this requirement, while other providers use their own testing and 

evaluation methods to determine which interpreters are qualified.

 

47VRS Reform Order, ¶ 180.

48According to FCC officials, the standard for interpreters to be qualified is that they must 

be able to interpret expressively and receptively, using specialized vocabulary. FCC 

officials said that the standard is based on case law derived from the ADA. 

Interpreter Accuracy

TRS Reimbursement Rates
Page 30 GAO-15-409 Telecommunications Relay Service

on projected costs and inaccurate demand forecasts submitted by 

providers.49

Consumer groups and TRS providers identified, through interviews and a 

survey, the following TRS-related competition challenges: TRS rate 

reductions,50 the lack of compensation for marketing and outreach and 

research and development, and the lack of interoperability between VRS 

providers.

The amount of compensation TRS providers receive has decreased over 

time, specifically, for VRS services.51 For example, as previously 

discussed, VRS rates have decreased from 2003 to 2015.52 Providers 

noted that the rate reductions have affected competition. Specifically, all 

10 providers stated that TRS rate reductions decreased competition, with 

6 of those providers stating that TRS rate reductions significantly 

decreased competition. Both providers and some consumer groups told 

us that TRS rate reductions have prevented new entrants from coming 

into the market and subsequently limited the number of providers a user 

can choose from. Further, providers told us rate reductions and increases 

in compliance requirements will lead more providers to exit the market.

However, FCC stated in its 2013 VRS Reform Order, that there is no 

evidence proving that per-minute costs have dropped dramatically based 

on the current TRS-fund administrator’s recalculated average of 

providers’ current reported per-minute costs.53

 

49VRS Reform Order, ¶ 183.

In addition, according to 

FCC, there are other reasons outside of rate reductions that could compel 

50TRS rate reductions refer to reductions in the reimbursement rates of VRS and IP Relay.

51VRS services make up about 70 percent of the payments to providers of all TRS 

providers from the TRS Fund, which makes VRS the largest TRS market in terms of 

compensation. 

52VRS rates went from $17 per minute for all VRS providers in 2003 to $5.29 per minute 

for tier i VRS providers, $4.82 per minute for tier II VRS providers, and $4.25 per minute 

for tier III VRS providers in 2015. 

53VRS Reform Order, ¶ 191.

Stakeholders Identified 

Challenges to 

Encouraging Competition 

and Technological 

Innovation

TRS Rate Reductions
Page 31 GAO-15-409 Telecommunications Relay Service

a provider to leave the market, such as a provider’s inability to compete 

effectively with other more efficient providers.

We conducted a market concentration analysis and found that 

competition among TRS providers is decreasing as the number of 

providers for most TRS services is decreasing. For example, the number 

of TRS providers has decreased from rate years 2008 through 2014 for 

all six TRS services except IP CTS. (See app. III for more detailed results 

of our market concentration analysis.) In addition, the VRS and IP CTS 

services, which have more providers and may appear to have the most 

competition, are dominated by a few providers. Our analysis found that in 

2013–2014 rate year the top VRS provider controlled most of the VRS 

market while the top three IP CTS providers controlled over 98 percent of 

the market, based on total minutes of service provided.54

Most TRS providers noted that the lack of compensation for marketing 

and outreach and research and development hinders competition. For 

example, 7 out of 10 providers stated that the lack of compensation to 

TRS providers for marketing and outreach has significantly decreased 

their ability to compete. According to one provider, a provider’s marketing 

and outreach efforts cut significantly into a provider’s profit margin, and as 

a result, the lack of marketing and outreach compensation discourages 

new entrants into the market and inhibits a provider’s ability to attract new 

customers through marketing efforts. According to FCC officials, they no 

longer reimburse providers’ marketing and outreach efforts because they 

cannot effectively determine whether there is a sufficient amount of 

potential new customers to warrant such an incentive. In addition, FCC 

stated in its 2013 VRS Reform Order that the majority of TRS’s marketing 

compensation appear to have been used by providers to promote 

individual-branded marketing campaigns focused on winning back TRS 

users from competitors rather than informing the general public about the 

nature and functions of relay services.55

 

54Our market concentration analysis measured the extent to which the activities in the 

TRS market are controlled by a few providers. We measured TRS provider concentration 

by calculating the number of providers, the concentration ratios of the top providers, and 

the Herfindahl-Hirschman Index (HHI), which account for the size-distribution of providers 

or the relative influence of both small and large providers in the market.

55In the Matter of Structure and Practices of the Video Relay Service Program, Report and 

Order and Further Notice of Proposed Rulemaking, 28 FCC Rcd. 8618, ¶31 (2013) (VRS 

Reform Order).

Lack of Compensation for 

Marketing and Outreach and 

Research and Development
Page 32 GAO-15-409 Telecommunications Relay Service

As mentioned, according to FCC officials, FCC ceased marketing 

compensation to providers and called for the creation of a national 

marketing and outreach pilot program that will, according to the 2013 

VRS Reform Order, seek to ensure that potential TRS users and the 

general public are aware of the TRS program and its role in providing 

functionally equivalent services.56 The 2013 VRS Reform Order outlined a 

nationwide TRS marketing and outreach pilot program that is intended to, 

among other things, establish clear messaging about the purposes, 

functions, and benefits of IP Relay and VRS; educate consumers who are 

deaf, hard of hearing, or have speech disabilities about broadband 

adoption programs available to low-income families; provide materials to 

local, state, and national governmental agencies on the purposes, 

functions, and benefits of IP Relay and VRS; and explore opportunities to 

collaborate with other entities to disseminate information about IP Relay 

and VRS. The 2013 VRS Reform Order called for the selection of either 

(1) “outreach coordinators” who will conduct and coordinate IP Relay and 

VRS outreach nationwide and will be compensated through the TRS 

Fund or (2) an FCC contract with the TRS Fund administrator to enter into 

a similar arrangement.57 According to the 2013 VRS Reform order, the 

TRS outreach coordinators will not be affiliated with any TRS provider 

and they will disseminate non-branded information to potential new users 

and to the general public about IP Relay and VRS, the purposes and 

benefits of the services, and how to access and use the services.58

According to most TRS providers, the elimination of compensation for 

research and development has also reduced competition and limited 

innovation. For example, 7 out of 10 providers stated that the lack of 

compensation from FCC to TRS providers for research and development 

significantly decreases their ability to compete. Specifically, one provider 

noted that the lack of compensation for research and development 

reduces a provider’s ability to compete through quality service 

improvements and innovations, such as new and unique provider-specific 

features including improved software functionality, enhancing VRS picture 

quality, or increasing captioning speed and accuracy during IP CTS 

sessions. However, according to FCC, TRS research and development 

 

56VRS Reform Order, ¶ 33.

57VRS Reform Order, ¶ 33.

58VRS Reform Order, ¶ 34.
Page 33 GAO-15-409 Telecommunications Relay Service

compensation is inefficient and duplicative. FCC stated in its 2013 VRS 

Reform Order that TRS research and development reimbursement would 

allow for duplicative spending because multiple providers would be able 

to expend research and development funds on similar or identical 

enhancements and would not share the results with potential or existing 

competitors.59 In addition, the 2013 VRS Reform Order, among other 

things, directed the FCC Managing Director to enter into an arrangement 

with the National Science Foundation to conduct research to ensure that 

TRS is functionally equivalent to voice telephone services and to improve 

the efficiency and availability of TRS.60

The majority of VRS providers stated that the lack of interoperability 

among VRS providers can inhibit competition. For example, 5 out of 6 

VRS providers stated that the lack of interoperability can lead to 

significantly less competition. Multiple providers told us, while 

interoperability of VRS equipment is required by FCC,

According to FCC officials, in 

January 2015, FCC and MITRE entered into a memorandum of 

understanding to conduct this research. FCC officials told us that the 

research project establishes a Center of Expertise that is intended to 

bring together experts, representatives of the community of persons with 

hearing or speech disabilities, and other stakeholders to prioritize and 

address the needs of TRS users. According to FCC officials, the Center 

of Expertise held its inaugural meeting in March 2015.

61

To address interoperability, improve competition, and quality, FCC 

proposed instituting and transitioning to a VRS Advanced Video 

Communication Platform (formerly known as Neutral Video 

some services 

are still not interoperable with other providers’ equipment and, as a result, 

one provider told us that they filed a petition with FCC.

 

59VRS Reform Order, ¶ 21.

60VRS Reform Order, ¶ 22.

61In the Matter of Telecommunications Relay Services and Speech-to-Speech Services 

for Individuals with Hearing and Speech Disabilities, Declaratory Ruling and Further 

Notice of Proposed Rulemaking, 21 FCC Rcd. 5442 (2006).

Lack of Interoperability among 

VRS Providers
Page 34 GAO-15-409 Telecommunications Relay Service

Communication Service Platform).62 According to the 2013 VRS Reform 

Order, a neutral video communication service provider will have multiple 

benefits, specifically: more effective and efficient competition on the basis 

of service quality, including interpreter quality and the capabilities to 

handle the varied needs of VRS, and more efficient and effective VRS CA 

service competition through the elimination of new entrant barriers such 

as the cost of building and maintaining a video communication service 

platform.63 In addition, the 2013 VRS Reform order directed FCC’s 

Managing Director to select a neutral third party to build, operate, and 

maintain the Advanced Video Communication Platform.64 In the order, 

FCC stated that it would contract out the above services and 

responsibilities to a third party and that party would be compensated 

through the TRS Fund.65

Some consumer groups and providers told us that the Advanced Video 

Communication Platform could stifle innovation. For example, the 

However, FCC officials stated that this 

procurement has been cancelled because prices were too high and the 

agency determined that it would not be in the federal government’s 

interest to accept any of the proposals submitted. Contrary to FCC’s 

perspective about the benefits of the Advanced Video Communication 

Platform, a majority of the providers responding to our survey stated that 

the platform will not improve competition. Specifically, 6 of 10 providers 

stated that the Advanced Video Communication Platform will reduce 

competition. One provider told us that the Advanced Video 

Communication Platform could disincentivize new companies from 

entering the market because existing TRS requirements, such as 24-hour 

staffing of interpreters, could still be in effect under the proposed 

Advanced Video Communication Platform. Therefore, according to the 

provider, labor costs could prevent new entrants from making profits.

 

62According to FCC’s 2013 VRS Reform Order, an Advanced Video Communication 

Platform allows a registered Internet-based VRS user to use VRS access technology to 

make and receive VRS and point-to-point calls through a VRS CA service provider. The 

functions provided by the Advanced Video Communication Service Platform include the 

provision of a video link, user registration and validation, authentication, authorization, 

ACD platform functions, routing (including emergency call routing), call setup, mapping, 

call features (such as call forwarding and video mail), and such other features and 

functions not provided by the VRS CA service provider. VRS Reform Order ¶ 89.

63 VRS Reform Order ¶ 90.

64 VRS Reform Order ¶ 93.

65 VRS Reform Order ¶ 93.
Page 35 GAO-15-409 Telecommunications Relay Service

Advanced Video Communication Platform request for proposal included a 

number of core features that all participating providers will use and offer 

to its customers. As a result, according to one provider, VRS providers 

would have to give up their proprietary technology and ultimately become 

a provider of interpretation services, rather than competing on unique and 

provider specific technological features in addition to interpretation. For 

example, another provider told us that as a result of a transition to an 

Advanced Video Communication Platform, existing innovative providerspecific features would no longer be available and subsequently replaced 

by Advanced Video Platform features. Since Advanced Video Platform 

features will be the same for all providers—as are reimbursement rates—

competition will shift from which company has the best features to which 

company has the best interpreters. FCC is in the beginning stages of 

developing the Advanced Video Communication Platform, so it is unclear 

at this point how it will affect VRS service quality and competition.

Since 2002, annual TRS Fund expenditures have grown by over $700 

million. A variety of factors contributed to this growth, including the 

development of Internet-based TRS services, increased TRS usage, and 

some fraud in VRS and IP Relay. The size of the TRS Fund is likely to 

continue to rise as more persons with hearing or speech disabilities learn 

about these services and the hard-of-hearing population increases as the 

baby boomers age. FCC’s fraud reduction efforts contributed to the 

decreases in total TRS costs that occurred in 2010 and 2011. FCC must 

continue to be vigilant about fraud, especially as new technologies 

emerge that could require the development of new internal controls. 

Beyond fraud reduction efforts, however, it is important that the TRS 

program be managed in a proactive manner that is in accordance with 

leading management practices. If, for example, FCC does not develop 

specific multiyear and intermediate goals that are objective, quantifiable, 

and measurable and that have performance indicators, targets, and time 

frames, it becomes difficult to determine whether FCC has met the 

program’s purpose of providing functionally equivalent services. 

Developing linked, TRS-specific performance goals and measures; 

conducting a full TRS program risk assessment; and consolidating rules 

and procedures for each TRS service 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.

Conclusions
Page 36 GAO-15-409 Telecommunications Relay Service

To improve performance management of the Telecommunications Relay 

Service, we recommend that the Chairman of the Federal 

Communications Commission take the following three actions.

• 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.

• Following the establishment of TRS’s performance goals, conduct a 

robust risk assessment that can help FCC design a comprehensive 

internal-control system. 

• 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.

We provided a draft of this report to FCC and RLSA for their review and 

comment. FCC agreed with our recommendations and discussed actions 

it plans to take to implement the recommendations. A copy of FCC’s letter 

is reprinted in appendix IV. FCC also e-mailed technical comments, which 

we incorporated as appropriate. RLSA did not have comments on the 

report.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 10 days from the 

report date. At that time, we will send copies of this report to the 

appropriate congressional committees, the Chairman of the Federal 

Communications Commission, the Chief Executive Officer of Rolka Loube 

Saltzer Associates, and other interested parties. In addition, the report will 

be available at no charge on GAO’s Web site at http://www.gao.gov.

Recommendations for 

Executive Action

Agency and ThirdParty Comments
Page 37 GAO-15-409 Telecommunications Relay Service

If you have any questions about this report, please contact me at (202) 

512-2834 or goldsteinm@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Major contributors to this report are listed in appendix V.

Sincerely yours,

Mark L. Goldstein

Director, Physical Infrastructure Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-15-409 Telecommunications Relay Service

The objectives of this report were to examine (1) how the services and 

costs of the Telecommunications Relay Service (TRS) program have 

changed since 2002; (2) the Federal Communication Commission’s 

(FCC) performance goals and measures for the TRS program and how 

they compare with key characteristics of successful performance goals 

and measures; (3) the extent to which the design of the TRS program’s 

internal control system identifies and considers program risks; and (4) the 

challenges, if any, that exist in ensuring quality services for users and a 

competitive environment for providers. The scope of our audit did not 

include the testing of specific internal control activities. 

To determine how the costs and services of the TRS program have 

changed since 2002, we reviewed FCC documents, including FCC orders 

and stakeholder comments in FCC rulemaking proceedings. In addition, 

we reviewed FCC’s OIG, GAO, Congressional Research Service, and 

consumer group reports on TRS. We also collected and analyzed TRS 

program data on costs and minutes of usage for all six major forms of 

TRS from 2002–2014. We assessed the reliability of these data through 

conversations with FCC and RLSA officials about how the data are 

gathered and maintained. We determined the data were sufficiently 

reliable for the purposes of showing trends in program usage and costs.

We selected 2002 for the scope of our review as that was the year when 

Video Relay Service (VRS)—a popular form of TRS—was first made 

widely available. We interviewed:

Agencies

Federal Communications Commission

Federal Communications Commission-Office of Inspector General

TRS Fund Administrators

National Exchange Carrier Association

Rolka Loube Saltzer Associates

Associations

American Association of the Deaf-Blind

Association of Late Deafened Adults

Cerebral Palsy and Deaf Organization

Hearing Loss Association of America

National Association of the Deaf

Telecommunications for the Deaf, Inc.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-15-409 Telecommunications Relay Service

Registry of Interpreters for the Deaf

TRS Providers

American Sign Language Services, Inc.

AT&T Inc.

Communication Axess Ability Group

Convo Communications

CSDVRS

Hamilton Relay

InnoCaption, Inc.

Purple Communications, Inc.

Sorenson Communications

Sprint Corporation

We analyzed these interviews to identify how and why TRS services had 

changed in costs and minutes from 2002-2014.

To identify FCC’s performance goals and measures for the TRS program, 

we reviewed FCC documents, such as strategic plans and performance 

budgets; reviewed FCC web pages pertaining to the TRS program; and 

interviewed FCC officials about program goals and measures. To assess 

program goals and measures, we compared FCC’s performance goals 

and measures to key characteristics of successful performance goals and 

measures that GAO developed in prior work, as well as to requirements 

contained in the Government Performance and Results Act of 1993, as 

amended by the GPRA Modernization Act of 2010.1

To understand the extent to which the design of the TRS program’s 

internal control system appropriately identifies and considers program 

risks, we reviewed FCC documents and rules, and spoke with FCC 

officials about TRS internal controls. Specifically, FCC, FCC OIG, and the 

current TRS Fund administrator provided us program-related 

documentation on risk assessments, control activities, and audits. We 

identified what controls were in place and then compared the design of 

the internal control system with the requirements contained in the GAO 

 

1

Pub. L. No. 103-62, 107 Stat. 285 (1993), as amended by Pub. L. No. 111-352, 124 Stat. 

3866 (2010).
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-15-409 Telecommunications Relay Service

Standards for Internal Control in the Federal Government (the Green 

Book).

To assess the challenges to ensuring quality services for users and a 

competitive environment for providers, we first identified challenges that 

were identified through our interviews with representatives from all 10 

TRS providers, associations representing the community of persons who 

are deaf or hard of hearing, FCC, FCC OIG, and the current and previous 

TRS Fund administrators. We also reviewed TRS-related FCC orders, 

standards set in the Americans with Disabilities Act, and industry 

literature. In addition, to develop quantifiable information about the 

providers’ views on the challenges to ensuring quality services for users 

and a competitive environment for providers, we developed a survey 

instrument for the providers. We pretested the survey with one provider to 

ensure that questions were clear, unbiased, comprehensive, and that 

terminology was used correctly. We made changes to the content of the 

questions in response to the pretest. We surveyed all 10 providers and 

received a 100-percent response rate. Because we administered the 

survey to the complete universe of potential respondents, there are no 

sampling errors. However, the practical difficulties of conducting any 

survey may introduce errors, commonly referred to as non-sampling 

errors. For example, difficulties in how a particular question is interpreted, 

in the sources of information that are available to respondents, or in how 

the data is entered into a database or analyzed can introduce unwanted 

variability into the survey results. In addition, to further analyze issues 

related to TRS competition and market concentration, we calculated 

certain measures of market concentration in the two largest forms of 

TRS—IP CTS and VRS—and analyzed the data on TRS minutes of 

service from each provider from 2008–2014. We selected 2008 as the 

starting year for this analysis because, according to FCC officials, this 

was the first year with complete market concentration data on all six 

forms of TRS.

We conducted this performance audit from April 2014 through April 2015 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusion based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Survey of Telecommunications 

Relay Service Providers

Page 41 GAO-15-409 Telecommunications Relay Service

The questions we asked in our survey of TRS providers are shown below. 

Our survey was comprised of closed- and open-ended questions. In this 

appendix, we include all the survey questions and aggregate results of 

responses to the closed-ended questions; we do not provide information 

on responses provided to the open-ended questions. For a more detailed 

discussion of our survey methodology see appendix I.

Contact Information:

Please provide the name and contact information of the person 

completing this survey in case GAO needs to follow up on the information 

provided.

Name:

Title:

Company:

Email:

Phone:

Service Quality Questions:

1. How, if at all, have the current TRS compensation rates affected your 

company’s ability to hire and retain qualified interpreters?

Response

Much more 

difficult to hire 

and retain 

 Slightly more 

difficult to hire 

and retain No effect

Slightly easier 

to hire and 

retain

Much easier to 

hire and retain Don’t Know

Total 

Responses

8 0 2 0 0 0 10

2. Industry wide, how, if at all, has a lack of skill-based routing affected 

TRS consumers receiving quality service?

Response

Much higher 

quality service 

 Slightly higher 

quality service No effect

Slightly lower 

quality service

Much lower 

quality service Don’t Know

Total 

Responses

0 0 2 2 5 1 10

Appendix II: Survey of Telecommunications 

Relay Service Providers 
Appendix II: Survey of Telecommunications 

Relay Service Providers

Page 42 GAO-15-409 Telecommunications Relay Service

3. Industry wide, how, if at all, has interpreter workload affected TRS 

quality?

Response

Much higher 

quality 

 Slightly higher 

quality No effect

Slightly lower 

quality 

Much lower 

quality Don’t Know

Total 

Responses

0 0 2 4 3 1 10

4. Overall, how effective is the FCC’s current oversight and testing of 

TRS quality?

Response

Extremely 

effective Very effective 

Somewhat 

effective Slightly effective Not at all effective Don’t Know Total Responses

0 0 4 6 0 0 10

5. Do you have any recommendations for how the FCC could better 

oversee and test TRS service quality? If so, please briefly describe 

below.

6. How much, if at all, will the FCC’s proposed Advanced Video 

Communication Platform (formerly known as Neutral Video 

Communication Service Platform) improve service quality?

Response

A lot A little Not at all Don’t know 

Total 

Responses

0 1 5 4 10
Appendix II: Survey of Telecommunications 

Relay Service Providers

Page 43 GAO-15-409 Telecommunications Relay Service

7. Please rank the following TRS quality challenges from the most 

significant challenge to the least significant challenge. Please place a 

1 in front of the most significant challenge, 2 in front of the second, 

etc.

Response

Question Rank 1 Rank 2 Rank 3 Rank 4 Rank 5

A. TRS compensation rates affect a company’s ability to 

hire and retain qualified interpreters. 4 6 0 0 0 

B. Lack of skill-based routing 0 1 5 3 1 

C. Interpreter workload 0 1 4 3 2 

D. FCC oversight and testing of service quality 0 2 3 1 4 

E. Other [Open-ended] 6 0 0 0 0 

Competition Questions:

8. How much, if at all, have TRS rate reductions affected competition in 

the TRS market?

Response

Significantly 

increased 

competition

Increased 

competition

Neither 

increased or 

decreased 

competition

decreased 

competition

Significantly 

decreased 

competition Don’t Know

Total 

Responses

0 0 0 4 6 0 10

9. For those services that your company provides or has provided, how 

much, if at all, do current TRS rates attract new companies to enter 

the TRS market and provide services? (Please respond “Don’t 

provide” if your company doesn’t currently or hasn’t previously 

provided the service).
Appendix II: Survey of Telecommunications 

Relay Service Providers

Page 44 GAO-15-409 Telecommunications Relay Service

Response

TRS Service Type A lot A little Not at all Don’t know

Don’t 

Provide Total

VRS 8 0 0 0 2 10

Text-to-Voice TTY-based TRS 0 1 2 0 7 10

Speech-to-Speech (STS) Relay Service 0 1 3 0 6 10

Captioned Telephone Service 0 1 2 0 7 10

Internet Protocol (IP) Relay Service 0 1 3 0 6 10

IP Captioned Telephone Service 0 2 3 0 5 10

10. How, if at all, has a lack of interoperability among providers affected 

competition?

Response

Significantly 

less competition

Moderately less

competition

Slightly less 

competition No effect

There is no lack 

of 

interoperability 

among

providers Don’t Know

Total 

Responses

5 2 0 3 0 0 10

11. How, if at all, has the lack of compensation from the FCC to TRS 

providers for research and development affected your company’s 

ability to compete?

Response

Significantly less 

ability to compete

Moderately less 

ability to compete

Slightly less 

ability to compete No effect Don’t Know Total Responses

7 1 1 1 0 10

12. How, if at all, has the lack of compensation from the FCC to TRS 

providers for marketing and outreach affected your company’s ability 

to compete?

Response

Significantly less 

ability to compete

Moderately less 

ability to compete

Slightly less 

ability to compete No effect Don’t Know Total Responses

7 1 1 0 1 10
Appendix II: Survey of Telecommunications 

Relay Service Providers

Page 45 GAO-15-409 Telecommunications Relay Service

13. How, if at all, will the FCC’s proposed Advanced Video 

Communication Platform (formerly known as Neutral Video 

Communication Service Platform) affect competition?

Response

Significantly 

increase 

competition

Increase 

competition

Neither increase 

nor decrease 

competition

Decrease 

competition

Significantly 

decrease 

competition Don’t know

Total 

Responses

1 1 0 1 5 2 10

14. Please rank the following challenges to TRS competition from the 

most significant challenge to the least significant challenge. Please 

place a 1 in front of the most significant challenge, 2 in front of the 

second, etc.

Response

Question Rank 1 Rank 2 Rank 3 Rank 4 Rank 5 Rank 6 Total

A. TRS rate reductions 8 1 1 0 0 0 10

B. Current TRS rate’s ability to attract new 

TRS providers 1 0 3 1 3 2 10

C. Lack of interoperability among providers 1 2 0 2 4 1 10

D. Lack of compensation for research and 

development 0 2 4 3 1 0 10

E. Lack of compensation for marketing and 

outreach 0 2 2 4 1 0 10

F. Other [Open-ended] 1 3 0 0 0 0 4 
Appendix III: GAO Analysis of Provider 

Concentration in TRS Product Markets, 2008–

2014 Rate Years

Page 46 GAO-15-409 Telecommunications Relay Service

Table 1: Provider Concentration in TRS Product Markets (annually as of July 1)

A. Number of Providers

TRS Products 2008 2009 2010 2011 2012 2013 2014 

TTY 7 7 6 5 3 4 3 

STS 7 7 6 5 3 4 NA

CTS 4 4 4 4 3 4 3 

IP Relay 6 6 7 6 3 3 NA

IP CTS NA 3 3 5 3 3 4 

VRS 10 9 8 9 7 6 6 

B. Concentration Ratio of Providers by Rate Year

TRS Products 2011–12 2012–13 2013–14 

IP CTS: Top 2 Providers 66.6% 75.2% 71.7%

IP CTS: Top 3 Providers 99.5% 99.3% 98.6%

VRS: Top 2 Providers 92.9% 91.2% 90.2%

VRS: Top 3 Providers 100% 99.0% 98.7%

C. Herfindahl-Hirschman Index (HHI) by Rate Year

TRS Products 2011–12 2012–13 2013–14 

IP CTS 3509 3554 3403

VRS 6973 6791 6603

Source: GAO Analysis of FCC data. | GAO-15-409

Notes: Under section A, number of providers was calculated in July of each year, which is beginning 

of the rate year

The concentration ratios and the HHI are computed for providers with complete data for the rate year; 

the data are not reported for other forms of TRS due to data limitations or confidentiality.

Appendix III: GAO Analysis of Provider 

Concentration in TRS Product Markets, 

2008–2014 Rate Years
Appendix IV: Comments from the Federal 

Communications Commission

Page 47 GAO-15-409 Telecommunications Relay Service

Appendix IV: Comments from the Federal 

Communications Commission
Appendix IV: Comments from the Federal 

Communications Commission

Page 48 GAO-15-409 Telecommunications Relay Service
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 49 GAO-15-409 Telecommunications Relay Service

Mark Goldstein, 202-512-2834 or goldsteinm@gao.gov

In addition to the contact named above, Faye Morrison (Assistant 

Director), Daniel Bertoni, Melissa Bodeau, David Bruno, Richard Bulman, 

Scott Clayton, Elizabeth Curda, David Hooper, Bert Japikse, John 

Karikari, Kelsey Kennedy, Kristen Kociolek, Hannah Laufe, Kieran 

McCarthy, Joshua Ormond, Steve Rabinowitz, Oliver Richard, Kelly 

Rubin, and James Sweetman Jr. made key contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(543341)
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