ACCESSIBLE 

COMMUNICATIONS

FCC Should Evaluate 

the Effectiveness 

of Its Public

Outreach Efforts 

Report to Congressional Committees

June 2015

GAO-15-574

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-15-574, a report to 

congressional committees

June 2015

ACCESSIBLE COMMUNICATIONS

FCC Should Evaluate the Effectiveness of Its Public 

Outreach Efforts

Why GAO Did This Study

CVAA was enacted to help ensure that 

people with disabilities have full access 

to the benefits of technological 

advances in communications. The act

required FCC to establish regulations

and conduct public outreach and 

included a provision that GAO review 

FCC’s efforts. GAO examined (1) the 

extent to which FCC established

complaint and enforcement procedures 

within CVAA-required time frames and 

conducted public outreach, (2) the 

actions FCC has taken to ensure 

industry compliance with CVAA’s 

recordkeeping provisions and to 

determine the level of industry 

compliance with accessibility 

requirements, and (3) stakeholders’ 

views on the effect of CVAA’s 

recordkeeping obligations on the 

development and deployment of new 

communications technologies.

GAO reviewed FCC’s regulations, 

orders, and biennial reports to 

Congress; surveyed a random sample 

of companies certifying compliance 

with CVAA requirements; assessed 

FCC’s efforts to conduct public 

outreach against key practices GAO 

previously identified through an expert 

panel; and interviewed FCC officials 

and representatives from industry 

associations, consumer advocate 

groups, and disability research 

organizations selected based on 

CVAA-related comments they 

submitted to FCC.

What GAO Recommends

FCC should evaluate its public 

outreach efforts and ensure those 

efforts incorporate key practices. FCC 

concurred with the recommendation 

and intends to take action to address it.

What GAO Found

The Federal Communications Commission (FCC) established accessibility 

complaint and enforcement procedures within the time frames mandated by the 

21st Century Communications and Video Accessibility Act of 2010 (CVAA) to 

ensure that people with disabilities would have access to advanced 

communications. FCC’s complaint and enforcement procedures enable 

consumers to file (1) a pre-complaint Request for Dispute Assistance (RDA), (2) 

an informal complaint, or (3) a formal complaint if consumers believe a 

communications product or service is not accessible to people with disabilities. 

From October 8, 2013, to April 1, 2015, FCC received 48 RDAs and no informal 

or formal complaints. FCC has undertaken numerous efforts to inform the public 

about CVAA’s protections and remedies by, for example, hosting seminars and 

webinars and publishing consumer guides on accessibility issues. However,

GAO found FCC’s efforts do not always align with key practices for conducting 

public outreach. In particular, FCC has not evaluated the effectiveness of its 

public outreach efforts. Without such an evaluation, FCC does not know the 

program’s effectiveness in informing the public of the protections and remedies 

available under CVAA and thus cannot reasonably assure the quality, quantity, 

and timeliness of the outreach program. Evaluating the outreach efforts would 

also enable FCC to determine whether current resources allocated to the 

outreach program are appropriate or need adjustment.

FCC has taken limited actions to ensure industry compliance with CVAA’s 

recordkeeping provisions and does not know the extent to which industry is fully 

complying with the requirements to make products and services accessible. FCC 

established the Recordkeeping Compliance Certification and Contact Information 

Registry to help ensure industry compliance with recordkeeping requirements. 

Companies subject to any CVAA accessibility requirement must submit an 

annual certification to FCC that they are maintaining records of their efforts to 

make their products accessible through the Registry. FCC could not say whether 

industry is complying with CVAA accessibility requirements because FCC lacks 

an objective measure for making this determination. However, developing a 

measure might not be cost effective given that FCC has received no informal or 

formal complaints asserting non-compliance with these requirements. In FCC’s

2014 biennial report to Congress, FCC based its determination of industry 

compliance on public comments and industry association reports.

Stakeholders GAO surveyed and interviewed generally reported that CVAA’s 

recordkeeping obligations have not affected the development and deployment of 

new communications technologies. Specifically, GAO estimated that between 59 

and 70 percent of companies view CVAA’s recordkeeping requirements as 

having had no effect on their development and deployment of new 

communications technologies. Overall, industry associations and disability 

advocates GAO interviewed generally agreed that accessibility improved since 

the passage of CVAA. Industry associations highlighted a number of associationled efforts to bring industry and consumers together to ensure that the needs of 

disabled consumers are being addressed. Advocates for people with disabilities 

indicated that there were still many ways in which the accessibility of 

communications technology could be further improved, but some believed that 

CVAA resulted in more widely available accessible technology.

View GAO-15-574. For more information, 

contact Mark L. Goldstein at (202) 512-2834 

or goldsteinm@gao.gov.
Page i GAO-15-574 Accessible Communications

Letter 1

Background 4

FCC Established Complaint and Enforcement Procedures in a 

Timely Manner, but Public Outreach Could Be Improved 7

FCC Has Taken Limited Actions to Ensure and Determine 

Compliance with Recordkeeping Provisions and with 

Accessibility Requirements 15

Stakeholders Indicate CVAA’s Recordkeeping Obligations Have 

Had Minimal Effects Thus Far on the Development and 

Deployment of New Communications Technologies 18

Conclusions 21

Recommendation for Executive Action 22

Agency Comments 22

Appendix I Objectives, Scope, and Methodology 24

Appendix II Copy of Survey to Certifying Companies 29

Appendix III Federal Communications Commission’s (FCC) Actions Implementing 

the Accessibility Complaint and Enforcement Procedures Required 

by the 21st Century Communications and Video Accessibility Act of 

2010 (CVAA) 39

Appendix IV Comments from the Federal Communications Commission 41

Appendix V GAO Contact and Staff Acknowledgments 42

Tables

Table 1: The Federal Communications Commission’s (FCC) 

Efforts Compared with Key Practices for Conducting 

Public Outreach 13

Table 2: Organizations Interviewed 28

Contents
Page ii GAO-15-574 Accessible Communications

Figures

Figure 1: Timeline of Communications Act Accessibility 

Requirements and Federal Communications Commission 

(FCC) Actions Implementing Those Requirements 6

Figure 2: The Federal Communications Commission’s (FCC) PreComplaint Request for Dispute Assistance (RDA) 

Process 9

Figure 3: The Federal Communications Commission’s (FCC) 

Informal Complaint Process for Accessibility Complaints 11

Figure 4: The Federal Communications Commission’s (FCC) 

Formal Complaint Process for Accessibility Complaints 12

Figure 5: Company Views on Selected Survey Questions Related 

to the Recordkeeping Requirements of the 21st Century 

Communications and Video Accessibility Act of 2010 19

Figure 6: Company Views on Selected Survey Questions Related 

to the Product and Service Accessibility Requirements of 

the 21st Century Communications and Video 

Accessibility Act of 2010 21
Page iii GAO-15-574 Accessible Communications

Abbreviations

CGB Consumer and Governmental Affairs Bureau

CVAA 21st Century Communications and Video Accessibility

Act of 2010 

DRO Disability Rights Office 

EB Enforcement Bureau 

FCC Federal Communications Commission 

RCCCI Recordkeeping Compliance Certification and

Contact Information 

RDA Request for Dispute Assistance 

VoIP Voice over Internet Protocol 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-15-574 Accessible Communications

441 G St. N.W.

Washington, DC 20548

June 25, 2015

The Honorable John Thune

Chairman

The Honorable Bill Nelson

Ranking Member

Committee on Commerce, Science

and Transportation

United States Senate

The Honorable Fred Upton

Chairman

The Honorable Frank Pallone, Jr.

Ranking Member

Committee on Energy and Commerce

House of Representatives

More than 56 million people in the United States have a disability, 

according to data from the Census Bureau. In addition to the difficulties 

that living with a disability can entail, people with disabilities can 

experience impeded access to the labor market, buildings, and 

communications. In particular, the spread of Internet-based and digital 

technologies has transformed the communications marketplace and 

altered our everyday lives. Smart phones, e-mail, and video conferencing 

are but a few of the many communications technologies that Americans 

rely on daily, and many of these advances have improved the 

communications capabilities of individuals with disabilities. However, due 

to questions about whether the full range of benefits of these 

technological advances are sometimes not accessible to the disability 

community, Congress passed the 21st Century Communications and 

Video Accessibility Act of 2010 (CVAA).1

CVAA required the Federal Communications Commission (FCC) to 

establish regulations to ensure that people with disabilities would have 

access to advanced communications (e.g., Voice over Internet Protocol, 

 1 Pub. L. No. 111-260, 124 Stat. 2751 (2010), as codified in various sections of title 47 of 

the United States Code (U.S.C.). 

Letter
Page 2 GAO-15-574 Accessible Communications

electronic messaging services, interoperable video conferencing, and 

Internet browsers built into mobile phones).2 These accessibility 

requirements for advanced communications supplement similar 

requirements established by law for traditional telecommunications (e.g., 

telephones, wireless handsets, and fax machines).3 CVAA also requires 

manufacturers and service providers of both traditional 

telecommunications and advanced communications to maintain records 

of their efforts to implement the act’s requirements to make their products 

accessible and submit an annual certification to FCC indicating that the 

companies are maintaining the records.4 The companies’ recordkeeping 

efforts include consultations with the disability community and information 

describing their products’ accessibility features and compatibility with 

commonly used peripheral devices.5 CVAA also required FCC to 

establish processes to facilitate the filing of complaints alleging the 

violation of the requirements to make traditional and advanced 

communications products and services accessible, and enforcement 

procedures in cases of violations.6 CVAA required FCC to establish a 

clearinghouse of information on the availability of accessible 

communications products and to conduct an informational and 

educational program designed to inform the public about the 

clearinghouse and the protections and remedies available under the act.7

Section 717 of the Communications Act of 1934, as amended by CVAA,8

included a provision that we evaluate FCC’s compliance with the 

enforcement and recordkeeping obligations contained in the act.9

 2 47 U.S.C. §§ 617 and 619. Voice over Internet Protocol (VoIP) is the routing of voice 

conversations over the Internet or any other Internet Protocol network.

In this 

report, we present information on (1) the extent to which FCC established 

complaint and enforcement procedures within the time frames required by 

3 47 U.S.C. § 255.

4 47 U.S.C. § 618(a)(5)(A) and (a)(5)(B).

5 47 U.S.C. § 618(a)(5)(A).

6 47 U.S.C. § 618(a).

7 47 U.S.C. § 618(d) and (e). 

8 Pub. L. No. 111-260, 124 Stat. 2751 (2010) (CVAA). CVAA is codified in various 

sections of Title 47 of the U.S. Code.

9 47 U.S.C.§ 618(c).
Page 3 GAO-15-574 Accessible Communications

CVAA and conducted public outreach, (2) the actions FCC has taken to 

ensure industry compliance with CVAA’s recordkeeping provisions and to 

determine the level of industry compliance with accessibility 

requirements, and (3) stakeholders’ views on the effect of CVAA’s 

recordkeeping obligations on the development and deployment of new 

communications technologies.10

To address these objectives, we reviewed relevant portions of CVAA and 

FCC documents, such as regulations, public notices, orders, and biennial 

reports to Congress. We compared FCC’s efforts in carrying out its 

responsibilities with requirements established in CVAA and assessed 

FCC’s efforts to conduct public outreach against key practices we 

previously identified.

We did not assess the effectiveness of 

CVAA’s enforcement provisions and FCC’s enforcement procedures to 

ensure compliance with CVAA because FCC had not taken any 

enforcement actions at the time of our review.

11

 10 We also present information on stakeholders’ views on the effect of CVAA requirements 

for making advanced communication products and services accessible on the 

development and deployment of new communications technologies.

In prior work, we convened an expert panel 

composed of 14 senior management-level experts in strategic 

communications to identify the key practices of a consumer education 

campaign. We selected these experts—who represented private, public, 

and academic institutions—based on their experience overseeing a 

strategic communications or social marketing campaign or other relevant 

expertise. We believe the key practices the expert panel identified in 2007 

remain relevant today since the practices are not time-sensitive. We also 

analyzed recordkeeping compliance certifications data covering the 

period January 2013 (the date the certification requirement became 

effective) to April 2015. We reviewed consumer complaints information 

covering the period October 2013 (the date the accessibility complaints 

process became effective) to April 1, 2015. We interviewed FCC officials 

and representatives from six industry associations, seven consumer 

advocate groups, and two disability research organizations. We selected 

organizations that had submitted at least two responses to FCC’s 

solicitations for public input on implementing CVAA from October 2010 

through September 2014; five organizations selected for interviews 

declined to speak with us or could not be reached. To obtain industry 

11 GAO, Digital Television Transition: Increased Federal Planning and Risk Management 

Could Further Facilitate the DTV Transition, GAO-08-43 (Washington, D.C.: Nov. 19, 

2007). 
Page 4 GAO-15-574 Accessible Communications

views on the effects of CVAA’s requirements on the development and 

deployment of new communications technologies, we surveyed a random 

sample of 355 companies that had certified their compliance with the 

recordkeeping requirements of CVAA as of December 2014. We 

administered the survey from February 2015 through March 2015 and 

received 173 responses, for a 49 percent response rate. The results of 

our survey generalize to the population of the companies that had 

certified compliance with recordkeeping obligations as of December 2014. 

More details about our scope and methodology can be found in appendix 

I and a copy of our survey in appendix II.

We conducted this performance audit from September 2014 to June 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.

When Congress amended the Communications Act of 1934 in 1996, it 

added a provision to ensure access to communications technologies for 

people with disabilities.12 The provision, Section 255, required 

manufacturers of traditional telecommunications equipment, such as 

telephones, wireless handsets, or fax machines, and providers of 

traditional telecommunications services, such as telephone calls, voice 

mail, or interactive voice response systems13 to “ensure that [their 

products and services] be accessible and usable by people with 

disabilities” if making them so was “readily achievable.”14

 12 Telecommunications Act of 1996, Pub .L. No. 104-104, §101, 110 Stat. 56, 75 (1996).

For a product or 

service to be “accessible” means that it must have certain input, control, 

and mechanical functions and meet certain information requirements to 

13 FCC, Consumer Guide, Telecommunications Access for People with Disabilities, 

accessed June 4, 2015, http://www.fcc.gov/guides/telecommunications-access-peopledisabilities.

14 According to 47 C.F.R. § 6.3(h), readily achievable means “easily accomplishable and 

able to be carried out without much difficulty or expense.”

Background
Page 5 GAO-15-574 Accessible Communications

operate and use the product.15 Whether making a product or service 

accessible is “readily achievable” depends, among other things, on the 

cost of the required action and the overall financial resources of the entity 

responsible for bearing that cost.16

CVAA was enacted to increase the access of people with disabilities to 

modern communications. Section 716, a new section of the 

Communications Act added by CVAA, requires manufacturers and 

service providers of “advanced communications services” to make their 

products accessible to people with disabilities. Advanced communication 

services include VoIP services, electronic messaging services, and 

interoperable video conferencing services. According to FCC, examples 

of accessibility features for equipment covered under sections 716 also 

include adjustable displays, screen readers, volume control, and tactile 

alerts. Section 718, also added by CVAA, introduced a similar 

accessibility requirement for manufacturers and service providers for 

Internet browsers built into mobile phones.

Examples of accessibility features for 

equipment covered under section 255 include adjustable displays, screen 

readers, volume control, and tactile alerts.

17 The functions of an Internet 

browser—for example, typing a web address in the address bar; 

identifying and activating home, back, forward, refresh, reload, and stop 

buttons; viewing status information; and activating zooming or other 

features—must be accessible to individuals who are blind or visually 

impaired. Importantly, advanced communication services were required to 

be made accessible unless doing so was not achievable,18

CVAA requires FCC to report biennially to Congress on its assessment of 

the level of industry compliance with CVAA’s accessibility requirements, 

a more 

rigorous standard than that applied to traditional telecommunications.

 15 47 C.F.R. § 6.3(a). For example, the product or service should be operable for persons 

with little or no vision or hearing and provide visual and auditory information through text, 

images, icons, or other cues, among other requirements.

16 47 C.F.R. § 6.3(h).

17 47 U.S.C. § 619.

18 47 U.S.C. § 617(g) defined achievable as “with reasonable effort or expense, as 

determined by FCC.” In determining achievability, FCC is required to consider certain 

factors, such as cost of the steps needed to meet the accessibility requirements and the 

technical and economic impact on the operation of both the company and product in 

question.
Page 6 GAO-15-574 Accessible Communications

an evaluation of accessibility barriers that exist with respect to new 

communications technologies, and complaints received during the 

reporting period and their outcomes, among other things. See figure 1 for 

a timeline of selected CVAA requirements and FCC’s actions to 

implement them.

Figure 1: Timeline of Communications Act Accessibility Requirements and Federal Communications Commission (FCC) 

Actions Implementing Those Requirements
Page 7 GAO-15-574 Accessible Communications

FCC established accessibility procedures for filing complaints alleging 

violations of CVAA’s accessibility requirements and enforcement 

procedures for cases of a violation on October 7, 2011, within the 1-year 

statutory deadline.19 See appendix III for more detail on FCC’s actions 

implementing Section 717’s complaint and enforcement provisions. In 

developing its complaint and enforcement regulations and procedures, 

FCC took into account industry and consumer feedback. For example, 2 

weeks after CVAA’s October 2010 enactment, FCC issued a public notice 

soliciting input on complaint and enforcement procedures,20 and 6 months 

after enactment, a Notice of Proposed Rulemaking seeking public 

comment on implementing both complaint and enforcement 

requirements.21

 19 47 U.S.C. § 618(a). These procedures were published in the Federal Register in 

December 2011 and were included under title 47, part 14 of the Code of Federal 

Regulations. They became effective in January 2012, 76 Fed. Reg. 82354 (Dec. 30, 

2011).

FCC received about 100 public comments from October 

2010 to May 2011 after publishing those two solicitations. When FCC 

adopted its complaint procedures in October 2011, it discussed its 

rationale for accepting or rejecting some public suggestions. FCC 

continued to seek and receive public comments after adoption of the 

20 FCC, Public Notice: Consumer & Governmental Affairs Bureau and Wireless 

Telecommunications Bureau Seek Comment on Advanced Communication Provisions of 

the Twenty-First Century Communications and Video Accessibility Act of 2010, CG Docket 

No. 10-213, DA 10-2029 (Oct. 21, 2010).

21FCC, Notice of Proposed Rulemaking: In the Matter of Implementation of Sections 716 

and 717 of the Communications Act of 1934, as Enacted by the Twenty-First Century 

Communications and Video Accessibility Act of 2010 (among other matters), 26 FCC Rcd 

3133 (2011).

FCC Established 

Complaint and 

Enforcement 

Procedures in a 

Timely Manner, but 

Public Outreach 

Could Be Improved

FCC Established 

Accessibility Complaint 

and Enforcement 

Procedures within 

Mandated Time Frames
Page 8 GAO-15-574 Accessible Communications

procedures to prepare its first biennial report, published in October 2012, 

to Congress on FCC’s implementation of CVAA.22

FCC’s complaint and enforcement procedures contain three types of 

actions that consumers can take with FCC’s assistance. According to 

FCC, the procedures enable consumers to contact companies directly by 

using FCC’s database of company contact information—the 

Recordkeeping Compliance Certification and Contact Information 

(RCCCI) Registry.23

An RDA is the most informal action a consumer can take and the process 

begins with the consumer sending a dispute request to FCC’s Consumer 

and Governmental Affairs Bureau (CGB) explaining why the consumer 

believes the manufacturer or service provider is in violation and what the 

consumer needs to resolve the dispute. The consumer has multiple 

methods for filing an RDA form, including telephone, online, mail, e-mail, 

and fax. CGB’s Disability Rights Office (DRO) assists in resolving the 

accessibility problem by contacting the consumer to learn more about the 

problem and working with the consumer and company to try to resolve 

the problem within 30 days. The consumer may request one or more 

extensions in 30-day increments to continue working with DRO officials, 

according to FCC’s online Consumer Help Center.

FCC’s intention in adopting these procedures was to 

facilitate settlements between consumers and companies as informally as 

possible and assist consumers with bringing their complaints to 

companies. The three types of consumer actions FCC established are (1) 

the pre-complaint Request for Dispute Assistance (RDA) process, (2) the 

informal complaint process, and (3) the formal complaint process. As of 

April 1, 2015, FCC had received 48 RDAs and no informal or formal 

complaints.

24

 22 FCC, Biennial Report to Congress as Required by the Twenty-First Century 

Communications and Video Accessibility Act of 2010: In the Matter of Implementation of 

Sections 716 and 717 of the Communications Act of 1934, as Enacted by the Twenty-First 

Century Communications and Video Accessibility Act of 2010, 27 FCC Rcd 12204 (2012). 

If a consumer is not 

satisfied with the results of an RDA, the consumer may file an informal 

complaint but must do so within 60 days after the initial or extended 30-

23 FCC requires companies who are subject to the accessibility requirements of Sections 

255, 716, and 718 to submit contact information to the RCCCI Registry. 47 C.F.R. § 

14.31(b)(2). 

24 https://consumercomplaints.fcc.gov/hc/en-us/articles/202939874-Take-Action-Optionsfor-Filing-an-Accessibility-Complaint. Accessed on March 4, 2015.

Pre-Complaint RDA Process

Example of a Request for Dispute 

Assistance

A blind consumer was having difficulty finding 

an accessible mobile handset that had a full 

read out of all menu levels and audible 

keystrokes to work with his mobile service 

provider and that had sufficiently strong signal 

reception to work in his home. FCC’s 

Disability Rights Office facilitated a resolution 

by having the service provider work with the 

consumer to test several models until the 

consumer was able to find an accessible 

handset that he could use.

Source: GAO summary of FCC data. | GAO-15-574
Page 9 GAO-15-574 Accessible Communications

day period ends. If a consumer takes no action after 60 days, FCC closes 

the case. See figure 2 for a flowchart of the RDA process.

Figure 2: The Federal Communications Commission’s (FCC) Pre-Complaint Request for Dispute Assistance (RDA) Process

According to FCC’s October 2011 Report and Order,25

 25 FCC, Report and Order and Further Notice of Proposed Rulemaking: In the Matter of 

Implementation of Sections 716 and 717 of the Communications Act of 1934, as Enacted 

by the Twenty-First Century Communications and Video Accessibility Act of 2010 (among 

other matters), 29 FCC Rcd 11909 (2011).

the pre-complaint 

RDA process is to provide an appropriate amount of time to facilitate 

settlements and provide assistance to consumers to rapidly and efficiently 

resolve accessibility issues with companies. In addition, FCC’s intention 

with the RDA process is to lessen the hesitation of some consumers to 

approach companies about their concerns or complaints by themselves. 

Further, the report and order stated that FCC’s involvement before a 

complaint is filed will benefit both consumers and industry by helping to 

clarify the accessibility needs of consumers for the manufacturers or 

service providers against which they may be contemplating a complaint, 

encouraging settlement discussions between the parties, and resolving 

accessibility issues without the expenditure of time and resources in the 

informal complaint process. According to FCC, 48 RDAs were filed 

between October 8, 2013, the date the new CVAA accessibility complaint

rules took effect, and April 1, 2015. DRO facilitated a resolution for 43 

RDAs by contacting the consumer and the company, and none were 

escalated to an informal complaint for investigation. DRO dismissed 2 
Page 10 GAO-15-574 Accessible Communications

RDAs because it was unable to obtain a response from the consumer to 

obtain additional information about the accessibility problem or to facilitate 

resolution. One RDA was withdrawn by the consumer, and at the time of 

our review, 2 RDAs were pending as dialog continued among DRO, the 

consumers, and the service providers.

The informal complaint process begins when a consumer files an informal 

complaint form.26 DRO fills out the form based on the information from the 

consumer’s RDA filing. As required by CVAA,27 a consumer has multiple 

methods for filing the informal complaint form, including telephone, online, 

mail, e-mail, and fax. FCC’s procedures require the Enforcement Bureau 

(EB) to review the informal complaint form for completeness, including 

whether it shows a possible violation. EB will dismiss the complaint 

without prejudice to refile if the form is incomplete, but the consumer may 

then refile an informal complaint with the correct information. If complete, 

EB will serve the complaint to the company named in the complaint, 

which must respond within 20 days of receiving the complaint and send 

the consumer and FCC a non-confidential summary of its response. In 

this answer, the company must provide sufficient evidence demonstrating 

that the product or service is accessible, or, if not accessible, that 

accessibility was not achievable under the rules or readily achievable. 

The consumer may reply to the company’s response in writing but must 

do so within 10 days. EB will investigate the consumer’s allegation and 

the company’s written response, and is required by CVAA28 to issue an 

order within 180 days finding whether the company violated sections 255, 

716, or 718—i.e., that the company did not ensure its product was 

accessible and could not prove that ensuring accessibility was 

unachievable—or any of FCC’s implementing rules described in the Code 

of Federal Regulations.29

 26 Prior to filing an informal complaint, a consumer must first work through the RDA 

process. 

If a violation is found, FCC may direct the 

company to bring its product into compliance within a reasonable period 

27 47 U.S.C. § 618(a)(2).

28 47 U.S.C. § 618(a)(3)(B).

29 See 47 C.F.R. Part 6—Access To Telecommunications Service, Telecommunications 

Equipment And Customer Premises Equipment By Persons With Disabilities, Part 7—

Access To Voicemail And Interactive Menu Services And Equipment By Persons With 

Disabilities, and Part 14—Access To Advanced Communications Services And Equipment 

By Persons With Disabilities.

Informal Complaint Process
Page 11 GAO-15-574 Accessible Communications

of time and take other appropriate enforcement action. The rules allow a 

company the opportunity to comment on a proposed remedial action 

before FCC issues a final order. See figure 3 for a flowchart of the 

informal complaint process.

Figure 3: The Federal Communications Commission’s (FCC) Informal Complaint Process for Accessibility Complaints

FCC’s rationale for making an RDA a prerequisite for filing an informal 

complaint is that after a consumer has undertaken the RDA process, all 

parties involved—DRO officials, the consumer, and the company—should 

have identified the correct manufacturer or service provider that the 

consumer will name in the informal complaint and the consumer should 

have obtained all the information necessary to satisfy the minimum 

requirements for filing an informal complaint. FCC does not intend the 

informal complaint process to require legal representation and allows at 

any time for both parties to resolve the problem on their own or the 

consumer to withdraw the informal complaint and file another RDA.

To file a formal complaint, the consumer must first obtain an FCC 

registration number.30

 30 The formal complaint process generally requires legal representation for consumers 

who are not versed in formal legal proceedings, according to FCC officials. This process is 

generally resolved on a written record consisting of a complaint, answer, and joint 

statement of stipulated facts, disputed facts, and key legal issues, along with all 

associated affidavits, exhibits, and other attachments. FCC proceedings may also include 

other written submissions such as briefs, written interrogatories, and other supplementary 

documents or pleadings. See 47 C.F.R. § 14.38.

FCC sends the complaint to the company, which Formal Complaint Process
Page 12 GAO-15-574 Accessible Communications

must answer with a defense within 20 days of receipt. The consumer may 

file and serve a reply to the company’s defense but must do so within 3 

days of receiving the company’s answer. EB staff review and investigate 

the consumer’s formal complaint filings and the company’s answer to the 

complaint, and make a decision. FCC’s procedures do not include a 

deadline for making a decision on the complaint. As shown in figure 4, the 

filing of an RDA or an informal complaint is not a prerequisite for filing a 

formal complaint.

Figure 4: The Federal Communications Commission’s (FCC) Formal Complaint Process for Accessibility Complaints

Section 717 directed FCC to establish procedures for enforcement 

actions against violations of Sections 255, 716, and 718.31 The 

procedures include the process established for handling informal and 

formal complaints. As of April 1, 2015, FCC had not taken any 

enforcement actions against a company because no informal or formal 

complaints had been filed.

FCC has undertaken numerous efforts to conduct its CVAA-mandated 

informational and educational program to inform the public about the act’s 

protections and remedies. FCC established a clearinghouse of 

information on accessibility products and services within the 1-year 

statutory deadline,32

 31 47 U.S.C. § 618. FCC’s rules are codified at 47 C.F.R. § 14.30.

and is conducting an outreach program to inform the 

public about the clearinghouse and CVAA’s protections and remedies. 

For example, FCC has hosted seminars and webinars on accessibility 

issues; published consumer guides and news releases; sought public 

32 47 U.S.C. § 618(d) and (e).

FCC Has Conducted 

Public Outreach Efforts

but Has Not Evaluated 

Their Effectiveness
Page 13 GAO-15-574 Accessible Communications

comment on rulemaking and waiver requests in advance of orders; and 

updated subscribers to its public e-mail service on accessibility-related 

information. FCC also maintains the Accessibility Clearinghouse on its 

website, which provides links to, for example, disability organizations, 

resources by type of disability, products and services, and consumer 

guides. In addition, FCC established the Disability Advisory Committee, 

which is charged with making recommendations to FCC on the full range 

of disability access issues, suggesting ways to facilitate the participation 

of consumers with disabilities in proceedings before FCC, and providing 

an effective means for stakeholders to exchange ideas and develop 

recommendations for accessibility solutions.33

While FCC has undertaken efforts to conduct public outreach, it has not 

evaluated the effectiveness of its efforts. We previously identified nine key 

practices that are important to conducting a consumer education 

campaign.34

Table 1: The Federal Communications Commission’s (FCC) Efforts Compared with Key Practices for Conducting Public 

Outreach

We compared FCC’s accessibility public outreach efforts with 

the key practices we identified and found FCC’s efforts did not always 

align with the key practices, as shown in table 1. In particular, we found 

FCC’s efforts do not align with two of the key practices related to defining 

goals and objectives and establishing process and outcome metrics.

Key practices for conducting 

consumer education

FCC’s public outreach efforts to inform public about accessibilityrelated protections and remedies How FCC’s efforts 

align with practice

Define goals and objectives Section 717 of the Communications Act of 1934, as amended, defined 

the goals of the public outreach, namely to inform the public about the 

availability of the clearinghouse and the protections and remedies 

contained in the 21st Century Communications and Video Accessibility 

Act of 2010 (CVAA); however, FCC has not set formal objectives for its 

outreach program. 

Do not align

Analyze the situation FCC includes analyses in its biennial reports to Congress on, for 

example, industry’s compliance with CVAA’s accessibility requirements 

and remaining accessibility barriers.

Align

 33 The Disability Advisory Committee membership includes representatives of 

organizations and other entities representing people with disabilities, state or local 

governments, industry, and other individuals with significant expertise in the disability and 

accessibility issues.

34 GAO-08-43.
Page 14 GAO-15-574 Accessible Communications

Key practices for conducting 

consumer education

FCC’s public outreach efforts to inform public about accessibilityrelated protections and remedies How FCC’s efforts 

align with practice

Identify stakeholders FCC’s Consumer and Governmental Affairs Bureau (CGB) has identified 

consumer advocacy groups representing people with disabilities, 

industry associations, and other interested stakeholders through, for 

example, the over 150 conferences CGB had attended that were related 

to CVAA and accessibility issues and public notices it had issued 

seeking comment on proposed accessibility rules between October 2010 

and October 2014.

Align

Identify available budgetary and 

other resources 

Since February 2012, FCC has been identifying specific CVAA-related 

activities and broad targets in its annual fiscal-year budget requests to 

Congress. In addition, FCC identified human resources—such as CGB 

and Disability Rights Office (DRO) staff to attend accessibility 

conferences, meetings, and other events; Consumer Affairs and 

Outreach Division staff to plan, develop, and conduct consumer outreach 

and education initiatives; and Web and Print Publishing Division staff to 

develop and maintain content for consumers on FCC’s website and 

Consumer Publications Library. 

Align

Research target audiences CGB regularly attends telecommunications accessibility conferences. Align

Develop consistent and clear 

messages

While CGB has developed and presented messages through its various 

efforts, it has not assessed the consistency and clarity of the messages.

Somewhat align

Identify credible messengers CGB and DRO are responsible for outreach on consumer issues and for 

implementing CVAA.

Align

Design media mix CGB uses a mix of media for delivering information on CVAA—such as 

through its website, public AccessInfo@fcc.gov e-mail subscription, 

seminars, webinars, and in-person attendance at conferences and 

events. 

Align

Establish both process and 

outcome metrics to measure 

success in achieving objectives

FCC has not established any metrics to measure success in achieving 

objectives of the outreach campaign. Process metrics assure the quality, 

quantity, and timeliness of the work. Outcome metrics evaluate how well 

the campaign influenced the attitudes and behaviors of the target 

audience that FCC set out to influence.

Do not align

Sources: GAO analysis of GAO-08-43 and FCC internal and public documents. | GAO-15-574

FCC has not established objectives for the outreach or metrics for 

measuring success in achieving objectives. Without such metrics, FCC 

does not know the program’s effectiveness in informing the public of 

CVAA’s accessibility provisions and thus, cannot reasonably assure the 

quality, quantity, and timeliness of its outreach program. Establishing 

process and outcome metrics could help FCC determine whether the 

current levels of budgetary and other resources allocated to the outreach 

program need adjustment. We previously reported that evaluation is an 

essential element of any public education campaign and that it was 

considered by experts participating in our panel as a “must do” even with 

limited resources. The experts also stressed the importance of having a 

clear understanding of the goals and objectives of the public outreach 

campaign when designing the metrics that comprise the evaluation 
Page 15 GAO-15-574 Accessible Communications

component. Once the goals are clearly defined, planners can establish 

the necessary targets to measure the effectiveness of the public 

outreach.35 While the consumer advocate groups we interviewed 

generally had mixed views about the effectiveness of FCC’s public 

outreach efforts, some offered suggestions for FCC to improve its efforts, 

such as making its accessibility and complaint websites easier to use; 

being more proactive in instructing the disability community in how to file 

complaints; and explaining the differences between CVAA and the 

American with Disabilities Act.36 FCC officials acknowledged that 

establishing a process by which they could measure how effective their 

outreach efforts are would be very beneficial. They said such an 

evaluation is needed to provide them with important information, such as 

nationwide data on the different disabilities and the required product 

features and functions to achieve accessibility for each type of disability.

The primary action FCC has taken to ensure industry’s compliance with 

CVAA’s recordkeeping requirements37

 35

was to establish the 

Recordkeeping Compliance Certification and Contact Information 

(RCCCI) Registry, which is maintained on FCC’s website. Companies 

GAO-08-43.

36 Pub. L. No. 101-336, 104 Stat. 353 (1990). The Americans with Disabilities Act, a civil 

rights law, prohibits discrimination against individuals with disabilities in several areas.

37 47 U.S.C. § 618(d).

FCC Has Taken 

Limited Actions to 

Ensure and 

Determine 

Compliance with 

Recordkeeping 

Provisions and with 

Accessibility 

Requirements

FCC Established a 

Database to Facilitate 

Industry Self-Certifications
Page 16 GAO-15-574 Accessible Communications

subject to any of CVAA’s accessibility requirements must submit an 

annual certification to FCC that they are maintaining records of their 

efforts to make their products accessible through the RCCCI Registry. 

Companies enter three types of information into RCCCI: (1) contact 

information for a person within the company authorized to resolve 

consumer complaints; (2) contact information for a person within the 

company in the event of an informal or formal complaint; and (3) a 

certification that the company is maintaining records of its efforts to make 

its products and services accessible. To inform companies of their 

recordkeeping and annual certification obligations, FCC has been posting 

public notices and sending e-mails to its AccessInfo subscribers since 

2013, reminding them to submit the required information into the RCCCI 

Registry annually by April 1. The RCCCI Registry was made available on 

FCC’s website in January 2013, and as of April 2015, FCC had received 

approximately 3,777 industry certifications.

During our review, FCC officials were unable to say whether the actual 

number of compliance certifications recorded in the RCCCI Registry 

represents full industry compliance with CVAA’s certification 

requirements. In particular, although FCC estimated over 28,000 

companies could be affected by CVAA’s requirements, FCC officials told 

us that this estimate does not accurately capture the number of 

companies subject to CVAA’s recordkeeping requirements.38

 38 As part of securing authorization to implement CVAA’s recordkeeping requirement, 

FCC was required under the Paperwork Reduction Act to provide the Office of 

Management and Budget’s Office of Information and Regulatory Affairs with an estimate 

of the number of manufacturers and service providers that could be affected by CVAA’s 

requirements. To develop this estimate, FCC used the North American Industry 

Classification System, which federal statistical agencies developed to classify businesses, 

and U.S. Census Bureau information, as well as prior estimates FCC had developed for 

regulations covering related equipment and services. FCC estimated that up to 28,077 

companies could be affected by CVAA’s recordkeeping requirements once those 

requirements were fully in effect.

Additionally, 

we found some companies that certified compliance with CVAA’s 

recordkeeping requirements did not believe they were subject to CVAA. 

For example, a representative from a certifying company in Nebraska we 

selected randomly to interview told us the company was not maintaining 

records in accordance with CVAA since the company had not received 

any complaints about the inaccessibility of its services and there were no 

people with disabilities in its service area. However, CVAA’s accessibility 

FCC Does Not Know

the Extent of Industry’s 

Compliance with

CVAA Requirements
Page 17 GAO-15-574 Accessible Communications

and recordkeeping requirements are tied to the manufacturing of 

communications equipment or the provision of communications services, 

and not whether a company’s clients, in its judgment, are people with 

disabilities. A few companies responding to our survey indicated that they 

did not believe the accessibility or recordkeeping requirements of the act 

applied to them since they were wholesalers rather than retailers of 

telecommunications or advanced communications services. 

Nevertheless, these companies had self-certified to FCC that they were 

complying with CVAA’s recordkeeping requirements.

Furthermore, FCC cannot say whether industry is fully complying with the 

requirements to make products and services accessible. As stated 

previously, CVAA requires FCC to report biennially to Congress on the 

level of industry compliance with Sections 255, 716, and 718.39 However, 

FCC lacks an objective measure for making this determination. In the 

2014 biennial report to Congress,40 FCC based its determination of 

industry compliance primarily on the public comments it received and 

industry association reports to prepare the final report.41 For example, 

based on comments it received, FCC determined that Section 255 

companies increased the availability of accessible telecommunications 

equipment and that Section 716 and 718 companies “made efforts to 

comply.” Although such commentary does not enable FCC to objectively 

determine industry compliance, developing an objective measure might 

not be cost-effective because to date, FCC has received no informal or 

formal complaints asserting non-compliance with CVAA accessibility 

requirements.

 39 47 U.S.C. § 618(b)(1)(A).

40 FCC, Biennial Report to Congress as Required by the Twenty-First Century 

Communications and Video Accessibility Act of 2010: In the Matter of Implementation of 

Sections 716 and 717 of the Communications Act of 1934, as Enacted by the Twenty-First 

Century Communications and Video Accessibility Act of 2010, 29 FCC Rcd 11909 (2014).

41 To prepare the October 2014 second biennial report to Congress, FCC issued three 

public notices from June 17 to August 28, 2014, seeking input from the public by 

September 11, 2014, and received 45 public comments. 
Page 18 GAO-15-574 Accessible Communications

Stakeholders we surveyed and interviewed generally reported that 

CVAA’s recordkeeping obligations have not affected the development and 

deployment of new communications technologies. We asked companies if 

CVAA’s requirements to maintain records of their efforts42 to make their 

products and services accessible affected the development and 

deployment of new communications technologies. As shown in figure 5, 

based on responses from the random sample of certifying companies that 

we surveyed, estimates of the percentages of companies that view 

CVAA’s recordkeeping requirements as having had no effect on their 

development and deployment of new communications technology range 

from 59 and 70 percent (across the four recordkeeping requirements). All 

percentage estimates from the survey have margins of error at the 95 

percent confidence level of plus or minus 14 percentage points or less, 

unless otherwise noted. Furthermore, we estimate that between 27 and 

30 percent of companies view the recordkeeping requirements as posing 

little or no burden to their company; between 47 and 53 percent view the 

requirements as posing either “some” or a “moderate” burden.43

 42 The recordkeeping requirements include maintaining records of consulting with 

individuals with disabilities, maintaining written descriptions of the accessibility features of 

products and services, maintaining information on the capability of products with 

peripheral devices, and submitting an annual recordkeeping compliance certification to 

FCC. 47 U.S.C. § 618(a)(5).

A few 

companies that described themselves as small commented that the 

burdens of complying with the recordkeeping requirement had little or no 

corresponding benefit to consumers. Stakeholders we interviewed did not 

raise specific harms or benefits associated with CVAA’s recordkeeping 

obligations on the development and deployment of new communications 

technologies.

43 Based on our survey, we estimate that 33 percent of companies would like more 

specific guidance from FCC on how to comply with CVAA’s recordkeeping requirements.

Stakeholders

Indicate CVAA’s

Recordkeeping 

Obligations Have

Had Minimal Effects 

Thus Far on the 

Development and 

Deployment of New 

Communications 

Technologies
Page 19 GAO-15-574 Accessible Communications

Figure 5: Company Views on Selected Survey Questions Related to the Recordkeeping Requirements of the 21st Century 

Communications and Video Accessibility Act of 2010
Page 20 GAO-15-574 Accessible Communications

As part of our survey, we also asked companies if CVAA’s requirements 

to make their products and services accessible affected the development 

and deployment of new communications technologies. As shown in figure 

6, we estimate that 72 percent of companies view those requirements as 

having had no effect on their development and deployment of new 

communications technologies. An estimated 28 percent of companies 

view the product accessibility requirements as posing little to no burden 

on their businesses; another 59 percent described those requirements as 

posing either “some” or a “moderate” burden on their companies. 

Additionally, we estimate that 21 percent of companies increased their 

efforts to incorporate accessibility features into their products or services 

due to the passage of CVAA. Another 64 percent reported that there had 

been no change in their efforts to incorporate accessibility features in their 

products or services as a result of CVAA; however, many of these 

companies indicated that they had been subject to product accessibility 

requirements before its passage.44

 44The companies that already had to make their products and services accessible were 

those subject to 47 U.S.C. § 255, which was added in 1996. 

A few companies responding to our 

survey commented that either because they were small or because they 

were service providers rather than manufacturers, they had very little or 

no influence over whether technology was more accessible and that the 

primary way for them to increase the accessibility of their services was 

through vendor selection.
Page 21 GAO-15-574 Accessible Communications

Figure 6: Company Views on Selected Survey Questions Related to the Product and Service Accessibility Requirements of 

the 21st Century Communications and Video Accessibility Act of 2010

In our interviews, industry associations and advocates for people with 

disabilities generally indicated that product accessibility had improved 

since the passage of CVAA. Representatives from industry associations 

highlighted a number of association-led efforts to bring industry and 

consumers together to ensure that the needs of consumers with 

disabilities are being addressed. For example, the Consumer Electronics 

Association hosts an accessibility roundtable at its annual International 

Consumer Electronics Show. FCC officials noted that the collaboration of 

CTIA-The Wireless Association was instrumental in launching the 

accessibility clearinghouse, and CTIA started its own Accessibility 

Outreach Initiative in 2013. Representatives from the 

Telecommunications Industry Association cited their role in efforts to 

increase the quality of personal sound amplification devices. Advocates 

for people with disabilities indicated that there were still many ways in 

which the accessibility of communications technology could be further 

improved, but some believed that CVAA resulted in more widely available 

accessible technology.

CVAA requires manufacturers and service providers of advanced 

communications services to make their products accessible to people 

with disabilities and requires FCC to inform the public about the 

availability of the act’s protections and remedies. Although FCC has 

undertaken numerous efforts to conduct its informational and educational 

program, we found FCC could strengthen its public outreach efforts by 

Conclusions
Page 22 GAO-15-574 Accessible Communications

following key practices, especially related to (1) defining objectives and 

(2) establishing process and outcome metrics. FCC has spent time and 

resources conducting public outreach, such as hosting seminars on 

accessibility issues and attending accessibility conferences. However, 

FCC has not established formal objectives for the outreach program or 

process and outcome metrics to assess the extent to which the program 

is meeting CVAA’s goals. It is important for FCC to have a clear 

understanding of the goals and objectives of its public outreach prior to 

establishing the necessary targets to measure the effectiveness of its 

outreach efforts. By establishing process and outcome metrics, FCC 

could determine whether the current levels of budgetary and other 

resources allocated to the outreach program need adjustment. 

Furthermore, FCC could better ensure the quality, quantity, and 

timeliness of its outreach regarding CVAA’s protections and remedies.

We recommend the Chairman of FCC evaluate the effectiveness of 

FCC’s accessibility-related public outreach efforts and ensure those 

efforts incorporate key practices identified in this report, such as defining 

objectives and establishing process and outcome metrics.

We provided a draft of this report to FCC for its review and comment.

FCC provided written comments (reprinted in app. IV) and technical 

comments, which we incorporated as appropriate. In the written 

comments, FCC stated that it agreed with our recommendation and noted 

that evaluating its public outreach efforts could enable FCC to determine 

whether current resources allocated to these efforts are appropriate and 

help to ensure the quality, quantity, and timeliness of such efforts. FCC 

stated it is committed to achieving CVAA’s goals with respect to 

conducting public outreach and it will look to define objectives and 

establish process and outcome metrics to measure success in achieving 

those objectives.

We are sending copies of this report to the Chairman of the Federal 

Communications Commission and appropriate congressional committees. 

In addition, the report will be available at no charge on GAO’s website at 

http://www.gao.gov.

Recommendation for 

Executive Action

Agency Comments
Page 23 GAO-15-574 Accessible Communications

If you or members of your staff 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.

Mark L. Goldstein

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

Methodology

Page 24 GAO-15-574 Accessible Communications

Section 717 of the Communications Act of 1934, as amended by the 21st 

Century Communications and Video Accessibility Act of 2010 (CVAA),1

included a provision that we evaluate the Federal Communication 

Commission’s (FCC) compliance with the enforcement and recordkeeping 

obligations contained in the act.2 This report presents information on (1) 

the extent to which FCC established complaint and enforcement 

procedures within the time frames required by CVAA and conducted 

public outreach, (2) the actions FCC has taken to ensure industry 

compliance with CVAA’s recordkeeping provisions and to determine the 

level of industry compliance with accessibility requirements, and (3) 

stakeholders’ views on the effect of CVAA’s recordkeeping obligations on 

the development and deployment of new communications technologies.3

To determine whether FCC established complaint and enforcement 

procedures within the required time frames of CVAA, we reviewed the 

Section 717 provisions related to those procedures

We did not assess the effectiveness of CVAA’s enforcement provisions 

and FCC’s enforcement procedures to ensure compliance with CVAA 

because FCC had not taken any enforcement actions at the time of our 

review.

4 and compared them 

with FCC’s implementing actions. Specifically, we reviewed the 

procedures FCC publically released in its October 2011 Report and Order 

and Further Notice of Proposed Rulemaking,

5

 1 Pub. L. No. 111-260, 124 Stat. 2751 (2010) (CVAA). CVAA is codified in various 

sections of Title 47 of the U.S. Code (U.S.C.). 

those procedures 

2 47 U.S.C. § 618(c).

3 We also present information on stakeholders’ views on the effect of CVAA requirements 

for making their products and services accessible on the development and deployment of 

new communications technologies.

4 47 U.S.C. § 618(a).

5 FCC, Implementation of Sections 716 and 717 of the Communications Act of 1934, as 

Enacted by the Twenty-First Century Communications and Video Accessibility Act of 

2010, CG Docket No. 10-213; Amendments to the Commission’s Rules Implementing 

Sections 255 and 251(a)(2) of the Communications Act of 1934, as Enacted by the 

Telecommunications Act of 1966, WT Docket No. 96-198; Accessible Mobile Phone 

Options for People who are Blind, Deaf-Blind, or Have Low Vision, CG Docket No. 10-145;

26 FCC Rcd 14557 (2011).

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 25 GAO-15-574 Accessible Communications

published as final rules in December 2011 in the Federal Register,

6 and 

the final rules codified in the U.S. Code of Federal Regulations (C.F.R).

7

https://consumercomplaints.fcc.gov/hc/en-us

To determine what information FCC provides to the public about filing 

accessibility complaints, we reviewed its Consumer Help Center web 

page ( ), which FCC had 

redesigned and opened during the course of our review. The Consumer 

Help Center instructs the public in how to seek FCC’s assistance and file 

complaints not only on accessibility issues, but also on other issues 

related to TV, phone, internet, radio, and emergency communications. To 

determine FCC’s efforts to inform the public about the availability of the 

clearinghouse and the protections and remedies available under sections 

255, 716, and 718,8

http://ach.fcc.gov/

we reviewed the contents of FCC’s Accessibility 

Clearinghouse of Information, which can be found at ; 

October 2012 and October 2014 biennial reports to Congress; online 

Consumer Help Center; and AccessInfo@fcc.gov e-mails that update 

public subscribers on accessibility and disability issues. In addition, we 

reviewed FCC’s October 2011 Report and Order and Further Notice of 

Proposed Rulemaking and other FCC documents to determine whether 

FCC established the Accessibility Clearinghouse within the time frames 

required by CVAA.9 We assessed FCC’s public outreach efforts against 

the key practices for consumer education planning identified in our 

November 2007 report.10

 6 Federal Communications Commission Final Rule: 47 CFR Parts 1, 6, 7, and 14 [CG 

Docket No. 10–213; WT Docket No. 96–198; CG Docket No. 10–145; FCC 11–151] 

Implementing the Provisions of the Communications Act of 1934, as Enacted by the 

Twenty-First Century Communications and Video Accessibility Act of 2010; 76 Fed. Reg. 

82354 (Dec. 30, 2011).

To identify the key practices of a consumer 

education campaign, we convened an expert panel composed of 14 

senior management-level experts in strategic communications. We 

selected these experts, who represented private, public, and academic 

7 See Title 47: Telecommunication, Part 14—Access to Advanced Communications 

Services and Equipment by People with Disabilities, of the Code of Federal Regulations 

(47 C.F.R. § 14).

8 47 U.S.C. § 618(e).

9 47 U.S.C. § 618(d).

10 GAO, Digital Television Transition: Increased Federal Planning and Risk Management 

Could Further Facilitate the DTV Transition, GAO-08-43, (Washington, D.C.: Nov. 19, 

2007).
Appendix I: Objectives, Scope, and 

Methodology

Page 26 GAO-15-574 Accessible Communications

institutions, based on their experience overseeing a strategic 

communications or social marketing campaign or other relevant expertise.

To determine the actions FCC has taken to ensure industry compliance 

with CVAA’s recordkeeping11 and annual certification obligations,12

To determine the telecommunications industry’s views on the effect of 

CVAA’s certification and recordkeeping obligations on the development 

and deployment of new communications technologies, we conducted a 

web-based survey. We drew a stratified random sample of 355 

companies from the population of 3,549 companies that had submitted 

recordkeeping certifications to FCC as of December 5, 2014. To obtain 

these 355 companies, we divided the companies into those that had 

identified themselves as only being subject to the product accessibility 

requirements of Section 255 of the Communications Act, and those 

subject to the product accessibility requirements of Sections 716 and 718 

of the Communications Act. Companies that submitted a certification to 

FCC without identifying themselves by a section were excluded from the 

sample. Additionally, because oftentimes the same person served as the 

contact person for multiple companies, we took a systematic sample 

within each stratum to ensure that no one respondent received more than 

four surveys from us. With this probability sample, each member of the 

study population had a nonzero probability of being included, and that 

probability could be computed for any member. Each sample element 

was subsequently weighted in the analysis to account statistically for all 

the members of the population, including those who were not selected. To 

we 

reviewed FCC’s October 2011 Report and Order and Further Notice of 

Proposed Rulemaking, October 2012 and October 2014 biennial reports 

to Congress; and interviewed officials from FCC’s Consumer and 

Governmental Affairs Bureau and Enforcement Bureau. We also 

assessed FCC’s efforts for determining the level of industry compliance 

with Sections 255, 716, and 718 by analyzing FCC’s assessments in its 

biennial reports to Congress, analyzing data (covering January 2013 to 

April 2015) from the Recordkeeping Compliance Certification and Contact 

Information Registry to determine the number of distinct companies 

certifying their compliance with CVAA, and interviewing Consumer and 

Governmental Affairs Bureau officials.

 11 47 U.S.C. § 618(a)(5)(A)(i)-(iii).

12 47 U.S.C. § 618(a)(5)(B).
Appendix I: Objectives, Scope, and 

Methodology

Page 27 GAO-15-574 Accessible Communications

ensure that our survey questions were clear and logical and that 

respondents could answer the questions without undue burden, we pretested our questionnaire with five companies. We interviewed pretest 

companies that varied in company size, accessibility requirement section, 

and equipment manufacturing or service provision. We administered the 

survey from February 2015 through March 2015. We received 173 

responses, for a 49 percent response rate. Because we followed a 

probability procedure based on random selections, our sample is only one 

of a large number of samples that we might have drawn. Since each 

sample could have provided different estimates, we express our 

confidence in the precision of our particular sample’s results as a 95 

percent confidence interval. This is the interval that would contain the 

actual population value for 95 percent of the samples we could have 

drawn. All percentage estimates from the survey have margins of error at 

the 95 percent confidence level of plus or minus 14 percentage points or 

less, unless otherwise noted.

In addition to sampling errors, the practical difficulties of conducting any 

survey may also introduce other types of errors, commonly referred to as 

non-sampling errors. For example, difficulties in how a particular question 

is interpreted, in the sources of information available to respondents, or in 

how the data were entered into a database or were analyzed can 

introduce unwanted variability into the survey results. With this survey, we 

took a number of steps to minimize these non-sampling errors. For 

example, our staff with subject matter expertise designed the 

questionnaire in collaboration with our survey specialists. As noted 

earlier, the questionnaire was pretested to ensure that the questions were 

relevant and clearly stated. When the data were analyzed, a second 

independent GAO analyst independently verified the analysis programs to 

ensure the accuracy of the code and the appropriateness of the methods 

used for the computer-generated analysis. Since this was a web-based 

survey, respondents entered their answers directly into the electronic 

questionnaire, thereby eliminating the need to have the data keyed into a 

database, thus avoiding a source of data entry error.

In addition, as shown in table 2, we interviewed representatives from 15 

organizations to obtain their views of FCC’s action to implement the 

provisions of CVAA and CVAA’s effect on increasing the accessibility for 

people with disabilities. We selected organizations that had submitted two 
Appendix I: Objectives, Scope, and 

Methodology

Page 28 GAO-15-574 Accessible Communications

or more comments in reply to FCC’s solicitation of public comments on 

proposed rules, regulations, and biennial report drafts.13

Table 2: Organizations Interviewed

Organization Representation

Industry 

Associations

Alliance for Telecommunications 

Industry Solutions

Represents global information and communications technology 

companies.

Consumer Electronics Association Represents the consumer technology industry.

CTIA-The Wireless Association Represents the wireless communications industry, including wireless 

carriers and their suppliers, as well as providers and manufacturers of 

wireless data services and products. 

National Cable & Telecommunications 

Association

Represents U.S. cable industry.

Telecommunications Industry 

Association

Represents the global information and communications technology 

industry. 

Voice on the Net Coalition Represents developers, providers, and users of Internet communications 

applications, products, and services.

Consumer 

Groups

American Council of the Blind Represents blind and visually-impaired people. 

American Foundation for the Blind Represents people with vision loss.

Hearing Loss Association of America Represents people with hearing loss.

National Association of the Deaf Represents deaf and hard of hearing people.

National Federation of the Blind Represents blind and low-vision people.

Telecommunications for the Deaf and 

Hard of Hearing

Represents deaf, hard of hearing, late deafened, and deaf-blind 

individuals.

Research 

Organizations

RERC-Trace Research and 

Development Center, University of 

Wisconsin Madison

Promotes accessibility and usability in telecommunications products for 

people with all types of disabilities.

Wireless RERC, Georgia Tech Develops wireless technologies and products that meet the needs of 

individuals with disabilities.

Other American Library Association Represents libraries, librarians, and library users.

Source: GAO and organization information. | GAO-15-574

 13Although other organizations—including the Information Technology Industry Council, 

the Internet Association, the Enterprise Wireless Alliance, the American Association of 

People With Disabilities, and the Entertainment Software Association—also submitted two 

or more comments to FCC on this matter, those organizations either declined to speak 

with us or could not be reached. We did not interview individuals who submitted 

comments to FCC.
Appendix II: Copy of Survey to Certifying 

Companies

Page 29 GAO-15-574 Accessible Communications

The questions we asked in our survey of certifying officers of companies 

subject to the reporting requirements of Section 717 of the 

Communications Act of 1934, as amended by Title I of the 21st Century 

Communications and Video Accessibility Act of 2010, P.L. 111-260 

(CVAA) are shown below. Our survey was composed of closed- and 

open-ended questions. In this appendix, we include all survey questions 

and aggregate results of responses to selected closed-ended questions; 

we do not provide information on responses provided to the open-ended 

questions. For a more detailed discussion of our methodology, see 

appendix I.

Section 1: Demographics

Data intentionally not reported for questions in Section 1: Demographics

This questionnaire covers the following company:

(Company name was inserted)

1. Which of the following describes your company?

(Check all that apply.)

Section 255 - Interconnected VoIP Equipment Manufacturer

Section 255 - Interconnected VoIP Service Provider

Section 255 - Telecommunications Equipment Manufacturer

Section 255 - Telecommunications Service Provider

Section 716 - Electronic Messaging Equipment Manufacturer

Section 716 - Electronic Messaging Service Provider

Section 716 - Interoperable Video Conferencing Equipment 

Manufacturer

Section 716 - Interoperable Video Conferencing Service Provider

Section 716 - Non-interconnected VoIP Equipment Manufacturer

Section 716 - Non-interconnected VoIP Service Provider

Section 718 - Mobile Phone Equipment Manufacturer that includes 

an Internet browser

Section 718 - Mobile Phone Service Provider that arranges for 

inclusion of an Internet browser

Other - Please specify: ______________

Appendix II: Copy of Survey to Certifying 

Companies
Appendix II: Copy of Survey to Certifying 

Companies

Page 30 GAO-15-574 Accessible Communications

2. How many people did your company employ as of 

December 31, 2014?

(Please include part-time and temporary staff.)

o Less than 500

o 501 - 2,000

o 2,001 - 5,000

o More than 5,000

——————-

o Cannot determine

3. What was your company’s annual revenue for calendar 

year 2014?

Calendar year 2014 annual revenue: $ ________ No response

4a. Approximately what percentage of your company’s annual 

revenue is accounted for by products or services that are 

required to be made accessible under Sections 255, 716, and 718 

of the Communications Act as amended by CVAA?

o None

o 1-25 percent

o 26-50 percent

o 51-75 percent

o 76-100 percent

——————

o Cannot determine

If you selected “None,” please explain:
Appendix II: Copy of Survey to Certifying 

Companies

Page 31 GAO-15-574 Accessible Communications

4b. Approximately what percentage of your company’s products or 

services is required 

to be made accessible under Sections 255, 716, and 718 of the 

Communications Act 

as amended by CVAA?

o None

o 1-25 percent

o 26-50 percent

o 51-75 percent

o 76-100 percent

——————

o Cannot determine

If you selected “None,” please explain:

Section 2: CVAA Requirements: Products and Services

5. Have the requirements of Sections 255, 716, or 718 had a

beneficial effect, no effect, or an adverse effect on your 

company’s design, development, and deployment of new 

communications technologies?

Response

Estimated

Percentage

95 percent confidence

interval - lower bound

(percentage)

95 percent confidence

interval - upper bound

(percentage)

Very/Somewhat beneficial effect 1.71 0.34 4.96

No effect 72.45 59.01 82.76

Somewhat/Very adverse effect 4.85 1.24 12.38

Cannot determine 20.86 11.64 34.52

Please note: Sections 255, 716, and 718 contain requirements for manufacturers and 

service providers to make their products and services accessible to people with 

disabilities, to the extent achievable.
Appendix II: Copy of Survey to Certifying 

Companies

Page 32 GAO-15-574 Accessible Communications

5a. If you would like to expand on your response to Question 5, 

please include examples of products or services whose design, 

development, and deployment were either beneficially or 

adversely affected by the requirement to be made accessible.

Data intentionally not reported

6. In your opinion, what level of burden, if any, have the Section 

255, 716, and 718 requirements posed to your company?

Response

Estimated

Percentage

95 percent confidence

interval - lower bound

(percentage)

95 percent confidence

interval - upper bound

(percentage)

Little to no burden 27.85 17.19 41.80

Some/Moderate burden 58.58 44.59 71.31

Great/Very great burden 0.99 0.09 3.87

Cannot determine 12.43 5.77 24.74

6a. If you would like to expand on your response to Question 6, 

please include examples where the requirement to make your 

product or service accessible represented what you see as a 

burden.

Data intentionally not reported

Section 3: CVAA Requirements: Recordkeeping
Appendix II: Copy of Survey to Certifying 

Companies

Page 33 GAO-15-574 Accessible Communications

7. Have each of the following Section 717 recordkeeping

requirements had a beneficial effect, no effect, or an adverse 

effect on your company’s design, development, and deployment 

of new communications technologies?

(Select one answer in each row.)

Response

Estimated

Percentage

95 percent confidence

interval - lower bound

(percentage)

95 percent confidence

interval - upper bound

(percentage)

a. Maintaining records of 

consulting with individuals with 

disabilities

Very/Somewhat 

beneficial effect

1.85 0.41 5.16

No effect 65.02 51.34 76.61

Somewhat/Very 

adverse effect

15.85 8.15 28.58

Not sure 12.00 5.43 24.47

Not applicable 5.13 1.95 12.85

b. Maintaining written 

descriptions of the accessibility 

features of your products or 

services

Very/Somewhat 

beneficial effect

2.13 0.54 5.57

No effect 70.31 57.11 80.82

Somewhat/Very 

adverse effect

13.42 6.58 25.43

Please note: Section 717 states you “shall maintain, in the ordinary 

course of business and for a reasonable period, records of the 

efforts taken by such manufacturer or provider to implement

sections 255, 716, and 718, including the following:

(i) Information about the manufacturer’s or provider’s efforts to 

consult with individuals with disabilities.

(ii) Descriptions of the accessibility features of its products and 

services.

(iii) Information about the compatibility of such products and 

services with peripheral devices or specialized customer premise 

equipment commonly used by individuals with disabilities to achieve 

access.”

Section 717 also requires that “An officer of a manufacturer or 

provider shall submit to the

(Federal Communications) Commission an annual certification that 

records are being kept in accordance with” CVAA.
Appendix II: Copy of Survey to Certifying 

Companies

Page 34 GAO-15-574 Accessible Communications

Response

Estimated

Percentage

95 percent confidence

interval - lower bound

(percentage)

95 percent confidence

interval - upper bound

(percentage)

Not sure 10.00 4.33 21.40

Not applicable 4.00 0.69 12.13

c. Maintaining information on the

compatibility of your products 

with peripheral devices or 

specialized equipment

Very/Somewhat 

beneficial effect

1.14 0.13 4.10

No effect 70.31 57.11 80.82

Somewhat/Very 

adverse effect

13.42 6.58 25.43

Not sure 7.85 3.25 17.76

Not applicable 7.14 2.72 17.46

d. Submitting an annual 

recordkeeping compliance 

certification to FCC

Very/Somewhat 

beneficial effect

3.57 0.45 12.12

No effect 59.15 45.11 71.84

Somewhat/Very 

adverse effect

27.00 16.42 41.05

Not sure 6.14 2.01 17.26

Not applicable 1.42 0.23 4.53

7a. If you would like to expand on your response to Question 7, 

please include examples of products or services whose design, 

development, and deployment were either beneficially or 

adversely affected by the recordkeeping requirements.

Data intentionally not reported

8. In your opinion, what level of burden, if any, have each of the 

following Section 717 recordkeeping requirements posed to your 

company? (Select one answer in each row.)

Response

Estimated

Percentage

95 percent confidence

interval - lower bound

(percentage)

95 percent confidence

interval - upper bound

(percentage)

a. Maintaining records of 

consulting with individuals with 

disabilities

Little or 

no burden

30.29 19.11 44.42

Some/Moderate burden 46.72 33.33 60.60

Great/Very great burden 3.28 0.32 12.19

Not sure 12.57 5.89 24.84

Not applicable 7.00 2.61 17.41
Appendix II: Copy of Survey to Certifying 

Companies

Page 35 GAO-15-574 Accessible Communications

Response

Estimated

Percentage

95 percent confidence

interval - lower bound

(percentage)

95 percent confidence

interval - upper bound

(percentage)

b. Maintaining written 

descriptions of the accessibility 

features of your

products or services

Little or 

no burden

30.00 18.85 44.16

Some/Moderate burden 50.01 36.37 63.64

Great/Very great burden 3.85 0.61 12.11

Not sure 9.85 4.22 21.32

Not applicable 6.14 2.01 17.26

c. Maintaining information on the

compatibility of your products 

with peripheral devices or 

specialized equipment

Little or 

no burden

26.86 16.30 40.92

Some/Moderate burden 52.01 38.27 65.45

Great/Very great burden 3.71 0.53 12.11

Not sure 7.71 3.14 17.69

Not applicable 9.43 3.89 21.10

d. Submitting an annual 

recordkeeping compliance 

certification to FCC

Little or 

no burden

28.28 17.57 42.18

Some/Moderate burden 52.58 38.80 65.98

Great/Very great burden 6.28 2.11 17.27

Not sure 9.00 3.57 20.90

Not applicable 3.71 0.53 12.11

8a. If you would like to expand on your response to Question 8, 

please include examples 

where the recordkeeping requirements represented what you 

see as a burden.

Data intentionally not reported
Appendix II: Copy of Survey to Certifying 

Companies

Page 36 GAO-15-574 Accessible Communications

9. Would more specific guidance from FCC on how to satisfy 

Section 717’s recordkeeping requirements be helpful to your 

company?

Response

Estimated

Percentage

95 percent confidence

interval - lower bound (percentage)

95 percent confidence

interval - upper bound (percentage)

Yes 33.00 21.33 47.22

No 40.14 27.51 54.23

Not sure 26.57 16.04 40.67

10. Does your company maintain any of the following documents in 

support of the Section 717 recordkeeping requirements?

(Select all that apply.)

Data intentionally not reported

Marketing related documents, including:

Product requirements

Product definitions

Market research documents

Customer and end user surveys and responses

E-mails

Other

Engineering documents, including:

Device and system requirements

Device and product design documents

The following statement is excerpted from an FCC Notice of Proposed 

Rulemaking:

“We will not mandate any one form for keeping records (i.e., we adopt a flexible 

approach to recordkeeping). While we establish uniform recordkeeping and 

enforcement procedures for entities subject to Sections 255, 716, and 718, we 

believe that covered entities should not be required to maintain records in a specific 

format. Allowing covered entities the flexibility to implement individual recordkeeping 

procedures takes into account the variances in covered entities (e.g., size, experience 

with the Commission), recordkeeping methods, and products and services covered by 

the provisions.” (FCC 11-151, paragraph 223)
Appendix II: Copy of Survey to Certifying 

Companies

Page 37 GAO-15-574 Accessible Communications

Requirements analysis

Planning documents

E-mails

Other

Meeting records that discuss relevant subject material, 

including:

Agendas

Presentations and documents studied during the meeting

Meeting minutes

Meeting summaries

Other

Relevant test documents, including:

Test plans

Results

Summaries

Other

Documents that specifically address Section 255, 716, 717, or 

718 requirements, including:

Checklists

Device analysis

E-mails

Other

Other documents not listed above:

Other

—————————-

No response
Appendix II: Copy of Survey to Certifying 

Companies

Page 38 GAO-15-574 Accessible Communications

Section 4: Changes Since the Passage of CVAA

11. Due to the passage of CVAA, has your company increased or 

decreased its efforts to incorporate accessibility features in its 

products or services?

Response

Estimated

Percentage

95 percent confidence

interval - lower bound

(percentage)

95 percent confidence

interval - upper bound

(percentage)

Decreased greatly/somewhat 0.14 0.00 2.41

No change 63.59 49.68 75.54

Increased somewhat/greatly 20.70 11.90 33.55

Not sure 15.29 7.67 28.15

Section 5: Comments, Respondent Information, and Survey 

Completion Question

12. If you would like to expand upon any of your responses to the 

questions above, or have any other comments about the effect of 

Section 717’s recordkeeping requirements on your company’s

ability to develop and deploy new communications technologies, 

please enter them below.

Data intentionally not reported

13. In case we need to clarify any of your responses, please provide 

your name and contact information:

Name:

Title:

Organization:

E-mail:

Telephone:

Data intentionally not reported

Please note: CVAA was signed into law on October 8, 2010.
Appendix III: Federal Communications 

Commission’s (FCC) Actions Implementing the 

Accessibility Complaint and Enforcement 

Procedures Required by the 21st Century 

Communications and Video Accessibility Act 

of 2010 (CVAA)

Page 39 GAO-15-574 Accessible Communications

Section 717a provisions related to FCC’s establishment of 

complaint and enforcement procedures FCC’s actions implementing the provisions

FCC shall establish regulations within one year after CVAA’s 

enactment on October 8, 2010, that facilitate the filing of formal 

and informal complaints that allege a violation of Section 255, 

716, or 718. (§ 717(a))

FCC released the procedures on October 7, 2011, and published 

them under title 47, Part 14 of the Code of Federal Regulations 

(47 C.F.R. Part 14) on December 30, 2011. The procedures 

became effective on January 30, 2012.

FCC shall establish procedures for enforcement actions with 

respect to such violations. (§ 717(a))

FCC established enforcement procedures within the regulations 

setting forth the process for filing formal and informal complaints. 

As of March 2015, no informal or formal complaints have been 

filed with FCC.

FCC shall not charge any fee to an individual who files a 

complaint. (§ 717(a)(1))

FCC does not charge a fee for filing an informal complaint. In the 

case of a formal complaint, FCC officials stated that they do not 

interpret any filing fee requirements to apply to asserting violations 

of sections 255, 716, or 718. FCC’s October 2011 Report and 

Order implementing Section 717 indicated that there was a filing 

fee associated with the formal complaint process.b

FCC shall establish separate and identifiable electronic, 

telephonic, and physical receptacles for the receipt of complaints 

filed (§ 717(a)(2))

FCC’s procedures allow persons to file RDAs and informal 

complaints online and by telephone, mail, e-mail, and fax.

FCC shall investigate allegations in an informal complaint, and 

issue an order concluding the investigation, include a 

determination whether any violation occurred. (§ 717(a)(3)(B))

FCC established investigation actions in its procedures: 47 C.F.R. 

§ 14.37 for informal complaints and 47 C.F.R. § 14.38 for formal 

complaints.

In the case of a violation determination, FCC may direct the 

company to bring its service or the next generation of its 

equipment or device into compliance within a reasonable time. (§

717(a)(3)(B)(i))

FCC established this requirement in its procedures: 47 C.F.R. § 

14.37(b)(1). As of March 2015, no informal or formal complaints 

have been filed with FCC.

Before FCC makes a violation determination, the company shall 

have a reasonable opportunity to respond to such complaint. (§

717(a)(4))

FCC established this requirement in its procedures: 47 C.F.R. § 

14.36(b) for informal complaints and 47 C.F.R. § 14.38 for formal 

complaints.

Before issuing a final order, FCC shall provide the company a 

reasonable opportunity to comment on any proposed remedial 

action. (§ 717(a)(4))

FCC established this requirement in its procedures: 47 C.F.R. § 

14.37(c) for informal complaints.

After the filing of a formal or informal complaint against a 

company, FCC may request, and shall keep confidential, a copy 

of the records maintained by the company that are directly 

relevant to the complaint. (§ 717(a)(5)(C))

FCC established the requirement for requesting records in its 

procedures: 47 C.F.R. § 14.31(c) for informal and formal 

complaints. The procedures require companies to submit a 

request for confidentiality of these records.

Appendix III: Federal Communications 

Commission’s (FCC) Actions Implementing 

the Accessibility Complaint and Enforcement 

Procedures Required by the 21st Century 

Communications and Video Accessibility Act 

of 2010 (CVAA)
Appendix III: Federal Communications 

Commission’s (FCC) Actions Implementing the 

Accessibility Complaint and Enforcement 

Procedures Required by the 21st Century 

Communications and Video Accessibility Act 

of 2010 (CVAA)

Page 40 GAO-15-574 Accessible Communications

Section 717a provisions related to FCC’s establishment of 

complaint and enforcement procedures FCC’s actions implementing the provisions

Nothing in FCC’s rules shall be construed to preclude a person 

who files a complaint and a company from resolving a formal or 

informal complaint prior to FCC’s final determination in a 

complaint proceeding. In the event of such a resolution, the 

parties shall jointly request dismissal of the complaint and FCC 

shall grant such request. (§ 717(a)(8))

FCC’s intent in adopting its procedures was to encourage the nonadversarial resolution of disputes. The informal complaint 

procedures (47 C.F.R. § 14.37) (1) allow a consumer and a 

company to talk to each other at any time to resolve the complaint 

by mutual agreement, and a consumer to withdraw an informal 

complaint and file another request for dispute assistance, and (2) 

require the consumer to notify the Enforcement Bureau if either of 

those two actions has occurred. The formal complaint procedures 

(47 C.F.R. § 14.50) allow both parties to meet and settle any 

matter in controversy by agreement and require that both submit a 

joint statement to FCC of the agreed upon proposals.

Source: GAO analysis of CVAA, the Code of Federal Regulations, and FCC documents. | GAO-15-574

a Sec. 717 of the Communications Act of 1934, which was added by the CVAA.

b FCC, Report and Order and Further Notice of Proposed Rulemaking: In the Matter of 

Implementation of Sections 716 and 717 of the Communications Act of 1934, as Enacted by the 

Twenty-First Century Communications and Video Accessibility Act of 2010 (among other matters), 29 

FCC Rcd 11909 (2011).
Appendix IV: Comments from the

Federal Communications Commission

Page 41 GAO-15-574 Accessible Communications

Appendix IV: Comments from the

Federal Communications Commission
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 42 GAO-15-574 Accessible Communications

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

In addition to the individual named above, Sally Moino (Assistant 

Director), Amy Abramowitz, Enyinnaya David Aja, Susan Baker, Russell 

Burnett, Justin Fisher, Sam Hinojosa, David Hooper, Stuart Kaufman, 

Josh Ormond, Dae Park, and Amy Rosewarne made key contributions to 

this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(543349)
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