Az-fcc re-Certification Application

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Arizona Relay Service FCC Certification Renewal and Supporting Documents
Arizona Relay Service, a program under the Arizona Commission for the Deaf and for the Hard of Hearing, has prepared the following narrative and attached appendices to comply with the FCC TRS Certification Renewal Application, specifically in response to the FCC Public Notice DA 17-697, CG Docket No. 03-123 released on July 19, 2017. Included in the Public Notice are the minimum mandatory FCC Telecommunications Relay Service (TRS) requirements under 47 C.F.R. §64.604 and §64.606. A copy of this Public Notice and these mandatory requirements are attached as Appendix A. Arizona Relay Service prepared this TRS Certification Renewal Application with the assistance of Sprint Accessibility.
Arizona Commission for the Deaf and for the Hard of Hearing contracted with Sprint (formerly Sprint Relay) to provide Telecommunications Relay Service effective December 2, 2014, to provide operational, technical, and functional standards pertinent to the FCC mandates as specified in 47 C.F.R. §64.604 and §64.606. Due to delays in the transition from AT&T, Sprint actually started providing services on Feb. 1, 2015. Included with this TRS Certification Renewal Application is a copy of the “intent to award” notification that was issued December 1, 2017. All of the minimum mandatory TRS requirements are listed in the RFP and are attached as Appendix B. Please note that although Sprint Accessibility provides Internet Protocol (IP) and Captioned telephone web-based services, Arizona Relay Service does not contract to provide these services in Arizona, nor is Arizona Relay Service responsible for oversight of IP and VRS or to other Internet or web-based relay services.
The FCC has requested that each FCC TRS Certification Renewal application respond to the minimum mandatory FCC TRS requirements for providing Telecommunications relay services and that each state includes procedures and remedies for enforcing any requirements imposed by state programs. Additionally, the FCC requested that several exhibits such as outreach presentations, promotional items, consumer training materials, and consumer complaint logs be included with the information provided.

Table of Contents

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Operational Standards

A.1 Communication Assistants (CAs)

§64.604 (a)(1) (i) TRS Providers are responsible for requiring that all CAs be sufficiently trained to effectively meet the specialized communication needs of individuals with hearing and speech disabilities.

CA Employment Standards

Arizona Relay Service contracts with Sprint to provide the hiring, training and oversight of Communication Assistants (CAs) for Arizona Relay Service. Sprint has established a successful procedure to attract qualified applicants for TRS CA positions. Sprint’s Quality Assurance team has developed comprehensive hiring and training programs that prepare employees for the challenging position as a CA and ensures all communications are of the highest quality. Employees continue to expand their knowledge of Relay and the importance of providing quality services to the consumers they serve throughout their employment as a CA. CAs are required to have a high school diploma or GED, which ensures the applicant has at least a 12th-grade level of English grammar and spelling skills, the ability to type 60 words-per-minute (wpm) on an auditory-based test, clear articulation and an intelligible, pleasant speaking voice.

Preference is given to CA applicants with TRS experience, knowledge of American Sign Language, or experience working with individuals who are deaf, hard of hearing or have a speech disability.

All applicants for CA positions are required to submit an employment application that details the applicant’s educational and employment history.

After an applicant’s educational history, employment history and typing test results are reviewed; a determination is made as to whether the applicant meets the minimum CA requirements.

A human resources representative will then screen potential candidates through face-to-face and telephone interviews to evaluate the applicant’s communication skills, including English grammar, diction and speech clarity, sensitivity to issues of customer service, integrity and confidentiality, and overall suitability for the job. Those applicants who do not pass the HR screening interview will not be considered for employment.

Sprint TRS CA applicants are required to pass a valid and unbiased 12th-grade level spelling test to be considered for employment. Sprint TRS CA applicants must pass a valid unbiased 12th grade level grammar test to be considered for employment.

Once the applicant passes the HR screening interview, he/she is interviewed in person by an Operations Supervisor for specific job dimensions that relate to the success of a CA. These dimensions include sensitivity to customers and issues of confidentiality. If the Supervisor recommends the applicant for employment, the applicant must pass a drug screen and a background investigation of educational, work and criminal histories.

This process ensures only qualified applicants are hired to work at Sprint Accessibility centers as a CA.

Sprint provides an enhanced VCO service called Captioned Telephone (CapTel) Services. Sprint requires all CapTel CAs have a high school graduate equivalency as a minimum qualification for the job. Sprint ensures CapTel Operators are sufficiently trained to meet the needs of CapTel users. Trainees must demonstrate adequate skill level in all aspects of call processing prior to graduation from training. CapTel Relay Trainees must also demonstrate a strong proficiency in the primary required skill-set of re-voicing for CapTel calls.

  • CapTel Operator Trainees spend 2-3 weeks training in a classroom setting.

  • There is a final proficiency exam that must be passed in order to move into a live call environment.

  • Upon completion of classroom training, CapTel Operators are scheduled for one-week of transition training, while being monitored and supported by another CapTel Operator or an Instructor.

  • All CapTel Operators must continue to qualify for live call handling each month.

  • Sprint CapTel Operators are routinely coached on Call Center ergonomics, call handling procedures, and confidentiality.

  • Each CapTel Operator is evaluated on a minimum of one call each shift.

  • There is also a monthly test that each CapTel Operator must pass in order to remain qualified to caption live calls.

§64.604 (a)(1)(ii) CAs must have competent skills in typing, grammar, spelling, interpretation of typewritten ASL, and familiarity with hearing and speech disability cultures, languages and etiquette. CAs must possess clear and articulate voice communications.

Arizona Relay Service, through their contract with Sprint, has shown that that Sprint CAs have competent skills in typing, grammar, spelling, interpretation of written ASL and familiarity with hearing and speech disability cultures, languages and etiquette. Sprint requires all CAs to possess clear and articulate voice communications. CAs are given five written and three hands-on performance evaluations demonstrating the ability to process calls. Sprint CAs must demonstrate Relay skill level in all aspects of call processing prior to graduation from training. CAs must demonstrate their ability to:

  • Sprint CAs must type 60 wpm prior to taking live calls and post training must demonstrate the ability to maintain a minimum typing speed of 60 wpm on an auditory test.

  • Sprint’s diversified culture training program provides the CA with information about understanding TRS users including deaf users and their culture, history and communication needs. Sprint’s diversified culture program incorporates training includes the characteristics and of hard-of-hearing and late deafened users, deaf/blind and speech disabled users.

  • Demonstrate a professional and courteous phone image

  • Process calls using live training terminals in an efficient and knowledgeable manner

  • Role-play scenarios written in varying levels of ASL

Sprint provides an extensive process for hiring CAs who provide Speech to Speech (STS). CA applicants must successfully achieve the following:

  • Six months of employment as a CA

  • Recommendation and/or approval from supervisor or manager

  • Attend and complete STS specialized STS training program including a written evaluation.

  • Proficiency in all areas of Relay call processing including grammar, enunciation and vocabulary

  • Hearing acuity test administered by an audiologist using calibrated equipment to perform a speech recognition test and pure tone test.

STS applicants who meet these qualifications receive additional training specifically on STS. Sprint’s STS training is delivered by individuals with professional experience related to Speech Disabilities and/or consumer experts and is based on adult learning theories.

STS applicants who meet all qualifications for the STS training program receive eight hours of classroom training specifically on STS. Sprint’s STS training program has been developed based on direct experience and consultation with Dr. Bob Segalman obtained during the initial STS trial conducted along with eight years of experience processing STS calls.

The STS training outline includes specific strategies used to facilitate communication without interfering with the STS user’s control over the call including retention of information at the user’s request and verification of what is said to verify accuracy.

The STS training outline is displayed in the following figure:


Sprint Values and Goals

Training Agenda

  • Objectives / Training Outline

  • Introduction and History

  • Video

  • Service Description

  • Characteristics of Customers

  • Stereotypes

  • Speech-Disabilities

  • Attributes of Speech-to-Speech Relay CAs

  • Speech-to-Speech verses Traditional Relay

  • FCC Requirements

  • Speech-to-Speech Variations

  • Assessment

Work Performance Components

  • Basic Call Processing

  • Call set up

  • Customer Database

  • Frequently Dialed Numbers

  • Customer Requests

  • Emergency Call Processing

  • Confidentiality

  • Transparency

  • Personal Conversations

  • Developmental Skill Practice

  • Audio

  • Observation


  • CA training

  • Taking over calls – 15 minute

  • CA work performance

  • Confidentiality and Transparency

  • Discuss call speech patterns

  • Discuss techniques customer uses

  • Have two CAs on one call, if necessary or customer requests.

  • Unacceptable to:

  • Have conversation regarding information discussed on calls

  • Discuss customers in general

All CapTel Operators are tested and competent in typing, grammar, and spelling to ensure skills meet the following FCC Guidelines. CapTel Operator training provides familiarity with hearing, deaf, and speech-disabled cultures.

Personnel supporting CapTel have the requisite experience, expertise, skills, knowledge, training, and education to perform CapTel Services in a professional manner. CapTel Operator Trainees are screened on several skill-sets to be considered for hire. Several tests are administered to evaluate for skills in the following:

  • Spelling

  • Pronunciation

  • Enunciation

  • Reading Ability

  • Vocabulary

  • Error Recognition - CapTel Operators must be able to recognize a mistake in voice-recognition and be able to appropriately correct errors while on a call.

A captioned telephone user does not type during CapTel calls; therefore it is not necessary for the Operator to interpret typewritten ASL.

Please review the Sprint TRS, STS and CapTel Training outlines in Appendix B for more information on CA training requirements.

CA Quality Assurance Programs

Sprint Accessibility Quality Assurance Managers coordinate all training curriculum and policies with the call center Quality Team Leaders and Assistant Trainers to ensure that consistent quality is maintained throughout the TRS network of Relay centers. The Sprint Quality Assurance Managers and the call center training teams meet weekly to receive updates, discuss changes and discuss concerns and how to address them. The training team is located in five Relay Centers across the country. This team along with the support of the Location Managers, Supervisors and CAs has just one goal: to provide excellent service to our customers. In addition, Sprint listens to customer’s feedback and takes proactive steps to implement suggestions and feedback. Sprint Accessibility does not develop training and consumer education programs for the TRS alone. Sprint Accessibility contracts with members of the deaf, hard of hearing, deaf-blind and speech-disabled communities to jointly develop and present training all TRS programs.

§64.604 (a)(1)(iii) CAs must provide a typing speed of a minimum of 60 words per minute. Technological aids may be used to reach the required typing speed. Providers must give oral-to-type tests of CA speed.

Transmission of 60 WPM

Arizona Relay Service contracts with Sprint to provide a comprehensive Quality Assurance program focusing strictly on typing speed and accuracy. As a part of this program, Sprint conducts pre-employment testing and internal testing (quarterly) using a five-minute oral-to-type test that simulates actual working conditions and the Relay environment. Internal testing on typing speeds demonstrated that Sprint’s CAs typed an average of 83.9 wpm, with at least 95% accuracy. In fact almost a third of Sprint’s CAs type over 90 wpm!

§64.604 (a)(1)(iv) TRS providers are responsible for requiring that VRS CAs are qualified interpreters. A “qualified interpreter” is able to interpret effectively, accurately, and impartially, both receptively and expressively, using any necessary specialized vocabulary.

Qualified VRS interpreters

Arizona Relay Service does not contract to provide VRS services, nor is the state responsible for the oversight of VRS. As of January 2012, Sprint no longer provides VRS services.

§64.604 (a)(1) (v) CAs answering and placing a TTY-based TRS or VRS call must stay with the call for a minimum of ten minutes. CAs answering and placing an STS call must stay with the call for a minimum of fifteen minutes.

In-Call Replacement of CAs

Through their contract with Sprint, Arizona Relay Service exceeds all FCC minimum requirements regarding changing CAs during a call. As a matter of practice at Sprint, calls are not taken over unless it is absolutely necessary to do so. Sprint CAs are trained to use on screen clocks to identify the total amount of time since the call arrived at the CA position. After 10 minutes with the TRS (15 minutes with STS) inbound customer, a CA may be relieved if it is appropriate. The only situations in which a CA would transition during a call prior to the FCC minimum standard of ten minutes include:

  • The customer requests a CA of the opposite gender or different CA,

  • End user verbal abuse or obscenity towards the CA

  • Call requires a specialist (STS, Spanish, etc.)

  • CA illness

  • At the request of the customer for any reason, and/or

  • CA becomes aware of a conflict of interest such as identifying callers as friends or family.

In addition, there are situations which may require a CA to transition the call to a different CA, which is only approved after the CA has remained on the call longer than the FCC minimum standard of 10 or 15 minutes (for STS calls). These include:

  • Shift change, and/or

  • CA fatigue normally as a result of a call in progress more than 30 minutes with difficult call content or speed or 60 minutes or more of an average call.

  • If transition of CAs is unavoidable, the change occurs with minimal disruption to either Relay participant including the following:

    • Sprint attempts to honor any requests for a specific gender during call transitions.

    • The second CA silently observes the call long enough to learn the spirit of the call as well as reviewing any customer call handling preferences provided during the call and as a part of the Customer Profile.

§64.604 (a)(1)(vi) TRS providers must make best efforts to accommodate a TRS user's requested CA gender when a call is initiated and, if a transfer occurs, at the time the call is transferred to another CA.

As stated in the section above (§64.604 (a) (1) (v)) Arizona Relay Service honors the requests of all callers when they request a specific CA gender. Relay users may request a specific CA gender through the Customer Profile or a per-call basis directly with the CA. The transfer of the CA to the requested gender occurs as soon as one is available. This requirement has been waived by the FCC for CapTel CAs.

§64.604(a) (1) (vii) TRS shall transmit conversations between TTY and voice callers in real time.

All conversations relayed between voice and TTY callers are transmitted in real-time. Arizona Relay Service uses Sprint’s Phoenix software, which provides tools and enhancements designed to allow conversations to be transmitted in real time, including the following:

  • Automated answer

  • CA-initiated macros (44 macros)

  • Function Keys (85 separate function keys)

  • System-initiated macros

  • On-line help panel

  • Tone of voice pre-approved descriptions (almost 100)

  • Automatic Error Correction Library (615 words)

  • Background descriptions (over 250)

All of these features are available in all languages including English and Spanish.

CapTel is a transparent service. CapTel CAs transmit audio and captioned text conversations from the voice caller to the CapTel user in real time. Since the CapTel user utilizes their own voice to transmit, no transmission occurs from the CA to the voice caller.

A.2 Confidentiality and Conversation Context

§64.604 (2) (i) Except as authorized by section 705 of the Communications Act, 47 U.S.C. 605, CAs are prohibited from disclosing the content of any relayed conversation regardless of content, and with a limited exception for STS CAs, from keeping records of the content of any conversation beyond the duration of a call, even if to do so would be inconsistent with state or local law. STS CAs may retain information from a particular call in order to facilitate the completion of consecutive calls, at the request of the user. The caller may request the STS CA to retain such information, or the CA may ask the caller if he wants the CA to repeat the same information during subsequent calls. The CA may retain the information only for as long as it takes to complete the subsequent calls.

Confidentiality Policies and Procedures

As stated earlier, Arizona Relay Service contracts with Sprint to oversee all TRS CAs, including CapTel CAs for the State of Arizona.

In accordance with the FCC regulations, all information provided for the call set-up, including customer database records remain confidential and cannot be used for any other purpose. Once the inbound party disconnects, CAs lose the ability to view or access any information pertaining to that call. No written or taped information regarding the call is kept once the call is released from the Relay position. Billing information is transferred to billing files after the call has been terminated and is no longer available except for billing purposes.

The only exception to this policy relates to STS calls. Arizona Relay Service STS Relay Agents may retain information from one inbound call for use in a subsequent outbound call, with the caller’s permission. Such information will only be retained for the duration of the inbound call.

Arizona Relay Service’s confidentiality expectations are strictly enforced and employees are expected to comply with this policy during and after their period of employment. Sprint strictly enforces confidentiality policies in the Center, which include the following:

  • Prospective CAs undergo a thorough background investigation and screening.

  • During initial training, CAs are presented with examples of potential breaches of confidentiality.

  • Stress can be a factor in maintaining confidentiality. CAs receive training on healthy detachment.

  • Breach of confidentiality will result in disciplinary action up to and including termination of employment.

  • CAs perform their work in cubicles that are bordered by high sound-absorption acoustic tiles and wear special noise reducing headsets.

  • All Sprint Accessibility Centers have security key access.

  • Visitors are not allowed in Relay work areas.

  • Supervisors are present in the work area to observe behavior.

  • All Relay Center personnel are required to sign and abide by the Sprint Accessibility Center’s Agreement Regarding Confidential Customer Information.

  • All employees attend annual confidentiality meetings wherein the confidentiality agreement is reviewed and re-signed.

Sprint Accessibility Center’s Agreement Regarding Confidential Customer Information requires CAs to:

  • Keep all call information confidential.

  • Not edit or omit any content from the conversation.

  • Not add or interject anything into the content or spirit of the conversation.

  • Assure maximum user control.

  • Continuously improve their skills.

Arizona Relay Service CapTel CAs must comply with the same rules TRS follows regarding confidentiality. The CapTel confidentiality form is similar to TRS. Below is an explanation of confidentiality as it pertains to Captel CAs.

Information obtained during a CapTel call should not be shared with any person except a member of the CapTel management staff who has asked for specific information. This information may be needed to clarify technical, policy, emergency, venting, consumer, or customer service issues. General call information will not be shared unless it is used to clarify, vent, or teach. Information about call content should be discussed in a private area only.
Only information critical to resolving the situation will be disclosed. This may include consumer name, name of business/agency, gender of caller, type of call (voice in, CapTel in), day of week, time of day, city, state, or any other details that could in some way identify a consumer.

A CapTel agent may have problems, complaints or stress from handling the call. The Captionist may ask to speak to a supervisor or other member of management (as long as it was not their call) in a private area.

The success of CapTel depends on quality and complete confidentiality. Since consumers will be less likely to use the service if they feel their personal and professional calls are not kept in the strictest confidence, all Captionists understand and abide by the confidentiality policy. Any Captionist who breaks this policy will be disciplined, up to and including termination. Please see Appendix E for the TRS pledge of confidentiality.

STS Limited Exception of Retention of Information

At the request of a caller, Arizona Relay Service STS CAs will retain information from a call in order to facilitate the completion of consecutive calls. STS CAs may utilize the TRS system designed electronic scratchpad to aid the CA during the processing to a call or subsequent calls. No information is kept after the inbound call is released from the CA position. Please see Appendix E for the TRS Pledge of Confidentiality form.

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