Federal Communications Commission DA 18-324
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Structure and Practices of the Video Relay Service 
Program
Telecommunications Relay Services and Speech-
to-Speech Services for Individuals with Hearing 
and Speech Disabilities
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CG Docket No. 10-51
CG Docket No. 03-123
ORDER
Adopted:  March 30, 2018 Released:  March 30, 2018
By the Chief, Consumer and Governmental Affairs Bureau, and the Managing Director:
I. INTRODUCTION
1. By this Order, the Consumer and Governmental Affairs Bureau (CGB) and the Office of 
the Managing Director (OMD) of the Federal Communications Commission (FCC or Commission) 
extend for 30 days, through April 30, 2018, the deadline for video relay service (VRS) providers to 
submit registration data for their registered users to the telecommunications relay services (TRS) User 
Registration Database (TRS-URD).  
II. BACKGROUND
2. In 2013, to help prevent waste, fraud, and abuse in the VRS program and determine the 
actual number of individuals using VRS, the Commission adopted the 2013 VRS Reform Order,
1
 directing 
the establishment of the TRS-URD and requiring VRS providers to take three steps: (1) submit 
registration data to the TRS-URD for each of their registered VRS users;
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 (2) have each VRS user’s 
identity verified through the TRS-URD;
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 and (3) before completing a VRS call, query the TRS-URD to 
confirm that the party on the video side of the call is a registered VRS user.
4
  
3. Construction of the TRS-URD was completed in 2017, and on December 29, 2017, the 
Commission issued a public notice announcing that the database was ready to accept user registration data 
1
 Structure and Practices of the Video Relay Service Program; Telecommunications Relay Services and Speech-to-
Speech Services for Individuals with Hearing and Speech Disabilities, Report and Order and Further Notice of 
Proposed Rulemaking, 28 FCC Rcd 8618, 8647-56, paras. 62-86 (2013) (2013 VRS Reform Order).
2
 47 CFR § 64.611(a)(4).  The registration data that must be submitted to the TRS-URD consists of the user’s full 
name, full residential address, VRS telephone number, date of birth, last four digits of the user’s Social Security 
number or Tribal identification number, registered location, VRS provider name and dates of service initiation and 
termination, self-certification of VRS eligibility (and the date it was obtained), the date on which the user’s 
identification was verified, and (for existing users only) the date on which the user last placed a point-to-point or 
relay call.  Id.  
3
 Id. § 64.615(a)(5).
4
 Id. § 64.615(a)(1).
Federal Communications Commission DA 18-324
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submitted by VRS providers.
5
  This announcement triggered a 60-day period, within which VRS 
providers must complete the submission of registration data for all currently registered users.  According 
to the TRS rules, “calls from or to existing registered users that have not had their information populated 
in the [TRS-URD] within the 60 days . . . shall not be compensable.”
6
  The TRS-URD Public Notice also 
triggered the second step in the TRS-URD process—verification of VRS user identities.  The TRS rules 
provide that “VRS providers shall not seek compensation for calls placed by individuals that do not pass 
the identification verification check conducted through the [TRS-URD].”
7
  The third step, requiring VRS 
providers to query the database to validate a user’s registered status before each call, otherwise known as 
the “all call query” (ACQ) function of the database, has not yet been activated.  Therefore, VRS providers 
are not required to send such queries, pending further notice from the Commission.
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4. On February 28, 2018, CGB and OMD released an order addressing recently raised 
concerns about implementation of the TRS-URD.  In addition to clarifying the meaning of “verification 
check” for purposes of determining when VRS providers may seek compensation for calls placed by users 
whose verification process has not been completed, CGB and OMD extended, through March 31, 2018, 
the deadline for VRS providers to submit registration data for existing registered users to the TRS-URD.
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III. DISCUSSION
5. To provide additional time to collect user data and consent from those VRS users who 
have not consented to submission of their information to the TRS-URD, we extend for 30 days on our 
own motion the temporary waiver granted to all VRS providers in the TRS-URD Deadline Extension 
Order.
 
6. The Commission may waive any provision of its rules on its own motion for “good cause 
shown.”
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  In particular, a waiver is appropriate where the particular facts make strict compliance 
inconsistent with the public interest.
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  In addition, we may take into account considerations of hardship, 
equity, or more effective implementation of overall policy on an individual basis.
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  Such a waiver is 
appropriate if special circumstances warrant a deviation from the general rule and such deviation will 
serve the public interest.
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7. We find good cause to extend for an additional 30 days, on our own motion, the 
temporary waiver granted to all VRS providers of the rule requiring the submission of registration data for 
5
 Video Relay Service Providers May Begin Submitting Data to the TRS User Registration Database, Public Notice, 
32 FCC Rcd 10467 (OMD CGB 2017) (TRS-URD Public Notice).  
6
 47 CFR § 64.611(a)(4)(ii).  
7
 Id. § 64.615(a)(5)(iii).  
8
 TRS-URD Public Notice, 32 FCC Rcd at 10468-69.
9
 Structure and Practices of the Video Relay Service Program; Telecommunications Relay Services and Speech-to-
Speech Services for Individuals with Hearing and Speech Disabilities, Order, DA 18-196 (OMD CGB Feb. 28, 
2018) (TRS-URD Deadline Extension Order).  The order also waived, for 31 days, section 64.611(a)(4)(iii) of the 
Commission’s rules, which requires the submission of registration information to the TRS-URD “upon initiation of 
service” for new users registered after the 60-day deadline.  Id., para. 16; 47 CFR § 64.611(a)(4)(iii).    
10
 47 CFR § 1.3.
11
 Northeast Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990).
12
 WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969), cert. denied, 409 U.S. 1027 (1972); Northeast 
Cellular, 897 F.2d at 1166.
13
 Northeast Cellular, 897 F.2d at 1166.
Federal Communications Commission DA 18-324
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all existing users within 60 days of the TRS-URD Public Notice.
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  The TRS-URD Administrator has 
provided CGB and OMD regular updates on VRS providers’ submission of registration information to the 
TRS-URD.  Based on data provided by the TRS-URD Administrator, VRS providers have continued to 
make progress on submitting such information.  Despite these efforts, however, reports indicate that there 
remains a number of active VRS users from whom the necessary personal data or consent for the 
submission of such information has not been obtained.  
8. We believe (especially in light of the extended interval between initiation of the TRS-
URD and its activation) that the 60-day period allowed by the Commission’s rules, together with the 31-
day waiver previously granted, has offered ample opportunity for both providers and consumers to 
complete the steps necessary to submit user information to the TRS-URD.  However, we recognize that 
some consumers may remain confused about whether they have to provide personal information and 
consent for such submissions to only one or to all of their providers.
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  Extending the temporary waiver an 
additional 30 days will ensure that there is sufficient time for VRS providers to explain to their 
consumers, and for consumers to understand, the nature of these requirements, thereby giving such 
consumers reasonable opportunity to consent to the submission of their registration data to all of their 
providers.  This will thereby avoid a cutoff of service, which is especially important to ensure that they 
have access in the event of an emergency.  
9. Therefore, we find that a limited further extension of the waiver previously granted is 
warranted and will ensure that TRS is made available to all eligible users.
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  We note that some 
consumers may continue to be unresponsive during this additional period, or may simply choose to 
withhold consent for a given VRS provider to submit information to the TRS-URD.  We believe that the 
further extension granted in this Order provides the maximum additional time that can be reasonably used 
by VRS providers to ensure that currently registered users are aware of the need for data submission and 
to obtain such data along with the user’s consent.  For the reasons noted in the initial waiver order and 
stated above, we believe that granting this additional extension of the data submission deadline is in the 
public interest.
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10. Accordingly, pursuant to sections 0.11, 0.141, 0.231, 0.361, and 1.3 of the Commission’s 
rules, 47 CFR §§ 0.11, 0.141, 0.231, 0.361, 1.3, and paragraphs 123-24 of the 2013 VRS Reform Order, 
28 FCC Rcd at 8666, para. 123-24, IT IS ORDERED THAT the limited waiver of section 64.611(a)(4)(ii) 
and (iii) of the Commission’s rules, 47 CFR § 64.611(a)(4)(ii), (iii), is extended for a period of 30 days, 
or through April 30, 2018.
11. And it is FURTHER ORDERED that this Order is effective upon release. 
Patrick Webre
Chief
Consumer and Governmental Affairs Bureau
Mark Stephens
Managing Director
14
 TRS-URD Deadline Extension Order at 6, para. 16; 47 CFR § 64.611(a)(4)(ii).  This waiver also extends for an 
additional 30 days the requirement for the submission of registration information to the TRS-URD “upon initiation 
of service” for users registered after the 60-day deadline.  TRS-URD Deadline Extension Order at 6, para. 16; 47 
CFR § 64.611(a)(4)(iii).  
15
 TRS-URD Deadline Extension Order at 5, para. 14.
16
 See 47 U.S.C. § 225(b)(1).
17
 See TRS-URD Deadline Extension Order at 6, para. 16.