Federal Communications Commission
	Washington, DC 20554
	March 9, 2026


DA 26-228

SMALL ENTITY COMPLIANCE GUIDE


Access to Video Conferencing

FCC 24-95
CG Docket No. 23-161
Released September 27, 2024


In accordance with Section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996, this Small Entity Compliance Guide (Guide) is intended to help small entities—small businesses, small organizations (non-profits), and small governmental jurisdictions—comply with the rules adopted in the above-referenced Federal Communications Commission (FCC or Commission) rulemaking docket.  This Guide is not intended to replace or supersede these rules, but to facilitate compliance with the rules.  Although we have attempted to cover all parts of the rules that might be especially important to small entities, the coverage may not be exhaustive.  This Guide cannot anticipate all situations in which the rules apply.  Furthermore, the Commission retains the discretion to adopt case-by-case approaches, where appropriate, that may differ from this Guide.  Any decision regarding a particular small entity will be based on the statute and any relevant rules. 
In any civil or administrative action against a small entity for a violation of rules, the content of the Guide may be considered as evidence of the reasonableness or appropriateness of proposed fines, penalties or damages.  Interested parties are free to file comments regarding this Guide in the above referenced docket and the appropriateness of its application to a particular situation.  The Commission will then consider whether the recommendations or interpretations in the Guide are appropriate in that situation.  The Commission may decide to revise this Guide without public notice to reflect changes in its approach to implementing a rule, or it may clarify or update the text of the Guide.  Please direct comments and recommendations, or requests for further assistance, to the FCC’s Consumer Center:

1-888-CALL-FCC (1-888-225-5322)
Videophone: 1-844-4-FCC-ASL (1-844-432-2275)
Fax: 1-866-418-0232



TABLE OF CONTENTS

I.	OBJECTIVES OF THE PROCEEDING	1
II.	COMPLIANCE REQUIREMENTS	3
A.	AMENDMENTS TO PART 14 PERFORMANCE OBJECTIVES	3
B.	AMENDMENTS TO PART 64 TRS RULES	5
C.	AMENDMENT TO TRS RULE FOR CALLS REQUIRING MULTIPLE CAS	9
III.	RECORDKEEPING AND REPORTING REQUIREMENTS	9
IV.	IMPLEMENTATION DATE	10
V.	INTERNET LINKS	10




I. OBJECTIVES OF THE PROCEEDING 
In the 2024 Video Conferencing Order, Access to Video Conferencing; 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; Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities; Petition of Sorenson Communications, LLC for Limited Waiver of the Privacy Screen Rule, CG Docket Nos. 23-161, 10-213, and 03-123, Second Report and Order and Order and Further Notice of Proposed Rulemaking, FCC 24-95, 39 FCC Rcd 11068 (Sept. 27, 2024) (2024 Video Conferencing Order or Multiple CA Order).
 the Commission takes steps to ensure that people with disabilities are able to access and use video conferencing.  As the Commission explains, video conferencing is a modern communications tool that is critical in connecting for work, education, health, and other fundamental life activities.  To advance access to video conferencing, the Commission first discusses how existing accessibility performance objectives in Part 14 of the Commission’s rules apply to interoperable video conferencing service (IVCS), a form of Advanced Communication Service (ACS).  Second, the Commission amends the Part 14 performance objectives to address specific features necessary to ensure access to video conferencing for individuals with disabilities.  Third, the Commission modifies its Part 64 rules for telecommunications relay services (TRS) to address how the Interstate TRS Fund will support the use of Video Relay Service (VRS) and other forms of TRS in video conferences.  Finally, the Commission authorizes TRS Fund support for multiple TRS communications assistants (CAs), when warranted, on a single call.
Advanced Communications Services.  Providers of ACS and manufacturers of equipment used for ACS must make such services and equipment accessible to and usable by people with disabilities, if achievable. The term “achievable” for ACS, including IVCS, means “with reasonable effort or expense, as determined by the Commission,” considering (1) the nature and cost of the steps needed to meet the requirements with respect to the specific equipment or service in question; (2) the technical and economic impact on the operation of the manufacturer or provider and on the operation of the specific equipment or service in question; (3) the type of operations of the manufacturer or provider; and (4) the extent to which the service provider or manufacturer in question offers accessible services or equipment containing varying degrees of functionality and features, and offered at differing price points.  47 CFR § 14.10(b).
  Service providers and manufacturers may comply either by building accessibility features into their services and equipment used for ACS or by choosing to use third-party applications, peripheral devices, software, hardware, or customer premises equipment (CPE) that are available to individuals with disabilities at nominal cost.  If accessibility is not achievable through either of these means, then manufacturers and service providers must make their ACS products and services compatible with existing peripheral devices or specialized CPE commonly used by people with disabilities to achieve access, subject to the achievability criterion.  The Commission adopted performance objectives to ensure the accessibility, usability, and compatibility of ACS and the equipment used for such services.
Interoperable Video Conferencing Service.  IVCS is defined as “a service that provides real-time video communications, including audio, to enable users to share information of the user’s choosing.”  In 2023, the Commission concluded that its existing Part 14 ACS accessibility rules apply to all services and equipment that meet that definition.  The Commission allowed IVCS service providers and manufacturers one year, until September 3, 2024, to come into compliance with the existing Part 14 accessibility requirements.  See Consumer and Governmental Affairs Bureau Announces Compliance and Comment Dates for the Interoperable Video Conferencing Services Proceeding, CG Docket Nos. 03-123, 10-213, and 23-161, Public Notice, 38 FCC Rcd 6778 (CGB 2023).
  
Existing Part 14 Accessibility Requirements.  Implementing the performance objectives of the current Part 14 rules will assist IVCS providers in ensuring accessibility.  For example, section 14.21(b)(1) states that, for services, equipment, and software to be accessible to people who are blind, “input,” “control” and mechanical functions shall be “provided in at least one mode that does not require user vision.”  Section 14.21(b)(2) states that “all information necessary to operate and use the product, including but not limited to, text, static or dynamic images, icons, labels . . .” shall be available “through at least one mode in auditory form.”  Meeting these performance objectives (e.g., by providing, among other things, voice-activated control settings and screen-reader functionality or compatibility) would address concerns that chat functions and control settings on IVCS platforms are often visual only, and thus inaccessible to blind and low-vision users.  Additionally, section 14.21(b)(1)-(2) states that in at least one mode, ACS shall permit operation by, and provide visual information to, people with “visual acuity between 20/70 and 20/200, without relying on audio.”  Meeting this objective through, e.g., magnification, high-contrast, and color inversion options, as well as compatibility with third-party refreshable braille displays, would be important steps toward making IVCS platforms accessible to low-vision and deafblind users.  
Similarly, compliance with the existing Part 14 rules could help ensure accessibility for people with cognitive and mobility disabilities.  Section 14.21(b)(1) specifies that, to be accessible, ACS and equipment used for ACS must have modes that are operable with limited manual dexterity; with limited reach and strength; without requiring body contact or close body proximity; without time-dependent controls; and “at least one mode that minimizes the cognitive, memory, language, and learning skills required of the user.”  Steps that providers could take to implement these requirements include providing voice- or gesture-based controls, one-button shortcuts, an “easy-to-use” setting, or  other features.
IVCS-Specific Accessibility Requirements.  In a number of areas, such as captioning, the Commission finds that more specific guidance is needed in the IVCS context.  Further, some accessibility concerns are not directly addressed at all by the current Part 14 rules.  For example, none of the existing performance objectives requires IVCS platforms to facilitate the use of sign language and sign language interpretation—a key omission for a medium inherently suited to sign language communication.  Therefore, the Commission amends Part 14 of its rules to define more specifically the performance objectives that IVCS providers must meet to achieve accessibility and promote more consistency in their implementation, thereby enabling people with disabilities to participate in video conferences whenever accessibility is achievable.
The performance objectives adopted for specific application to IVCS also apply to equipment and software used for IVCS.  Manufacturers of equipment used for IVCS must ensure that such equipment, as well as software components of such equipment, meet these new and modified objectives, unless doing so is not achievable.
 Compliance with each of the amended performance objectives is conditioned on the objective being “achievable,” which means it can be achieved “with reasonable effort or expense.”  Therefore, the rules themselves include a safeguard to ensure that the burden and cost of compliance will not be unreasonable, considering, among other factors, the technical and economic impact on the company’s operation and the extent to which accessible services or equipment are already being offered by the company.
Telecommunications Relay Services.  The structure of the Commission’s TRS program reflects the fact that, historically, most people have used wireline or wireless telephone networks to communicate remotely by voice.  Thus, North American Numbering Plan (NANP) telephone numbers are used to route calls between TRS users and the people they are calling, and the provision of TRS, to date, has typically been configured to fit within the structure of a traditional telephone call, with a “calling party” and “called party” and originating and terminating NANP numbers.  As a result, even though a VRS user’s connection with a CA is established via an Internet video link, the Commission has been able to rely on originating and terminating telephone numbers as part of the information required to verify the user’s eligibility and the minutes of service for which TRS providers are compensated.
Video conferencing, however, is generally accessed through the Internet, without necessarily involving any telephone numbers.  While a consumer can obtain audio-only access to some video conferences by dialing a telephone number, full video access is usually achieved directly through the Internet, without the use of originating or terminating telephone numbers.  Accordingly, in the 2024 Video Conferencing Order, the Commission updates the rules governing TRS to apply in the circumstances presented by video conferencing.  Notably, the Commission does not require IVCS and TRS providers to offer integrated TRS on video conferences, but allows them to do so through collaborative efforts and in accordance with the rules for integrated TRS on video conferences.
Commission Objectives.  In amending its rules, the Commission furthers its long-standing goal of ensuring that the country’s communications networks are accessible to all individuals, including those with disabilities.  Video conferencing has become a ubiquitous and critical part of daily life, but video conferencing accessibility remains a work in progress.  Given the centrality of video conferencing in modern American society, the Commission determines that video conferences should be made accessible as soon as it is achievable to do so.  
II. COMPLIANCE REQUIREMENTS
A. Amendments to Part 14 Performance Objectives
In the 2024 Video Conferencing Order, the Commission amends several performance objectives in Part 14 of its rules to specify the obligations of video conferencing services in ensuring the accessibility of the service to participants with disabilities.
Availability of Captions.  Existing section 14.21(b)(2)(iv) requires ACS providers to provide auditory information through at least one mode in visual form, and, where appropriate, in tactile form.  The Commission amends this rule by adding language to require video conferencing services to: 
· Provide at least one mode with captions that accurately and synchronously display the spoken communications in a video conference.  (47 CFR § 14.21(b)(2)(iv))
The Commission adds definitions of “accurately” and “synchronously” to the rule:
· Accurately means that captioning matches the spoken words of a conversation, in the order spoken, verbatim, without summarizing or paraphrasing, sufficiently to enable a user to understand what is being said.  (47 CFR § 14.21(b)(2)(iv)(A))
· Synchronously means that, to the greatest extent possible, the captions begin to appear at the time that the corresponding speech or sounds begin and end approximately when the speech or sounds end, are delivered fast enough to keep up with the speed of those words and sounds, and remain displayed long enough to be read by the user.  (47 CFR § 14.21(b)(2)(iv)(B))
The Commission also amends this rule by adding language to require that video conferencing services must:
· Enable users to connect with third-party captioning services so that captions provided by such services appear on the requesting user’s video conference screen.  (47 CFR § 14.21(b)(2)(iv))
The Commission does not specify how the video conferencing service must enable such connections to meet this performance objective; the means for connecting to third-party captioning services can be determined by the IVCS provider.  The requirement to enable third-party captioning also does not require an IVCS provider to ensure that third-party captioning is available to users at no or nominal cost—unless the IVCS provider is relying on a third party to fulfill its primary captioning obligation specified by the rule.  Similarly, if an IVCS provider is not relying on a third party to fulfill its primary captioning obligation, the IVCS provider is not responsible for ensuring that captions provided by a third party are accurate and synchronous, except to the extent of its existing obligation to not impair or impede accessibility in section 14.20(a)(4)-(5) (47 CFR § 14.20(a)(4)-(5)).
Further, consistent with the technology-neutral, outcome-oriented nature of performance objectives, the IVCS captioning rule does not differentiate between captioning generated with human involvement and captions created entirely with automatic speech recognition technology.
Sign Language Interpreting.  The Commission amends its Part 14 rules to require video conferencing services to enable the use of sign language interpretation.  Specifically, the new rule requires that:
· Interoperable video conferencing services and covered equipment and software used with such services shall enable the use of sign language interpretation provided by third parties, including the transmission of user requests for sign language interpretation to providers of video relay service and other entities and the provision of sufficient video quality to support sign language communication.  (47 CFR § 14.21(b)(4)(i))
As the Commission explains, this rule does not require video conferencing services to provide their own sign language interpretation.  Rather, the rule requires video conferencing services to provide a means for participants in the video conference to enable the use of sign language interpretation provided by third parties, such as VRS.  As with other performance objectives, the means for connecting to third-party sign language interpreting services must be determined by the IVCS provider.
	Also note that this performance objective does not differentiate regarding the type of sign language service that may be offered by a third party.  Most sign language users who participate in video conferences will be using American Sign Language (ASL).  However, this performance objective is intended to apply broadly to all forms of visual language commonly in use by people with disabilities. 
User Interface Controls.  The Commission also amends section 14.21(b) to require video conferencing services to provide user interface controls that allow participants to ensure accessibility.  Specifically, the amended rule requires video conferencing service providers to: 
· Provide user interface control functions that permit users to activate and adjust the display of captions, speakers, and signers and other features for which user control is necessary for accessibility.  (47 CFR § 14.21(b)(2)(4)(ii))
The rule adds further details explaining these requirements: 
· “Adjust the display of captions” means that a video conference participant can alter the size, font, and on-screen location of captions and adjust the color and opacity of both the captions and the caption background (47 CFR § 14.21(b)(2)(4)(ii)(A)), and, 
· “Adjust the display of speakers and signers” means that video conference participants can minimize or hide extraneous windows, expand the windows of their choice, or relocate particular windows; and edit their own display names before or after joining a video conference.  (47 CFR § 14.21(b)(4)(ii)(B))
In adopting these requirements for user controls, the Commission explains that accessibility is not a static condition.  To ensure that a video conferencing service is accessible across the wide range of devices that may be used to access it, and by users with varying disability-related needs, individual users must themselves be able to manipulate accessibility-related functions.  The amended performance objective addresses this problem by providing that video conference participants be able to control the activation and settings of accessibility-related features.  The text of the amended rule reflects that user control is especially important in two areas: captioning and the visual display of speakers and signers.
The Commission also points out that additional accessibility challenges arise as the number of participants in a video conference grows.  To ensure that critical visual information is accessible, video conference participants must be able to reconfigure the layout and visibility of video windows appearing on the users’ own device.  In addition, video conference participants must be able to edit their own display names.  This allows participants (including interpreters and third-party accommodation services) to quickly differentiate themselves from other call participants, helping sign language users and interpreters find each other more easily, especially in conference calls with many participants.  (47 CFR § 14.21(b)(4)(ii)(B))
B. Amendments to Part 64 TRS Rules
In the 2024 Video Conferencing Order, the Commission amends its Part 64 rules related to TRS to specify the requirements for use of TRS on video conferencing  services, including the integrated participation of CAs.  
1. New Part 64 Definitions
The Commission adds four definitions to Part 64 for terms relevant to the use of TRS on video conferences.  These definitions are:
· Integrated VRS. The provision of VRS in a video conference whereby the CA is included as a participant in the video conference and communication between the CA and the participants takes place on the video conferencing platform rather than through a separate connection.  (47 CFR § 64.601(a)(23))
· Interoperable video conferencing service (IVCS). Has the meaning given in Part 14 of this chapter.  (That definition is: “a service that provides real-time video communications, including audio, to enable users to share information of the user’s choosing.”)  (47 CFR §  64.601(a)(28)) 
· Multi-party video conference. A video conference call with three or more participants, excluding VRS CAs and any other participant providing an accommodation for a participant.  (47 CFR § 64.601(a)(31))
· Video conference. A session of IVCS involving two-way real-time communication between two or more IVCS users.  (47 CFR § 64.601(a)(56))
2. Amendments to Part 64 Rules Relating to VRS on Video Conferences
Providing VRS on IVCS.  The Commission amends the Part 64 rules to affirm that VRS providers may provide integrated service to participants in video conferences without a telephone call. The Commission also allows, but does not require, Internet Protocol Captioned Telephone Service (IP CTS) providers to seek compensation for providing video conference captioning on an integrated basis, in compliance with the current TRS rules.  IP CTS providers that seek compensation for providing captioning in video conferences on an integrated basis may use the same billing and CDR guidelines discussed for VRS.

· Provision of integrated VRS in video conferences. A VRS provider may provide integrated VRS in a video conference upon request by a registered VRS user (or by a person authorized by a registered enterprise VRS user).  (47 CFR § 64.604(e)(1))
The integrated provision of VRS in a video conference means that the CA is included as a participant in the video conference, and communication between the CA and the participants takes place on the video conferencing platform rather than through a separate connection.  
With respect to the VRS user and VRS CA entering a video conference through the participant access procedure, a VRS provider providing integrated VRS in a video conference must:
· Collect from the party requesting service sufficient information to confirm the requesting party’s registration for VRS.  (47 CFR § 64.604(e)(2)(i))
· Require CAs, when joining a video conference, to self-identify as a CA and provide the name of the VRS provider (e.g., by editing their display name).  (47 CFR § 64.604(e)(2)(ii))
Eligibility of VRS User.  A VRS provider must validate the eligibility of the requesting VRS user prior to connection of the VRS CA to the video conference.  Specifically, the user validation rule states:
· Validation shall occur during the call setup process, prior to the placement of the call, except that validation of the provision of integrated VRS in a video conference shall occur prior to the connection of a VRS CA to the video conference.  (47 CFR § 64.615(a)(1)(i))
CA-Related Requirements.  The Commission does not prohibit multiple VRS providers from responding to service requests from different users for the same video conference.  However, in a video conference with integrated VRS, it is possible for all participants to be served by one CA from the same VRS provider.  Therefore, the Commission requires that, when a VRS provider receives two requests for VRS for a single video conference, the VRS provider shall only bill the TRS Fund for VRS provided to the first requesting user.  If a CA joins a video conferencing call and detects that a VRS CA from the same VRS provider is already present on the call, the later-in-time CA should terminate participation in the call, and no separate call data record shall be submitted to seek compensation for that CA’s presence on the call.  To facilitate implementation of this practice, the Commission requires that VRS CAs identify themselves as such in a video conference, including the name of their VRS employer.  CAs may identify themselves for this purpose by indicating in their display name that they are an interpreter and identifying the VRS provider with which they are affiliated.
With respect to team interpreting (i.e., two interpreters from the same VRS provider working as a team), the Commission explains that VRS providers are not prohibited from assigning an additional CA to a particular VRS call or video conference, if deemed necessary.  However, at this time, no additional compensation is paid for the second CA from the same VRS provider.
Multiple ASL Users on the Same IVCS Call.  The Commission explains that, in the ordinary case, if the VRS user who requested service leaves a video conference, or is disconnected, before the session ends, then the billable period has ended and the CA should leave the video conference.  As an exception, the Commission allows the continuation of TRS Fund-supported service to a video conference after the initiating user drops off, provided that a registered VRS user who remains in the video conference has made a request for service.  (In addition, at least one non-signing user must remain on the call.)  In implementing this exception, VRS providers may choose to include in their software for managing service to video conferences the capability to hold in reserve any extra service requests from video conference participants that were not fulfilled when made because another participant already requested VRS for the conference.  By holding an additional request in reserve, it can be automatically fulfilled if the first-in-line requester leaves the conference early.  
Further, if there are no requests held in reserve, and the CA is aware that other sign language users may remain in the video conference, the CA may delay exiting the conference for up to five minutes of additional compensable time, to allow a remaining registered user to request service.  (47 CFR § 64.604(e)(4)(iv))  Upon verification of the new registered user, the CA (or a replacement) may continue service to the video conference beyond the five-minute grace period.  The Commission requires that the second registered VRS user’s telephone number be included in the call data submitted for compensation.  The TRS Fund administrator will provide appropriate guidance to VRS providers on how an extension of service, in response to a remaining participant’s request, should be reflected in the call data records submitted by a provider in support of compensation requests. 
Replacement CAs.  The Commission does not modify the current rule requiring that VRS CAs stay on a call for a minimum of 10 minutes before being replaced by another CA.  (47 CFR § 64.604(a)(1)(v)). 
Call Data Records (CDRs).  The Commission amends the rules governing call data records (CDRs) to explain how providers must submit data regarding minutes of use on video conferences for compensation from the TRS Fund.  As an initial matter, the Commission continues to require that CDRs be compiled through an automatic record keeping system, but provides a minor modification for call termination in video conferences.  Specifically, the amended rule requires providers to:
· Submit such data electronically, in a standardized format. For purposes of this subparagraph, an automated record keeping system is a system that captures data in a computerized and electronic format that does not allow human intervention during the call session for either conversation or session time; provided that, this subparagraph does not prohibit the submission of a CDR in which the end of conversation or session time is automatically determined by a CA’s exit from a video conference prior to its termination, in accordance with the Commission’s applicable rules.  (47 CFR § 64.604(c)(5)(iii)(D)(4))
In submitting CDRs for compensation, VRS providers must:
· Treat each video conference as a single call for compensation purposes, except as specifically authorized by the Commission.  (47 CFR § 64.604(e)(2)(iii))
Rather than the existing requirements to submit originating and terminating telephone numbers or IP addresses for a typical TRS call in section 64.604(c)(5)(iii)(D)(2)(v)-(vi), the Commission requires that:
· A VRS provider’s call data shall identify each video conference in which integrated VRS is provided.  For such video conferences, in lieu of the information on originating and terminating telephone numbers or IP addresses, a VRS provider may submit information, as specified in instructions issued by the administrator, that identifies the VRS user requesting service and the video conference session in which service was provided.  (47 CFR § 64.604(c)(5)(iii)(D)(9))
Recording Minutes of Use.  The Commission amends the Part 64 rules to specify how compensation can be provided for the minutes of use for CAs on video conference calls.  Generally, for purposes of cost recovery from the TRS Fund, the minutes of use are defined as “the minutes of use for completed interstate or Internet-based TRS calls placed through the TRS center beginning after call set-up and concluding after the last message call unit.”  (47 CFR § 64.604(c)(5)(iii)(E)(2)).  The exception to this rule is specified in section 64.604(e), in which the Commission adopts rules for the start and end times of VRS on video conference calls: 
· Start time.  For the purpose of TRS Fund compensation for the provision of integrated VRS in a video conference, a VRS provider’s TRS minutes of use begin when a CA enters the video conference, provided that the CA identifies the requesting VRS user within five minutes of entering the video conference.  If, within that time, the CA cannot identify the requesting VRS user, or it is evident that VRS is not needed, then the call must be identified as non-compensable.  (47 CFR § 64.604(e)(3))
Note that the start time for minutes of use on a video conference call requires the CA to identify the requesting VRS user within five minutes of entering the call, and that, if the CA cannot do so, the call is non-compensable.  A VRS provider must provide guidance to CAs on making this determination.  Note further that the start time does not include any time that the CA may spend in a “waiting room” prior to joining the video conference itself.
· End time.  For the purpose of TRS Fund compensation for the provision of integrated VRS in a video conference, a VRS provider’s TRS minutes of use end when the earliest of the following events occurs: 
(i) The CA disconnects from the video conference;
(ii) All non-signing participants disconnect from the video conference; 
(iii) All signing participants disconnect from the video conference; or 
(iv) The registered VRS user who initially requested service disconnects from the video conference and five minutes elapse without a further request for service by a registered VRS user participant.  (47 CFR § 64.604(e)(4))
Note that the “end time” rule may require a VRS CA to make a determination of when the video conference call has ended, and the CA’s exit is recorded as the end of billable minutes.
Privacy Screen Rule.  The Commission amends the VRS privacy screen rule to allow VRS users and CAs to turn off their videos when participating in a video conference.  The first part of the rule remains unchanged for a typical VRS call, while the second part of the rule specifies actions of CAs on video conference calls.  The amended rule states:
· Visual privacy screens/idle calls. Except as provided in this paragraph, a VRS CA shall not enable a visual privacy screen or similar feature during a VRS call and must disconnect a VRS call if the caller or the called party enables a privacy screen or similar feature for more than five minutes or is otherwise unresponsive or unengaged for more than five minutes, unless the call is a 9-1-1 emergency call or the caller or called party is legitimately placed on hold and is present and waiting for active communications to commence. Prior to disconnecting the call, the CA must announce to both parties the intent to terminate the call and may reverse the decision to disconnect if one of the parties indicates continued engagement with the call.
 	
· A VRS CA providing integrated VRS in a multi-party video conference: 
(A) may temporarily turn off the CA’s video camera when engaged in team interpreting, if the other CA is actively providing ASL interpretation; 
(B) may stay connected to the video conference if the VRS user who requested service has turned off the user’s camera, as long as that user stays connected to the video conference; and, 
(C) if five minutes elapse in which no party is responsive or engaged in conversation, shall announce that VRS will be terminated and the CA shall disconnect from the video conference.  (47 CFR § 64.604(d)(5))
The rule allowing VRS CAs and users to turn off their cameras only applies in a “multi-party” video conference, which is defined to include at least three participants, not counting the VRS CAs and any other participant providing an accommodation for a participant. 
Annual Reports.  The Commission amends the annual report rule for VRS providers to address the determination to be made by CAs on entering a video conference:
· If a VRS provider provides integrated VRS in video conferences, its annual report shall provide a detailed explanation of the instructions and training provided to CAs on implementation of § 64.604(e), including guidance on how to make the determinations required by § 64.604(e)(3).  (47 CFR § 64.606(g)(6))
The annual report rule requires VRS providers to report on the instruction and training provided to CAs in determining when minutes of use begin for a CA entering the video conference, specifically, “provided that the CA identifies the requesting VRS user within five minutes of entering the video conference.”  (47 CFR § 64.604(e)(3)).
3. Amendments to Part 64 Rules Related to TRS
Confidentiality.  The Commission amends the confidentiality rule in section 64.604(a)(2)(i) to account for the types of information and materials that a CA may encounter on a video conference.  The Commission also amends this rule to clarify that the confidentiality requirements apply to TRS providers as well as TRS CAs.  Specifically, the rule as amended reads:
· Except as authorized by section 705 of the Communications Act, 47 U.S.C 605, TRS providers and CAs are prohibited from disclosing the content of any relayed conversation (and any non-relayed content communicated in a video conference) regardless of content, and with a limited exception for STS CAs, from keeping records of the content of any conversation (and any non-relayed content communicated in a video conference) 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.  (47 CFR § 64.604(a)(2)(i))
Prohibition on Exclusivity Agreements.  The Commission adopts a rule prohibiting exclusivity agreements between IVCS providers and TRS providers.  Specifically:
· Exclusivity Agreements. A TRS provider may not enter into an agreement with an IVCS provider if such agreement would give the TRS provider exclusive access among TRS providers to the IVCS provider’s facilities or such agreement would give the IVCS provider exclusive access among IVCS providers to the TRS provider’s service via a video connection.  (47 CFR § 64.604(c)(15))
With respect to de facto exclusivity agreements, the Commission stresses that sections 14.20(a)(4)-(5) (47 CFR § 14.20(a)(4)-(5)) prohibit IVCS providers from installing network features, functions, or capabilities that impede accessibility or usability.  Although the application of this rule to network features, functions, and capabilities is determined on a case-by-case basis, the Commission emphasizes that software applications that are installed, e.g., to enable IVCS users to request a VRS CA, must not impede the ability of users to request service from their preferred provider.
	No Advance Scheduling of Video Conference Calls.  Note that the Commission does not modify the current rule that TRS providers must decline requests to reserve a TRS CA in advance of a scheduled video conference or call.  Accordingly, the existing “first-come, first-served” and speed of answer rules remain in effect.  (47 CFR § 64.604(b)(2)).
C. Amendment to TRS Rule for Calls Requiring Multiple CAs
The Commission amends the Part 64 rules to define when the use of more than one CA on a single call may be compensable from the TRS Fund.  The amended rule states:
· TRS calls requiring the use of multiple CAs.  TRS Fund compensation may be paid for more than one CA (or automated equivalent of a CA, when authorized) to handle the following types of calls: 
o (i) VCO-to-VCO calls between multiple captioned telephone relay service users, multiple IP CTS users, or captioned telephone relay service users and IP CTS users; and 
o (ii) Calls between users of different types of relay services for which more than one CA is warranted.  (47 CFR § 64.604(c)(14))
The Commission explains that this amendment ensures that, when warranted, TRS Fund compensation is available for calls between users of different types of relay services, for example, VRS and IP Relay, where a VRS user signs to a CA who voices to another CA who communicates in text to the IP Relay user.
III. RECORDKEEPING AND REPORTING REQUIREMENTS
	The 2024 Video Conferencing Order contains one new information collection requirement for VRS providers’ annual reports in section 64.606(g)(6):
·  If a VRS provider provides integrated VRS in video conferences, its annual report shall provide a detailed explanation of the instructions and training provided to CAs on implementation of § 64.604(e), including guidance on how to make the determinations required by § 64.604(e)(3).
This rule requires VRS providers to report on the instruction and training provided to CAs in determining when minutes of use begin for a CA entering the video conference, specifically, “provided that the CA identifies the requesting VRS user within five minutes of entering the video conference.”  47 CFR § 64.604(e)(3).
IV. IMPLEMENTATION DATE
The amendments to the Part 14 rules in the 2024 Video Conferencing Order shall become effective two years and 30 days after publication of the text or summary thereof in the Federal Register, January 12, 2027.
The amendments to the Part 64 rules in the 2024 Video Conferencing Order shall become effective 30 days after publication of the text or summary thereof in the Federal Register, January 13, 2025.
The amendment to section 64.606(g)(6) as adopted in the 2024 Video Conferencing Order requires approval by the Office of Management and Budget (OMB) under the Paperwork Reduction Act. This rule shall become effective after the Commission publishes a notice in the Federal Register announcing OMB approval and the relevant effective date.
V. INTERNET LINKS
A copy of the 2024 Video Conferencing Order is available at: https://docs.fcc.gov/public/attachments/FCC-24-95A1.pdf 

A copy of the Federal Register Summary of the 2024 Video Conferencing Order is available at: https://www.federalregister.gov/documents/2024/12/13/2024-27479/access-to-video-conferencing

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