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Internet-based TRS Provider Certification

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Released: January 4, 2012


Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.


Washington, D.C. 20554

TTY: 1-888-835-5322

DA 12-3

Released: January 4, 2012






By the Chief, Consumer and Governmental Affairs Bureau:
On November 23, 2011, Snap Telecommunications, Inc. (Snap) filed an application1 for
Commission recertification2 as a provider of video relay service (VRS) that is eligible for compensation
from the Interstate TRS Fund (Fund).3 For the reasons discussed below, the Consumer and Governmental

1 Snap Telecommunications, Inc., Application of Snap Telecommunications, Inc. for Certification Renewal as an
Internet-Based Video Relay Service Provider,
CG Docket No. 10-51 (filed Nov. 23, 2011), amended on December
22, 2011 (Snap Recertification Application). Snap’s November 23, 2011 filing replaced its February 7, 2011
Application for the Renewal of Snap Telecommunications, Inc.’s Certification as a VRS Provider, which it had filed
in CG Docket No. 03-123. See 47 C.F.R. § 64.606; Structure and Practices of the Video Relay Service Program,
CG Docket No. 10-51, Second Report and Order and Order, 26 FCC Rcd 10898 (2011) (iTRS Certification Order).
2 The Commission initially granted Snap certification for the provision of VRS on May 8, 2006, for five years, until
May 8, 2011. See Notice of Certification of Snap Telecommunications, Inc. as a Provider of Video Relay Service
(VRS) Eligible for Compensation from the Interstate Telecommunications Relay Service (TRS) Fund,
CG Docket
No. 03-123, Public Notice, FCC 06-67 (rel. May 8, 2006); Erratum (rel. May 9, 2006). The Consumer and
Governmental Affairs Bureau twice extended this certification period for Snap and other affected providers, in order
to maintain the status quo while the Commission considered reform of the Internet-based certification process. See
Consumer and Governmental Affairs Bureau Announces Extension of Expiring Certifications for Providers of
Internet-Based Telecommunications Relay Services,
CG Docket Nos. 03-123 & 10-51, Public Notice, 26 FCC Rcd
6737 (2011) (extending expiring certifications to November 4, 2011); Consumer and Governmental Affairs Bureau
Extends Expiring Certifications for Certain Providers of Video Relay Service and IP Relay Service
, CG Docket Nos.
03-123 & 10-51, Public Notice, 26 FCC Rcd 15157 (2011) (extending expiring certifications to January 4, 2012).
3 The Communications Act of 1934, as amended, defines telecommunications relay services (TRS) as:
. . . telephone transmission services that provide the ability for an individual who is deaf, hard of
hearing, deaf-blind, or who has a speech disability to engage in communication by wire or radio
with one or more individuals, in a manner that is functionally equivalent to the ability of a hearing
individual who does not have a speech disability to communicate using voice communication
services by wire or radio.
47 U.S.C. § 225(a)(3) (as amended by the Twenty-First Century Communications and Video Accessibility Act of
2010 (CVAA), Pub. L. No. 111-260, § 103(b), 124 Stat. 2751, 2755 (2010); Pub. L. No. 111-265 (technical
amendments to CVAA)). VRS is a form of Internet-based TRS (iTRS) that uses a broadband Internet connection
between the VRS user and the communications assistant (CA) to enable a person using American Sign Language to
communicate over video with another party through a CA. During a VRS call, the CA relays the communications

Affairs Bureau (Bureau) hereby grants the Snap Recertification Application on a conditional basis,
pending inspection of Snap’s facilities and confirmation of Snap’s compliance with all applicable rules
and orders, as well as our determination that Snap is qualified to receive compensation from the Fund and
that grant of full certification would be consistent with the objective of preventing waste, fraud, and abuse
to the Fund, as embodied in our VRS rules and orders.

In the iTRS Certification Order released on July 28, 2011, the Commission amended its
requirements and processes for certifying iTRS providers as eligible for compensation from the Fund, to
ensure that iTRS providers receiving certification are qualified to provide iTRS in compliance with the
Commission’s rules, and to eliminate waste, fraud, and abuse through improved oversight of such
providers.4 These new rules require that all iTRS providers obtain certification from the Commission to
be eligible to receive compensation from the Fund.5 They further require that all VRS applicants for
certification lease, license or own, as well as operate, essential facilities associated with iTRS call centers
and employ their own CAs to staff those centers on the date of their application for certification.6 Each
iTRS applicant for certification is also required to submit specific types of documentary evidence that
demonstrate its compliance with Commission rules, including those adopted in the VRS Practices R&O.7
On October 17, 2011, the Commission released the iTRS Certification Clarification Order,8 clarifying
certain aspects of the certification requirements adopted in the iTRS Certification Order, and modifying
section 64.606 of the Commission’s rules to lessen the burdens on applicants for certification associated
with the submission of certain documentation to the Commission.9
Based on our review of the Snap Recertification Application, we grant conditional certification to
Snap to provide VRS services. In the iTRS Certification Order, the Commission reserved the right, after
initial review of an application, to conditionally grant certification, subject to one or more subsequent on-
site visits to the applicant.10 The Commission noted that such visits would “better enable the Commission
to verify the information provided in a certification application, and help us to better assess an applicant’s
ability to provide service in compliance with our rules.”11 This grant of conditional certification is

between the two parties, signing what the other party says to the deaf or hard of hearing user and responding in
voice to the other party to the call. The Interstate TRS Fund compensates eligible providers of VRS and other forms
of interstate TRS for their reasonable costs of providing these services. See 47 C.F.R. § 64.604(c)(5)(iii).
4 iTRS Certification Order, 26 FCC Rcd at 10899, ¶ 1. The measures adopted in the iTRS Certification Order were
part of the Commission’s ongoing and transitional efforts to reform the structure and practices of the VRS program,
and the new certification processes by which this grant of conditional certification is awarded may be superseded or
modified by future Commission actions on VRS reform.
5 Id. at ¶ 2.
6 Id.
7 See, e.g., 47 C.F.R. § 64.606(a); see also Structure and Practices of the Video Relay Service Program, Report and
Order and Further Notice of Proposed Rulemaking, 26 FCC Rcd 5545 (2011) (VRS Practices R&O).
8 Structure and Practices of the Video Relay Service Program, Sprint Nextel Corporation Expedited Petition for
Clarification, Sorenson Communications, Inc. Petition for Reconsideration of Two Aspects of the Certification
Order, AT&T Services, Inc. Petition for Reconsideration of AT&T
, CG Docket No. 10-51, Memorandum Opinion
and Order, Order, and Further Notice of Proposed Rulemaking, 26 FCC Rcd 14895 (2011) (iTRS Certification
Clarification Order
9 See id. at 14902-14904, ¶¶ 16-20.
10 47 C.F.R. § 64.606(a)(3); see also iTRS Certification Order, 26 FCC Rcd at 10914, ¶ 37.
11 iTRS Certification Order, 26 FCC Rcd at 10914, ¶ 36.

without prejudice to the Commission’s final determination of Snap’s qualifications, and is dependent on
the Commission verifying the information provided in the Snap Recertification Application, as amended,
and on the veracity of the applicant’s representations that it will provide service in compliance with all
pertinent Commission requirements.12
To allow the Commission to make such a determination, we reserve the right to conduct one or
more on-site inspections of Snap’s facilities by designated personnel, and to request additional
documentation relating to Snap’s provision of VRS. Ultimate conversion to full certification will be
granted if, based on on-site visits and our review of such additional documentation, the Commission finds
that Snap is in compliance with the Commission’s rules and orders, including those rules designed to
ensure the accuracy and integrity of Fund payments,13 and is qualified to receive compensation from the
Fund for the provision of VRS.14 If at any time during the period in which Snap is operating pursuant to
this conditional certification, the Commission determines that Snap has failed to provide sufficient
supporting documentation for any of the assertions in Snap’s application or that any of those assertions
cannot be supported, or finds evidence of any apparent rule violation, fraud, waste, or abuse, the
Commission will take appropriate action, including the possible denial of the Snap Recertification
Application. In the event of such denial, Snap’s conditional certification will automatically terminate 35
days after such denial.15 If, however, the Commission grants full certification, Snap, like all VRS
providers, must continue to operate in compliance with all relevant Commission rules and orders.
Redacted copies of the Snap Recertification Application and the amendment are available for
public inspection and copying during regular business hours at the FCC Reference Information Center,
Portals II, 445 12th Street, SW, Suite CY-A257, Washington, DC 20554, (202) 418-0270. The full text
of this Public Notice is similarly available for public inspection or copying. These documents may also
be purchased from the Commission’s duplicating contractor, Best Copy and Printing, Inc. (BCPI), Portals
II, 445 12th Street, SW, Room CY-B402, Washington, DC 20554. Customers may contact BCPI at its
web site:, or by calling 1-800-378-3160. Redacted copies of the Snap Recertification
Application and the amendment may also be found by searching on the Commission’s Electronic
Comment Filing System (ECFS) at (insert CG Docket No. 10-51 into the
Proceeding block).
To request materials in accessible formats for people with disabilities (Braille, large print,
electronic files, audio format), send an e-mail to or call the Consumer and Governmental
Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (TTY). This Public Notice can also be
downloaded in Word or Portable Document Format (PDF) at:
For further information, please contact Gregory Hlibok, Consumer and Governmental Affairs
Bureau, Disability Rights Office, at (202) 559-5158 (voice/videophone), (202) 418-0431 (TTY), or e-mail
- FCC -

12 Id. at ¶ 37.
13 See 47 C.F.R. § 64.604(c)(5)(iii).
14 See iTRS Certification Order, 26 FCC Rcd at 10914, ¶ 37; 47 C.F.R. § 64.606(b)(2),(c)(2).
15 See iTRS Certification Order, 26 FCC Rcd at 10914-15, ¶ 37. If the Commission terminates a conditional
certification, the provider must give at least 30 days’ notice to its customers that it will no longer offer service.

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