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Released: November 8, 2012

FCC Consumer Advisory Committee

Recommendation Regarding FCC IVR and Web-based complaint handling

The Consumer Advisory Committee (CAC) of the Federal Communications
Commission (Commission) respectfully submits these comments in response to a
request from FCC staff to review the Commission’s telephone interactive voice
response (IVR) and online complaint processes. This review comes in the context of
a broad review of the FCC’s complaint-handling process currently under way.
The purpose of the CAC is to make recommendations to the Commission regarding
consumer issues within the jurisdiction of the Commission and to facilitate
participation of all consumers in proceedings before the Commission. To
accommodate staff’s request, the CAC established a Consumer Complaint Task Force
(CCTF)1 that was charged with testing the IVR (i.e. the FCC Consumer Center
accessed via the 888-225-5322 telephone number) and web-based complaint
processes (accessed at and providing feedback to the
CAC. To date the CCTF has met via teleconference three times and provided an
informal briefing to FCC staff to discuss the task force’s findings.

1 The full list of CCTF member representatives is as follows: Ed Bartholme (Call For Action), Scott
Bergmann (CTIA – The Wireless Association), Debra Berlyn (National Consumers League), Lise
Hamlin (Hearing Loss Associaiton of America), Mitsuko Herrera (Montgomery County, MD Office of
Cable and Broadband Services), Irene Leech (Consumer Federation of America), Mia Martinez
(National Asian American Coalition), Ken McEldowney (Consumer Action), Art Neill (New Media
Rights Project), Stephanie Podey (National Cable & Telecommunications Association), Paul Schroeder
(America Foundation for the Blind), Dorothy Walt (Helen Keller National Center for Deaf-Blind) and
Olivia Wein (National Consumer Law Center).

Based on the CCTF’s findings, the CAC makes the following recommendations for
ways that the Commission should improve its complaint-handling process:
Regarding the IVR process:
The Commission should create an IVR system for consumer-related issues
separate from industry-related issues;
The Commission should create a dedicated phone number exclusively for the
submission of consumer complaints;
Where possible, the Commission should seek to reduce the number of
options presented in the IVR menus and allow for more functionality to ease
navigation between menus;
Wordiness and overuse of industry jargon (e.g. “slamming,” “DTV,” “wireless
spectrum management”) should be reduced or eliminated;
The Commission should make it easier for consumers to reach a live
specialist; and
· The hours of the call center should be extended, or at the very least the
Commission should provide clear notification of the hours a live specialist
may be reached.
Regarding the online complaint process:
· The Commission should review the three levels of the online complaint
system (i.e. complaint types, categories and forms) to ensure that complaints

about specific categories of service (e.g. bundled services) are more
The Commission should seek to reduce confusing and/or misleading
verbiage in the online complaint website’s menus;
The Commission should ensure that all menus and forms are screen-reader
The Commission should lift the 1,000 character limit in online form comment
fields to allow consumers sufficient room to accurately convey their
concerns; and
The Commission should ensure that the complaint forms specify what
information is required and what is optional in order for consumers to
continue with the complaint process.
Regarding the complaint-handling process generally:
The Commission should seek guidance from complaint specialists at the
Consumer Financial Protection Bureau and Federal Trade Commission
regarding those agencies’ complaint-handling processes;
· The Commission should make instructions on how to file a complaint more
prominent on both the homepage and the online complaints
landing page (;
· The Commission should prominently include instruction on how to reach a
live complaint specialist by phone (and the business hours for the call center
and ASL operator) on the page; and

The Commission should streamline the process for forwarding complaints to
telecommunications providers for investigation.
In conclusion, we appreciate the Commission’s consideration of the CAC’s input on
this topic. Given the importance of the Commission’s complaint-handling process in
providing guidance to the Commission’s enforcement, policy-making and consumer
education activities, it is imperative that the complaint-handling process be made
more consumer-friendly.
DATE ADOPTED: September 21, 2012
Respectfully Submitted:
Debra Berlyn
FCC Consumer Advisory Committee

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