Industry Insights

Reminder to Verify Certification for FCC Recordkeeping Requirements

March 2018
Author:  Burnie Snoddy

Burnie Snoddy

Senior Managing Consultant


1401 50th Street, Suite 350
West Des Moines, IA 50266-5935

Des Moines

By April 2, 2018, all telecommunications providers and equipment manufacturers subject to Section 255, 716 or 718 of the Communications Act must complete their certification for the Federal Communications Commission’s (FCC) Accessibility Recordkeeping and Contact Information Requirements in conjunction with the Americans with Disabilities Act of 1990. FCC Public Notice, DA 18-206 was released March 1, 2018.

By April 2, and annually thereafter, companies must file these certifications online with the FCC’s registry. Companies must certify compliance with recordkeeping requirements and provide contact information for filing consumer complaints and the name of a designated agent for service of formal and informal complaints.

An important part of this obligation is a requirement that as of January 30, 2013, companies begin keeping records of their:

  • Efforts to consult with individuals with disabilities and local support agencies
  • Descriptions of the accessibility features of offered products and service devices—these often will come from vendors and manufacturers
  • Information about the compatibility of any offered products and services with peripheral or specialized customer premise equipment commonly used by individuals with disabilities to achieve access—again, vendors and manufacturers are the typical source for this

BKD understands the FCC website and other official websites can be somewhat intimidating. However, this report is simple, and you should be able to complete it with very little difficulty. The login process requires your company FCC Registration Number (FRN) and FRN password. The reporting information should be collected ahead of time. Companies must complete all data entry for this reporting in one sitting, so be sure to gather the information and have the appropriate personnel available for certification before entering the website. Step-by-step filing instructions are available, if needed.

If you have questions or would like assistance with this certification, contact Bryan Dilks, Connie Stufflebeem, Bob Abrams or Burnie Snoddy.

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