Proposal for New TRS Fund Support for Internet Protocol Captioned Telephone Service
The Federal Communications Commission (FCC or Commission) proposes to adopt a new three-year plan for Telecommunications Relay Services (TRS) Fund support of internet Protocol Captioned Telephone Service (IP CTS). Based on recent data that allows more reliable assessment of the costs of fully automatic IP CTS, the Commission proposes to apply different formulas for compensating TRS providers for the provision of Communications Assistant (CA)-assisted and automatic speech recognition (ASR)-only IP CTS. The Commission proposes to continue using an average-cost methodology, subject to revised criteria for determining reasonable costs and to annual adjustments based on relevant cost factors.
What this rule actually says
The FCC is proposing new funding rules for captioned telephone services that help deaf and hard-of-hearing people make phone calls. Specifically, it's changing how much money the government reimburses companies that provide these services, and it's creating different payment rates depending on whether the service uses a human operator or automatic speech recognition software. This is a narrow rule about telecommunications infrastructure funding, not a broad regulation about AI or user data.
Who it applies to
- If you're building: A captioned telephone service (IP CTS) where deaf/hard-of-hearing users can make phone calls with real-time captions or AI-assisted transcription
- If you're NOT affected: Medical scribes, hiring assistants, support chatbots, and most other AI tools—unless they specifically provide captioned telephone relay services
- If you're in: The United States (FCC jurisdiction only)
- User data scope: This rule governs how the government pays providers, not how user data is collected or protected; privacy/data rules come from different regulations
Real talk: Most indie founders building AI products will not be affected by this. You'd only care if your core product is specifically a captioned telephone service serving deaf/hard-of-hearing users and you're seeking FCC reimbursement through the TRS Fund.
What founders need to do
- Check if you're actually in scope (0.5 days): Ask yourself: "Is my product a captioned telephone service funded by the FCC's TRS program?" If no, stop reading and move on.
- If yes, monitor FCC updates (ongoing, 2-3 hours/month): The rule is still "proposed" as of February 2023—it's not law yet. Subscribe to FCC alerts at fcc.gov to track when this becomes final.
- Understand the two payment tiers (1-2 days): If/when this becomes final, study whether your service uses human operators (CA-assisted) or only automated speech recognition (ASR-only), because that determines your reimbursement rate.
- Engage with FCC if you disagree (3-5 days): The comment period may still be open. If the proposed rates are unfavorable to your business model, file comments with the FCC explaining your cost structure.
- Budget accordingly (1 day): Once finalized, update your financial projections based on the new reimbursement rates—they may be higher or lower than current rates.
Bottom line
Monitor this if you're building a captioned telephone service; ignore it if you're building anything else.