Georgia Tech's Center for Advanced Communications Policy (CACP) filed comments in response to the Federal Communications Commission Consumer and Governmental Affairs Bureau's request for comments on the accessibility of advanced communications technologies. The Bureau sought to obtain updated information on providers' usability and accessibility of information and customer care services. They also sought to understand whether there has been progress in the accessibility of mobile products. CACP offers the latest preliminary findings from their 2022 Mobile Accessibility Review (Review) to address these inquiries. In the comments, CACP indicated low transparency about the presence of inclusive features on mobile devices. The comments highlight that it is challenging for the everyday consumer to find accessibility information in the consumer guides or the device manuals. To accurately glean the presence of accessible features in mobile phones requires using multiple consumer-facing sources. However, we argue that this process causes an undue burden on consumers with disabilities. We further assert that this limited transparency is a missed opportunity, as clarity on whether a device has the accessibility features that consumers seek could improve consumer satisfaction and potentially reduce call center complaints concerning access issues.
The comments also highlight the accessibility of mobile phones in Lifeline providers and major wireless carriers. The Review found room for growth in all categories for both provider types. Greater uniformity of accessibility features across provider types would better ensure the accessibility of affordable phones. For example, increasing real-time-text (RTT) and two-way video capabilities in Lifeline-provided phones would increase the likelihood of consumers with hearing disabilities identifying and purchasing a phone that has the suite of accessibility features needed for effective communications with both people who are Deaf (e.g., two-way video) and those who are hearing (e.g., RTT). The comments also suggested that increasing the presence of features that enable alternative input, ease of navigation, and connectivity to external assistive technology devices would improve mobile phone access and equity for persons with mobility disabilities. Comments also covered access for persons with cognitive disabilities and vision disabilities. To read the full comments, please see the attachment below.