CACP on the Record – Accessibility of Inmate Calling Services

Filing Date
October 27th, 2021

Georgia Tech's Center for Advanced Communications Policy (CACP) offered reply comments to the Federal Communication Commission's Fifth Notice of Proposed Rulemaking in the Matter of Rates for Interstate Inmate Calling Services (ICS) [WC Docket No. 12-375]. In this request for reply comments, the FCC sought whether they held the statutory authority to mandate inmate calling service providers offer access to Telecommunications Relay Service (TRS) and the benefits and costs of doing so. CACP supported comments made by HEARD that the FCC has ancillary authority to ensure that providers of TRS provide accessible services and equipment for inmates with disabilities, as indicated in Section 716. This authority is further imbued by federal legislation requiring TRS service providers to offer functionally equivalent telephone services for people with disabilities.

As it pertains to benefits, CACP reasserted and provided support to comments made by HEARD. Research indicates that there is a positive relationship between inmate communication access on family health. Family contact during incarceration reduces recidivism.[1] Research also shows that strong familial support networks strengthened through visitations and regular communication during the incarceration period reduce the likelihood of reoffending[2] and offer messages of reform to the children and families of incarcerated persons' that discourage them from going down the same path that led to imprisonment.[3] We further asserted that one of the benefits of offering advanced communications, such as VRS, is more cost-effective than text-based TRS because of conversation flow. We conclude by echoing the Joint Advocates' comments that "access to communications is a basic human and civil right of incarcerated people with disabilities that is critical to their ability to navigate and survive the carceral system." To read the full comments by the CACP, please click here or see the attachment below.


[1] De Claire, K., & Dixon, L. (2017). The effects of prison visits from family members on prisoners’ well-being, prison rule breaking, and recidivism: A review of research since 1991. Trauma, Violence, & Abuse, 18(2), 185-199.

Brunton-Smith, I., & McCarthy, D. J. (2017). The effects of prisoner attachment to family on re-entry outcomes: A longitudinal assessment. The British Journal of Criminology, 57(2), 463-482.

[2] Folk, J. B., Stuewig, J., Mashek, D., Tangney, J. P., & Grossmann, J. (2019). Behind bars but connected to family: Evidence for the benefits of family contact during incarceration. Journal of Family Psychology, 33(4), 453.

[3] Tasca, M., Mulvey, P., & Rodriguez, N. (2016). Families coming together in prison: An examination of visitation encounters. Punishment & Society, 18(4), 459-478.