FCC Considers New Customer Service Requirements for Communications Providers
FCC Considers New Customer Service Requirements for Communications Providers
Through a Notice of Inquiry (NOI) released October 23, 2024, the Federal Communications Commission (FCC) is examining whether to establish comprehensive standards for customer service across all broadband, voice, video/cable and satellite TV providers, including small rural operators (Communications Providers).
The focus of the NOI is to consider proposals that could “take some of the pain” out of routine customer problems and make it easier for consumers to change providers “when they are frustrated.” Specifically, the FCC seeks comment on several key areas including requirements for simple service cancellation processes, guaranteed access to live customer service representatives, specific timeframes for installations and service calls, and new standards for handling automatic service renewals and price increases. The Commission is also examining requirements for serving disabled customers and non-English speakers.
The FCC is requesting comments on these proposals, with initial comments due November 22, 2024, and reply comments due December 9, 2024.
Advocacy Needed to Exempt Smaller Communications Providers
In the NOI, the FCC recognizes that compliance with new customer service requirements could pose unique challenges for smaller operators and seeks comments on establishing a comprehensive waiver process. Unfortunately, the waiver process envisioned in the NOI would only be for Communications Providers that can demonstrate undue hardship and only those with fewer than 15,000 subscribers. The FCC also seeks input on whether granted waivers should be time-limited and subject to renewal, and whether certain small providers should be completely exempt from some or all requirements.
The FCC’s proposed threshold of 15,000 subscribers is heavily influenced by previous rules and regulations developed in the context of cable carriage and cable systems. Additionally, the notice does not explicitly define the term “subscriber,” which could potentially refer to individual service subscribers, household subscribers, or could vary based on service type (broadband vs. cable vs. voice, etc.). If the FCC were to adopt such a waiver process, the resulting process could significantly curtail the ability for clients to obtain waivers given the “undue hardship” standard and low subscriber threshold.
Accordingly, JSI encourages clients to participate in individual or group comments in which you relay how well your company handles customer service matters, contrasting the “in person” experience that your company offers with the automated services used by larger providers that are the focus of customer frustration and has prompted the need for the NOI. Comments should also argue for a larger threshold for waivers with no “undue hardship” standard.
If you are interested in submitting comments or have questions about how these proposed requirements might affect your operations, please contact Brett Hallagan or John Kuykendall.