Reminder: Wireless Handset Manufacturer Hearing Aid Compatibility Status Report Due July 16, 2018

Kelley Drye Client Advisory

Please be reminded of the upcoming due date for the Report listed below:
FCC Form 655 – Wireless Handset Manufacturer Hearing Aid Compatibility Status Report
All manufacturers of wireless handsets that are used in the delivery of digital commercial mobile radio service (“CMRS”), specified in section 20.19 of the Federal Communications Commission’s (“FCC’s” or Commission’s”) rules, must file, by midnight EDT on Monday, July 16, 2018,* FCC Form 655 reporting on the status of the manufacturer’s compliance with the FCC’s rule 20.19 hearing aid compatible handset requirements. The reporting requirement includes, but is not limited to, identifying the number of handsets tested for hearing aid compliance and the number of compliant handset models offered to service providers as well as providing information regarding noncompliant handset models, the status of product labeling, and outreach efforts. The FCC Form 655 must be submitted electronically via the FCC’s website.
*This report typically is due on or before July 15th annually. However, because that date falls on a weekend in 2018, Commission rules dictate that the report is due on the next business day.
Time Period Covered by Report
The report covers the time period July 1, 2017 – June 30, 2018.  Information in the report must be up-to-date as of June 30, 2018.
Who Must file:
All manufacturers of wireless handsets that are used in the delivery of digital commercial mobile radio service that comes within the scope of rule 20.19 below. 
Prior to January 1, 2018 for Tier I carriers and April 1, 2018 for service providers other than Tier I carriers:
Rule 20.19 applies to providers of digital CMRS in the United States that meet the following specifications:
(i) to the extent that they offer real-time, two-way switched voice or data service that is interconnected with the public switched network; and
(ii) utilize an in-network switching facility that enables the provider to reuse frequencies and accomplish seamless hand-offs of subscriber calls; and
(iii) such service is provided over frequencies in the 698 MHz to 6 GHz bands.
On or after January 1, 2018 for Tier I carriers and April 1, 2018 for service providers other than Tier I carriers:
Rule 20.19 applies to providers of digital mobile service in the United States to the extent that they offer terrestrial mobile service that enables two-way real-time voice communications among members of the public or a substantial portion of the public, including both interconnected and non-interconnected VoIP services, and such service is provided over frequencies in the 698 MHz to 6 GHz bands.

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Please be advised that attorneys in Kelley Drye & Warren’s Communications Practice Group are experienced in addressing issues related to the hearing aid compatibility handset reports. For more information regarding this client advisory, please contact your usual Kelley Drye attorney or any member of the Communications Practice Group.