Reminder: FCC Service Provider Hearing Aid Compatibility Certification due January 15, 2020

Kelley Drye Client Advisory

Following are reminders for upcoming Federal Communications Commission (FCC) reports and compliance requirements due in January 
Form 855:  Hearing Aid Compatibility Service Provider Certification
As we explained previously, in late 2018, the FCC eliminated the annual FCC Form 655 hearing aid compatibility (HAC) report for service providers and replaced it with the annual Form 855 certification filing. 
The annual Form 855 Certification must be filed by all digital mobile service providers within the scope of FCC rule 20.19, including mobile virtual network operators (MVNO) and resellers, and among other requirements, filers must:

  • certify whether or not they are in full compliance with Commission HAC rules;
  • explain any instances of noncompliance;
  • provide percentage of HAC handsets offered during the time period covered by the Certification; and
  • link to the filer’s public webpage that lists information on HAC handsets, as required by the rules.

The Form 855 Certification covers the period January 1, 2019 – December 31, 2019 and is due to the FCC by January 15, 2020.  The Form 855 Certification must be completed online and the link to the filing portal and instructions for the form are available here
Note that providers that are otherwise exempt from HAC rules, pursuant to the de minimis exception of  FCC rule 20.19(e), still are required to file the HAC Certification.  Providers may also be subject to website content and record retention requirements and should be sure to review the FCC rules to confirm any HAC compliance obligations.

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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 certification.  For more information regarding this client filing alert, please contact your usual Kelley Drye attorney.