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VoIP providers who are not already familiar with the Federal Communication Commission’s Twenty-First Century Communications and Video Accessibility Act (CVAA) need to get up to speed soon. Recently the FCC (News - Alert) released a Public Notice reminding VoIP providers and equipment manufacturers of advanced communications systems that they, too, are covered by the FCC regulation.

The CVAA is a 2010 law ensuring telecommunications access for people with disabilities, and the FCC began issuing regulations implementing the legislation in October 2011, according to an article by law firm, Sheppard Mullin Richter & Hampton.

Since January 30, VoIP providers are now required to maintain business record of their compliance with the CVAA regulations during the ordinary course of their business, according to the article. Further, by April 1, 2013, those covered by the regulation must file contact information for resolving consumer complaints, and their first certification showing that they are in compliance with the recordkeeping requirements.

The recordkeeping obligation that went into effect January 30, reportedly mandates records that show information about efforts to consult with individuals with disabilities; descriptions of the accessibility features that are a part of products and services; and information about the compatibility of products and services with peripheral devices or specialized customer premise equipment commonly used by individuals with disabilities to achieve access.

For the April 1 deadline, those covered must identify the name and contact details of a person within the company who is authorized to resolve customer complaints. They must also designate an agent for the service of informal and formal complaints alleging violations of the CVAA rules, the article noted. The contact information must list the person’s title, address, phone number, and if available, TTY number, fax and email.

“Covered entities should note that these designations must be done for each entity or subsidiary that is subject to the CVAA,” noted the Sheppard Mullin Richter & Hampton article. “Implementing regulations cannot be satisfied by designating one overall contact person for a parent company.”

The certification must be supported by an affidavit or declaration under penalty of perjury, signed and dated by an authorized officer of the company or subsidiary with personal knowledge of the representations provided, it added.

This certification must be filed electronically on the FCC’s website and updated within 30 days of any changes to its certification.

While recordkeeping and certification are required, “the goal of these statutes is to ensure that individuals with disabilities are able to access and use the services and products in the same way that individuals without disabilities are able to do so,” noted the law firm Kelley Drye & Warren. So, the substantive requirements are the heart of the statutes and VoIP providers need to make sure they are in compliance.

For VoIP providers who are not familiar with the CVAA, it is time to consult the lawyers.