FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011 Page: 5,682
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requested and provided to consumers to be made available for public review in a format that is accessible
to individuals who are deaf-blind."36
95. Several commenters expressed interest in the ways that the Commission should assess the
effectiveness and efficiency of certified programs during the NDBEDP pilot program. For example, the
National Coalition is concerned that, as proposed in the NDBEDP NPRM, the pilot program would not
include measures for evaluating its success.337 It suggests, among other things, that the pilot use objective
measures to assess the effectiveness of the distribution program to the maximum extent possible, test and
compare the relative effectiveness of a variety of program models, and actively seek direct consumer
input on the pilot's success.33 The Lighthouse adds that "a new metric may be needed" in assessing cost
efficiencies for a population that has been long underserved and that, "[m]easurements initially should
evaluate the relative effectiveness of programs in a state or region with [a] goal [of] establishing a
national standard over a reasonable period of time."339 It also suggests that any assessment of the pilot
program's effectiveness must be informed, first and foremost, by input from deaf-blind consumers,
advocacy groups, and leaders, and that such input must be obtained in a culturally relevant and fully
accessible manner.340 The Lighthouse explains further that Commission-established public comment
periods "are typically too short to solicit meaningful involvement from the Deaf-Blind community."34'
Likewise, AADB recommends that oversight and reporting responsibilities be shared with a national,
non-profit, deaf-blind consumer organization, which "has the network with other consumer groups and
the connections with members to make this [program] succeed." 2 Parker adds that "rich evaluation data
(from focus groups of consumers, brief surveys, and from measuring consumer valued outcomes) is
critical for building an effective and responsive system.""343
96. With respect to the appropriate intervals for reporting, records retention and audits,
several commenters supported the submission of reports to the Commission every six months.'" In
addition, DBYAA recommends requiring retention of electronic records for five years to enable efficient
audits and resolution of consumer complaints.45 TEDPA reports that some state EDPs have a three-year
records retention policy, and recommends that all information be submitted electronically with hard
copies being retained for two years, with the exception of financial records, which it says should comply
336 AADB Comments at 3.
337 National Coalition Comments at 2.
3" Id. See also ACB Reply at 2, recommending that the Commission conduct two pilot programs, one reliant on
state programs and the other reliant on a regional model, so that the Commission may compare the success of each
model against each other.
339 Lighthouse Comments at 3.
34 Id. at 2.
341 Id.
342 AADB Comments at 10-11.
3 Parker Comments at I (parenthetical in original).
344 See, e.g., DBYAA Comments at 6; MoAT Comments at 3; ACB Reply at 0 (supporting generally the
Commission's processes to monitor equipment distribution).
3- DBYAA Comments at 6.5682
Federal Communications Commission
FCC 11-56
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United States. Federal Communications Commission. FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011, book, April 2011; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc52169/m1/854/: accessed April 25, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.