The Annual Hearing Aid Compatibility (HAC) Status Reports (FCC Form 655) filing is due on January 15, 2016 for the reporting period of January 1, 2015 – December 31, 2015.  The filing system is accessible through the Commission’s Universal Licensing System (ULS) here. Filers may access the system through ULS using their regular FCC Registration Number (FRN) and password.  The updated HAC rules recently adopted in the Fourth Report and Order have not yet become effective, so the 2016 filing should largely resemble prior process and reports.

Handset Offering Requirements

Wireless service providers are permitted to meet either one of two HAC compliance safe harbors.  First, providers may certify that they have a minimum of 10 handset models that have an M3 or better rating and 10 handset models that have a T3 or better rating.  Alternatively, providers may certify that at least 50 percent of the handsets that they offer have an M3 or better rating, and that at least one-third of the handsets offered have a T3 or better rating.  Note also that there is a de minimis exception to the HAC requirements for carriers that offer two or fewer handset models to customers in a particular air interface (e.g., GSM, CDMA) for less than two years.  However, very few wireless carriers fall within this exemption.

Labeling Requirements

Service providers are also subject to public website and labeling requirements.  The HAC rules require that packages containing hearing aid-compatible handsets must be explicitly labeled and must include detailed information in the package or product manual, with the M and/or T rating clearly displayed.  And, all handsets with Wi-Fi capabilities must also include a label disclosing that the handset has not been rated for hearing aid compatibility with respect to Wi-Fi operation.  Wireless service providers also must offer a means for consumers to test hearing aid-compatible handsets in their owned or operated retail stores.

In addition, all carriers that operate a publicly-accessible website must have available on that website a list of all currently-available hearing aid compatible handsets.  The list must include their M or T ratings as well as the level of “functionality.”  Service providers are permitted to develop their own “functionality” ratings for display and reporting purposes.  This functionality rating might divide phones into categories such as Basic Handset, Feature Phone and Smartphone, for example.

Please do not hesitate to contact us with any questions regarding the HAC report or the filing system. Should you require our assistance in filing this report, please let us know no later than the close of business on Friday, January 8, 2016.