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TDD/TTY Accessibility Checklist for PSAPs

The TDD/TTY Accessibility Checklist can be used as a tool in the self evaluation process required of all agencies. Developed originally to assist agencies in Texas, this document incorporates requirements found within the ADA and common areas found within settlement agreements. Once you have completed the checklist, you will have a better idea of areas that may need further attention. Established operating procedures and a comprehensive training program are key to a successful emergency response system. It also reflects the agency's commitment to the protection of lives and property in the community it serves. It is recommended that you maintain documentation of your evaluation process. And if, at some time, your agency is contacted by Justice, you will have answers readily available.

How to use this document

The following is provided as a sample of questions that should be asked in a self analysis of your 9-1-1 system and services. The more questions that are answered "yes", the more likely the department will provide meaningful telephone emergency response service to those using TDD/TTY. If "no", you may want to consider taking action and documenting a timeline.

Self Evaluation (Title II, Sec. 35.105)*

Have the current services, policies, and practices, and the effects thereof, that do not or may not meet the requirements, been evaluated and the extent modification of any such services, policies, and practices is required, made necessary modification?

Has the opportunity been provided to interested persons, including individuals with disabilities or organizations representing individuals with disabilities participated in the self-evaluation process by submitting comments?

Has the public entity made available to applicants, participants, beneficiaries, and other interested persons information regarding the provisions of this part and its applicability to the services, programs, or activities of the public entity, and made such information available to them in such a manner as the head of the entity finds necessary to apprise such persons of the protections against discrimination assured to them by the ADA?

Does the entity that employs 50 or more persons have a published grievance procedure providing for prompt and equitable resolution of complaints alleging any action that would be prohibited by the ADA.

Equipment

  • Does the telephone emergency response system provide the same level of service, i.e. Automatic Number Identification (ANI) and Automatic Location Identification (ALI), to all citizens, including those who call with a TDD/TTY?
  • In the event of individual line or system failure, is an alternative method of receiving emergency calls accessible to TDD/TTY callers?
  • Are all consoles that are available for receiving emergency calls equipped with TDD/TTY accessible equipment?
  • Is redundancy in the 9-1-1 equipment provided for? If the answer to the previous question is yes, are TDD/TTY accessible equipment included in the redundancy plan?
  • Does the equipment and method used to transfer emergency calls to other emergency services provide for accessibility with TDD/TTYs?
  • If your system utilizes automatic call distribution and includes an automatic recording to the citizen who may be put into a queue until there is an available telecommunicator, does the recording include a TDD/TTY recorded message?
  • Do equipment upgrade or expansion plans include TDD/TTY accessibility?
  • Does the recording equipment (which records incoming emergency lines) include recording the point of answer for TDD/TTY's?
  • Are the TDD/TTY's located where the call taker can switch from voice mode of communication to TDD/TTY without causing delay in answer time?
  • Can VCO (voice carry-over) and HCO (hearing carry-over) calls be handled with the current system?
  • If the TDD/TTY equipment has preprogrammed messages, have persons with hearing impairment been consulted regarding the appropriate language for TDD/TTY users?
  • Has the center explored the feasibility of or have TDD/TTY detection equipment installed?
  • Does the communications system have the capability to provide TDD/TTY access to alternative non-emergency numbers?
  • Can the call taker make a call back using a TDD/TTY?
  • Do you have a maintenance plan for the TDD/TTY equipment and procedures (including documentation) for such?

Operations

  • Has your agency developed and implemented Standard Operating Procedures (SOPs) for responding to TDD/TTY calls?
  • Have SOPs been written for TDD/TTY call handling and disseminated to call-taking personnel?
  • Do secondary PSAPs have the capability to answer TDD/TTY calls?
  • Is the standard time for answering voice calls comparable to that for TDD/TTY calls?
  • Do the call-back procedures include contingencies for reaching a citizen who uses a TDD/TTY?
  • Does the center keep entries or statistics of TDD/TTY calls?
  • Are there procedures for handling Telecommunication Relay Services (TRS) calls?
  • Has the agency developed and incorporated effective methods for transferring TDD/TTY calls to the fire department or EMS? (note: only applicable if voice calls are handled this way.)
  • Has the agency developed and implemented SOPs for processing silent open-line calls? Does the call taker interrogate the line for a possible TDD/TTY call? (see Title II Technical Assistance Manual)
  • Is there a program in place to test the TDD/TTY with the overall system?

Training

  • Are there minimum TDD/TTY training requirements for telecommunicators?
  • Does the agency provide a comprehensive TDD/TTY training program for all call takers?
  • Are refresher classes provided at a minimum of every 6 months?
  • Is someone assigned to follow technological development through the various public safety associations and add these innovations into the training regiment?

Other

  • Have members of the disability community been consulted in the self-evaluation process, including the creation of standard operating procedures and the development of training.
  • Has a public awareness program been developed and implemented, to notify citizens using TDD/TTYs of the department's accessibility and services?
  • Does the local telephone directory indicate direct access to telephone emergency services for TDD/TTY users? (DOJ has provided approved language)

* the Americans with Disabilities Act: P.L.101-336, Title II, Section 35.162