ADA Best Practices Tool Kit for State and Local Governments

C. Equipment and Features to Provide Direct and Equal Access to Emergency Communications Services

Now that you have a basic understanding of how TTY communications work, let’s look at how Title II of the ADA’s requirements translate to what PSAPs need to do. Remember, PSAPs must provide direct and equal access to emergency communications services for people who use TTYs.

1. Number of TTYs

In order to provide equal access to TTY users, every call-taking position within the PSAP must have its own TTY or TTY-compatible equipment.³ PSAPs must have systems that enable call takers to handle TTY calls as properly, promptly, and reliably as voice calls.

Why must every call-taking position have its own TTY or TTY-compatible equipment? To give TTY users equal access to emergency call services. Experience has shown that:

• With TTY or TTY-compatible equipment at each call-taking position, call takers can handle TTY calls as effectively as voice calls.

• Call takers at PSAPs that have only one TTY have significant difficulties handling TTY calls as quickly as voice calls.

• Sharing a TTY among several call takers may result in undue delay in obtaining the TTY and connecting it to the answering position.

• Transferring a TTY call from a non-TTY capable answering position to a TTY-dedicated position may result in the call being disconnected or undue delay in answering the call. In some cases, transfers may result in the loss of enhanced features, such as automatic number identification and automatic location identification information.

• Each call taker needs to query every silent, open line as a potential TTY call. Because most PSAPs receive many silent, open line calls, often more than one at a time, each call taker must have his or her own TTY equipment to be able to query all of those calls with a TTY.

2. Automatic Identification Features

Many PSAPs have equipment with advanced features that facilitate quicker responses to callers. For example, many have automatic number identification (ANI) and automatic location identification (ALI). These features automatically tell the call taker the phone number and address from which a call originates.

If your area’s emergency service provider has these features, you must ensure that TTY calls have the same access as voice calls to such enhanced features whenever feasible. Such features are currently available for TTY calls placed using traditional TTY hook-ups to standard telephone lines. Emergency service providers need to stay current with changing technology to ensure that equal access and services are provided to TTY callers relying on newer technologies when they become available.

TTY calls may not simply be transferred to a third line to get this information because transfers often result in the loss of the automatic phone number and address information.

3. Automatic Call Distribution (ACD)

Another feature employed by PSAPs is automatic call distribution (ACD). ACD places incoming calls into a queue, sends out a programmed message to callers to let them know that their calls have been received, and distributes calls to the next available call taker. This feature, if offered, must also be accessible for TTY calls. For TTY callers transferred to a queue using ACD, there must be a programmed TTY message providing the same information that other callers receive.

4. Switching Between Voice Mode and TTY Mode

All call takers must have the capability to switch back and forth easily from TTY mode to voice mode during the same call. This is especially necessary for silent calls because it allows the call taker to first query the line by voice and then quickly switch to query the line by TTY.

5. Voice Carryover and Hearing Carryover

Voice carryover (VCO) is a communication hybrid of TTY and voice. With VCO, a person with hearing loss can speak directly to the call taker and read the response that is typed back.

Hearing carryover (HCO) allows a TTY user to type words on the TTY and hear call takers’ spoken responses through the handset.

Having equipment that can switch back and forth between voice mode and TTY mode is also necessary for VCO and HCO. These types of communication can shorten the length of calls that would otherwise be conducted exclusively by typing.

Both of these types of communication can be accomplished using standalone TTY equipment and alternating between speaking into the handset and placing the handset in the TTY when the caller (HCO) or call taker (VCO) types a response.

6. Maintenance and Back-up of TTY Equipment

The ADA regulation contains a specific provision requiring that covered entities maintain their accessible features and equipment in operable working condition.⁴ To comply with this regulation, PSAPs must implement procedures for maintenance and back-up capability for TTY equipment that are equally effective as the procedures for maintenance and back-up capability provided for voice telephone equipment. For example, TTY equipment must be maintained and tested as often as voice equipment to ensure that it is working properly.

If a PSAP has a plan for back-up equipment in case some of its equipment malfunctions, the telephone lines malfunction, or there is a power failure, the plan must provide for TTY calls and equipment. For instance, PSAPs should keep extra TTY equipment on hand, in case primary equipment fails, if they have back-up voice telephone equipment for such a situation.

7. Training Call Takers to Respond Effectively to TTY Calls

PSAPs should train their call takers to effectively recognize and process TTY calls. Providing appropriate equipment is only as effective as your staff training.

The ADA does not specify how call takers should be trained. But the Department of Justice believes that the following are essential for proper training:

• Training should be mandatory for all personnel who may have contact with individuals from the public who have hearing or speech disabilities.

• PSAPs should require or offer a refresher training at least as often as they require or offer training for voice calls, but at a minimum, every six months.

The checklist included with this chapter has additional information about what should be included in a comprehensive training program. You should use this checklist to assess your current training program for emergency call services, policies and procedures, and testing program.

8. Testing to Ensure Direct, Equal Access

Frequent testing is essential to ensure direct, equal access to emergency communications services. The best way to test is to implement an internal testing program. The goal of these tests is to determine whether TTY equipment functions properly and whether personnel have been adequately trained to handle TTY calls correctly.

Include these steps in your testing:

• Conduct two types of test calls: silent, open line calls in which no tones are emitted, and calls in which the caller introduces the call by transmitting TTY tones. These tests should be unannounced, and should cover each call taker and each position.

• Keep records of the results of all test calls. Include, at a minimum, the date and time of each test call; the identification of the call taker and the calltaking position; whether each call was silent or transmitted tones; whether the caller received a TTY response and the content of the TTY response; the time elapsed and the number of rings from the initiation of the TTY call until the call taker responded by TTY; and whether the call was processed according to the PSAP’s standard operating procedures.