FCC Caption Quality R&O Summary: What you need to know

Overview

In its most recent rulings, the Federal Communications Commission (FCC) has issued deliberately vague, broad metrics for the quality of closed captioning. There are no specific accuracy rates or latency limits, but they place great emphasis on process, practices, monitoring, assessing, and responding to complaints.  They have no periodic public reporting requirement but very demanding documentation and record-keeping requirements for monitoring quality and responding to complaints.

The basics: There are SEVEN primary, non-technical quality requirements
  • Accuracy
  • Synchronicity (latency)
  • Completeness (latency)
  • Monitoring and maintaining equipment
  • Periodic quality assessments
  • Record-keeping – Record of evaluations, problems and fixes
  • ENT fill-in [hyperlink]
    • Weather
    • Sports
    • Breaking News

The specifics:

Quality requirements vary by program type

+ Pre-recorded programs: Near-perfect quality required

  • De minimis errors
  • Maximum synchronicity, minimum latency
  • Minimal losses at breaks
  • Proper on-screen placement

+ Live programs: Do the best you can—and be prepared to prove you did

  • No specific accuracy metric
  • “Overall accuracy” should render captions “understandable,” comparable, and equivalent to aural track
  • “Best practices” essentially required for programmers, caption vendors, and captioners
  • Synchronicity: “minimum” latency required, subject only to technical limitations”
  • Completeness—maximize by:
    • limiting latency
    • facilitating captioner text reduction through break notification and “advance delivery” of audio
    • allowing  caption bleed-over into breaks if placement is adjusted to avoid compromising captions in commercials and promos

+ Near live programs (within 24 hours to first air)

  • Same as Live [hyperlink]
  • Encourage use of scripts, post-taping clean-up (edit, synchronize)

Quality requirements vary by role

Distributors have the ultimate responsibility for compliance

Programmers, vendors, and captioners must certify full compliance or employ FCC best practices

All parties must monitor, assess and fix problems promptly – and document all these actions

+ “Best practices” for programmers
  • Adopt specific quality performance standards
  • Assure caption vendor training and oversight
  • Provide scripts and names to captioners in advance
  • Verify compliance
  • Offline captions
  • Perform periodic, in-depth spot checks for accuracy
  • Real-time captions: in-depth assessments whenever complaint is received
  • Adopt troubleshooting protocol to respond to complaints
  • Monitor caption quality in real time
  • Record/log all caption issues
  • Certify all the above to distributors
+ “Best practices” for live caption vendors
  • Establish specific quality metrics
  • Perform “frequent and regular” quality assessments
    • Accuracy assessment must include:
    • Misspelled words
    • Missing words
    • Incorrect punctuation
    • Incorrect words
  • Ensure technical systems are functional, fast, and foolproof
  • Respond promptly to complaints from programmers and viewers
  • Regularly review discrepancy reports received from captioners
  • Alert programmers promptly to problems
+ “Best practices” for live captioners
  • “Be as good as you can be” on quality metrics
  • File timely, thorough discrepancy reports
  • Allow captions to pass at breaks
  • Perform “frequent and regular” self-evaluation
  • Monitor and maintain equipment

Broadcast stations

+ Broadcast stations have dual obligations:

As distributors: live plus network programming syndicated programming
As programmers: live local programming

+ As distributors:
  • Must use best efforts to obtain quality certifications from all programmers
  • Must assure that station processing does not degrade accuracy of captions generated by programmers
  • Must be able to identify and fix caption problems promptly
  • Must be able to respond to complaints from public and/or FCC with documentation proving non-degradation, monitoring, assessment and repairs.
  • Must minimize latency and maximize completeness
+ As live programmers:
  • Must use best efforts to obtain quality certifications from all captioning vendors
  • Must use contract with caption vendors to establish accuracy, synchronicity and completeness targets
  • Broadcast stations as live programmers (cont)
  • Must adopt other programmer best practices, including
    • Names and scripts to captioners in advance of airing
    • Verify programmer compliance
      • Periodic in-depth accuracy
    • Spot checks for offline captions and whenever
    • Notified by FCC of problems with real-time captions
  • Monitor caption quality in real-time
  • Record/log all caption issues
  • Adopt troubleshooting protocol to respond to complaints

 

Important dates

ENT Supplementation

+ Teleprompter captioned stations:

Effective date: June 30, 2014

All segments of in-studio programming must be scripted and thus captioned, including weather, sports, and breaking news in-studio.
                        Note: Weather must be fully-scripted but need not precisely track spoken words.

Breaking news and live, on-scene interviews if not fully scripted must be supplemented with crawls, textual information, or other means to the extent technically feasible.

Stations still have to comply with accessibility of programming, providing emergency information under 47 C.F.R. § 79. (link??). Additionally, stations must appoint an ENT coordinator to monitor process and provide training to all news staff.

 

+ FCC Quality Deadlines:

All quality standards other than ENT Enhancements: January 1, 2015

ENT enhancements: June 30, 2014

 

+ The Future - Be Prepared:

FCC Further Notices 2/20/14 Proposals:

  • Impose quality responsibilities more directly on programmers as well as distributors
  • Mandate technical solutions for latency/completeness (e.g.,  VFI’s delay device).
  • Mandate more aggressive pre-broadcast dissemination of information to captioners.
  • Eliminate advertising exemption
  • Require 708 digital caption capabilities
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