FCC’s next regulations should cinch loopholes and address video visitation

In response to the FCC's request for comments, we submitted four analyses of unresolved issues

by Aleks Kajstura, January 21, 2016

In response to the FCC’s call for further comments on their regulations of the prison and jail phone industry, we submitted our analysis of and recommendations on four unresolved issues:

• Single Calls: we explain how the FCC’s attempt to rein in “single call” programs left a significant loophole that can be easily closed.
• Western Union and MoneyGram: we highlight an unintentional loophole in the FCC’s regulation of fee-sharing schemes between the phone companies and money transfer providers, and suggest that the FCC could instead copy Alabama’s solution to the problem.
• Bundling unrelated services: we outline how bundling phone services with unrelated financial and other technology services is creating a growing opportunity for companies to create an end run around the FCC’s current regulations in the short term as well as undermine the FCC’s long-term goals of fostering a self-regulating ICS market through competition.
• Video visitation: we updated the FCC on issues surrounding video visitation, showing that a national consensus has developed acknowledging that the growing trend of video visitation replacing traditional in-person visitation is a major step in the wrong direction and providing 5 recommendations for regulation.

Reply comments are due February 1, and can be submitted online for docket number 12-375.