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NCRA takes an extended look at captioning

Since broadcast captioning became a critical and expected service in this country, solutions related to captioning quality metrics have been elusive and NCRA, captioners, captioning companies, broadcasters, and organizations that represent individuals who are deaf and hard-of-hearing have been unable to find a realistic solution. The solution is universally understood: captions should be readable, understandable, comprehensive, and timely. However, once the conversation of defining and calculating “an error” begins, realistic and workable solutions become less apparent.

It is for this reason that a subcommittee of NCRA’s Captioning Community of Inter­est began to work on best practices related to captioning quality. The members com­prising that group are Carol Studenmund, RDR, CRR, CBC, CCP, Amy Bowlen, RDR, CRR, CBC, Darlene Parker, RPR, Darlene Pickard, RDR, CRR, CBC, CCP, and Tracy Reinke, RPR, CRR, CBC, CCP.

After breaking out roles and responsi­bilities of various players within the cap­tioning cycle, the document lists suggested best practices to captioners, captioning companies, content creators, content dis­tributors, and consumers of captioning services. As a group, we have been reach­ing out to hearing health groups and cap­tioning companies to ask for their feed­back, and we have been very pleased with what we have been hearing from them. The document is not quite finished but we have received some excellent comments from these individuals and organizations which have been incorporated thus far.

Simultaneously, NCRA became aware that the Federal Communications Com­mission was taking a serious look at cap­tioning standards. We were extremely concerned about potential solutions that solely dealt in specific captioning stand­ards. What we wanted to avoid was a situ­ation like the one that has recently become law in Canada, where simple edits a cap­tioner makes to maintain their speed but do not affect the viewer’s understanding of the program have been ruled an error. For example, if a speaker in a program says “they are” and the captioner writes “they’re”, the regulations in Canada rule that an error. We do not buy this line of reasoning and are working on that specific situation now but that will be the subject of a different article.

Essentially, NCRA’s outside legisla­tive counsel, Dave Wenhold, and I went to the FCC’s D.C. headquarters to meet with several representatives from its disability rights division. We explained issues that captioners often face that makes their jobs more difficult, such as lack of adequate preparation time and incomplete prepa­ration materials, a poor audio connec­tion, and a lack of tech support from the content creator or content provider. Ad­ditionally, we noted exactly why specific quality metrics will not improve the level of captioning that viewers receive. We left the meeting confident that if and when the FCC eventually does issue quality stand­ards related to captioning, the interests of our captioners and captioning companies will be well-represented in the final prod­uct.

What comes next? We will be finaliz­ing the captioning quality document that can be found at by reaching out to content creators and con­tent providers and requesting their feed­back on the document. NCRA will also be undertaking a major public relations effort aimed at educating consumers of all captioning services, content creators, content providers, and all other individu­als, companies, and organizations related to captioning about how to provide the best captions for television viewers every­where.

Finally, we will remain in contact with the FCC as they deliberate over caption­ing quality and push toward a workable solution for captioners and individuals who rely on captioning services, as well as pushing all media markets to caption all of their programming.


Adam Finkel is NCRA’s Assistant Director of Govern­ment Relations and can be reached at or 703-556-6272 ext. 159.