Open Letter on Ongoing Discriminatory Barriers to Video Relay Services for Deaf and Hard of Hearing Youth in Immigrant Families

To federal regulators, Video Relay Service providers, disability rights advocates, and the public:

Hands United is a U.S.-based nonprofit organization dedicated to preventing language deprivation among Deaf and hard-of-hearing (DHH) children in immigrant families. We work nationally with families whose children are Deaf, DeafDisabled, DeafBlind, or hard of hearing— many of whom do not yet have full access to spoken language or American Sign Language (ASL) due to linguistic, systemic, and access barriers.

In November 2024, we formally contacted FCC leadership to raise serious concerns about barriers our families were facing when attempting to access federally funded Video Relay Services (VRS), specifically through Purple ZVRS. At that time, families we supported had already been waiting up to five months for services they fully qualified to receive.

As of January 2026, more than a year later, none of these families have received VRS devices or services.

We have received no response to our original correspondence. Meanwhile, the harm continues.

The core concern

Families report that Purple ZVRS requires Deaf minor children—some as young as five years old—to personally contact customer service to verify their eligibility and provide personal information such as addresses and phone numbers. These interactions are conducted with adult representatives and require the child to communicate directly in sign language.

This practice is deeply concerning for several reasons:

• Many of these children are language-deprived, a condition widely recognized as a neurological and developmental emergency.
• Expecting young children—Deaf or hearing—to independently provide accurate personal information is developmentally inappropriate.
• Requiring children to act as intermediaries for complex administrative and legal processes places an undue and inappropriate burden on them.
• Parents who do not speak English are often unable to effectively communicate with customer service representatives through written English or spoken phone calls, leaving families with no viable alternative pathway.

Through discussions with other VRS providers, we understand that requiring Deaf minor children to personally verify eligibility in this manner is not an FCC mandate. Yet families continue to face excessive wait times—often exceeding two hours per attempt—and repeated failed efforts to complete verification.

Prolonged and disproportionate harm to immigrant families

These practices disproportionately impact families whose primary language is not English. Parents are effectively excluded from participating in the process, while their children—who may not yet have full linguistic access in any language—are expected to navigate adult systems alone.

This harm is not marginal. National data indicate that approximately 33% of Deaf and hard-of-hearing children in the United States live in households where English is not the primary language. When access to federally funded telecommunications services is conditioned on written English proficiency—or on a child’s ability to navigate adult administrative systems—these families are systematically excluded from services explicitly intended to ensure communication equity.

What began as months-long delays in 2024 has now become a complete and ongoing denial of access extending into 2026.

VRS is not a luxury. It is an essential telecommunications service. Delays and denials have real consequences: children cannot independently communicate with schools, medical providers, emergency services, or extended family members. For Deaf youth—especially those already at risk of language deprivation—this compounds isolation, inequity, and harm.

Our call to action

1. The elimination of age-inappropriate verification practices that require Deaf minor children to independently engage in customer service and eligibility verification processes.
2. Accessible verification pathways for parents and guardians, including language-accessible support and the ability for adults to complete verification on behalf of their children without relying on the child as an intermediary.
3. Transparency and clarification regarding which verification practices are required by the FCC versus those imposed by individual providers, communicated in accessible formats. This information must not be provided solely in written English, but made available through multiple modalities, including plain-language translations, audio formats, and accessible sign language formats.
4. Immediate provision of devices and services for families who clearly qualify under federal guidelines and have already experienced prolonged delays.
5. Oversight and guidance from the FCC to ensure that VRS providers are not creating discriminatory barriers that disproportionately exclude Deaf youth and immigrant families from federally guaranteed services.

Silence is not neutrality

We raised these concerns formally in November 2024. More than a year later, with no response and no resolution, families remain without access to services they are legally entitled to receive.

Hands United publishes this letter not to assign blame, but to demand accountability, transparency, and child-centered practices that align with the intent and purpose of federally funded Video Relay Service programs.

Deaf children deserve access to communication. Immigrant families deserve equitable treatment. Language deprivation cannot wait.