Almost all programming that is shown on television, with very few exceptions, must be captioned. The 21st Century Video Accessibility Act (CVAA) requires that any program broadcast on television with captions must be captioned when it’s delivered via Internet Protocol (IP) – on the web, on demand, via Apple, Hulu, Amazon, et cetera. Over the last couple of years, the Federal Communications Commission (FCC) has phased in requirements for captioning video clips, and the last benchmark of this requirement is around the corner.
Effective, July 1, 2017, the FCC requires all live and near-live video clips to be captioned for programming delivered via IP. This is very different from the previous two clip requirements, which dealt solely with prerecorded content, and presents its own challenges. Where offline captions, created for pre-recorded programming, are synced to match audio, live captions are often behind. This means that when a programmer clips a live-captioned program, the captions that follow the clip often must be adjusted to match the audio correctly.
While many programmers are already captioning clips – Saturday Night Live clips are captioned for the next days’ broadcast, for example, the new rule represents a significant change to others, especially sports video programmers.
What do you need to know to comply with this last hurdle?
Let’s step back and review the genesis of the imminent FCC mandate, the requirements, and how programmers will be able to meet this new ruling.
The Evolution of the Mandate
In 2014, the FCC modified IP captioning requirements to include clips or excerpts of full-length programming. A program captioned on television must now be captioned when delivered via IP, whether delivered in full or in “clips.” One notable difference between full-length and clipped programming:
- Clipped programming must only be captioned when delivered via a programmer’s website or application.
- Third party platforms, such as Hulu, Yahoo! YouTube or ITunes, are not required to comply with this benchmark, though many are doing so voluntarily.
In January 2016, all direct lift clips of prerecorded content required captions. “Direct Lift” or “straight lift” is a single excerpt of a captioned program, as if a piece of the program were cut and pasted onto a website. The clip includes only one part of a program, with no added material.
In January 2017, “montage” or combination clips required captions. Montage clips are comprised of multiple direct lifts. Some programmers stitch together direct lift clips into one clip as a tease for the full program – these are considered montages.
The final benchmark, effective July 1, requires clips from programming captioned live be captioned when delivered via IP. While direct life and montage clips must be captioned as soon as they are posted, programmers have more time to caption these clips, as detailed below.
Live and Near-Live Programming Defined
Live programming is programming which is broadcast at the same time it is happening, such as live news or sporting events. Many sports programmers will share clips of exciting plays almost immediately after broadcast. The new rule gives these programmers 12 hours to ensure those clips are captioned.
Near-live programming is programming that is performed and recorded less than 24 hours prior to broadcast, such as late night talk shows that are often recorded 6-12 hours before broadcast. The clips rule gives programmers eight hours to ensure those clips are captioned.
It is important to note that video clips – live and near-live – may be distributed online without captions at first, as long as the video is captioned in the timeframe required.
How to Caption Clips for FCC Compliance?
The nature of live captioning means captions are always going to be slightly behind the video. Clipping captions along with video doesn’t ensure the captions will always match the video. Some programmers have tried less-than-reliable Automatic Speech Recognition (ASR) solutions that fall short on quality and accuracy, but the FCC very clearly states that captions delivered via IP must be of equal quality to those broadcast on television.
To ensure timely and accurate captions for live clips, organizations need to rely on humans — highly skilled captioners or transcribers, who have been trained specifically in transcription and video syncing. Best practices inform us that organizations also need technology – robust workflow automation – to ensure caption delivery in full compliance with FCC requirements and timeframes.
Programmers are subscribing to various practices to accommodate the need for quick turnaround captioning of live and prerecorded clips. These include:
- Partnering with a 24/7 operation which guarantees transcription quality, can meet turnarounds of less than six hours and offers API integrations with the programmer’s video distribution platform.
- Receiving a secondary live captioned feed during the broadcast, which allows the producer or captioner to clip and offset captions to match video.
- Investing in a software solution which allows the user to resync the live-captioned text to match video or clip segment.
- Purchasing captioning software and creating the clip captioning from scratch.
Captioning is essential to providing content, information, insight and clarity to a wide range of viewers. In addition to the 50 million Americans with hearing loss, captions are now ubiquitous in bars, gyms and on social media. The FCC clips rule further expands the availability of this valuable service.
If you are interested in learning more about IP caption regulations click here
This article was first published in SVG News.