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The Washington Connection 12-18-19

Welcome to the Washington Connection, the legislative and information service of the American Council of the Blind.  The Washington Connection is brought to you by the ACB national office. If you have any questions or comments on the information provided, don’t hesitate to contact us and ask to speak with Claire Stanley or Clark Rachfal.

The Washington Connection is updated any time we have new information to share with you. The following articles are available as of December 18, 2019. Messages 2, 4 and 5 are new.

Thank you for calling the Washington Connection.

Call to Action! Tell Congress to Support H.R. 4129, and Provide Coverage for Low Vision Devices

 

Representatives Carolyn Maloney (D-NY) and Gus Bilirakis (R-FL) introduced the Medicare Demonstration of Coverage for Low Vision Devices Act, H.R. 4129! This bill is one of ACB’s legislative imperatives this year. Once it becomes law, H.R. 4129 would direct the Center for Medicare and Medicaid Services (CMS) to construct a five-year pilot program for the coverage of low vision devices. Other co-sponsors of H.R. 4129 include Reps. Steve Cohen (D-TN), Adam Schiff (D-CA), and Ann Wagner (R-MO).

Reps. Maloney and Bilirakis recirculated a communication to all their colleagues in the U.S. House about supporting this legislation, and it is important that our members hear from us about this bill as well. Included below is the legislative imperative from this year’s legislative seminar.

ACB encourages all members to contact their members of Congress to support H.R. 4129!  Please update the ACB national office on your outreach by sending a message to advocacy@acb.org.

To contact your senators or representatives, call the U.S. Capitol switchboard at (202) 224-3121, and ask to be connected to the senators and representatives for your state. Or visit www.senate.gov to find your senators’ contact information. To locate your representatives, visit www.house.gov/representatives.

Talking Points:

  • Ask your representative to co-sponsor H.R. 4129, the Medicare Demonstration of Coverage for Low Vision Devices Act, and ask your senators to introduce a companion bill to H.R. 4129.
  • This legislation would provide greater access to low vision devices for Americans with vision loss, and allow them to live more independent and integrated lives in their communities.
  • This demonstration of coverage would provide quantifiable data for the need and cost of CMS coverage for low vision devices.
  • This bill is supported by: American Council of the Blind; American Foundation for the Blind; Aira; Blinded Veterans Association; National Association for the Employment of People who are Blind; National Industries for the Blind; OrCam; & Vision Serve Alliance.

Secure Independence for Seniors and Medicare Beneficiaries Legislative Imperative

Background

In November of 2008, the Centers for Medicare and Medicaid Services (CMS) promulgated a regulation that has had a detrimental impact on the lives of countless individuals who are blind or visually impaired. The Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Acquisition Rule contains a provision entitled “Low Vision Aid Exclusion” which states that all devices, “irrespective of their size, form, or technological features that use one or more lens to aid vision or provide magnification of images for impaired vision” are excluded from Medicare coverage based on the statutory eyeglass exclusion. ACB believes this extremely restrictive reading of the eyeglass exclusion has resulted in the denial of vital assistive devices for seniors and other Medicare beneficiaries that offers solutions for sustaining independence in the home.

This proposal has had a significant impact on beneficiaries with vision impairments who depend on assistive technology that incorporates one or more lenses to aid in their vision. The expansion of the eyeglass exclusion has prevented access to devices such as handheld magnifiers, video monitors, and a wide array of technologies that utilize lenses to assist individuals in overcoming the obstacles impeding their independence. These tools are often essential for individuals with low vision who, without the aid of assistive technology, cannot read prescriptions, medicine bottles, and other important materials containing content that is vital to their personal health and safety.

In short, these devices allow individuals with low vision to live independently and safely. Such a poor regulatory policy serves as a pre-emptive and unwarranted coverage denial for any new technology designed to assist individuals with vision loss. Knowing its influence in the medical devices marketplace, innovation and competition will be curtailed if Medicare continues to maintain this coverage exclusion. The unwanted side effects include sacrificing personal independence for more costly residential assistive living, which in the long run ends up putting greater strain on our entitlement programs.

Call for Action

ACB urges the House of Representatives and Senate to re-introduce the Medicare Demonstration on Coverage of Low Vision Devices Act. First introduced as H.R. 729 in the 114th Congress, this legislation had bipartisan support and is one of many workable solutions that should be part of the current healthcare discussion in the 116th Congress.  The bill was reintroduced as H.R. 2050 in the 115th Congress in 2017.

This legislation would evaluate, through a five-year national demonstration project administered by the Department of Health and Human Services, the fiscal impact of a permanent change to the Social Security Act. This legislation would allow reimbursement for certain low-vision devices that are the most function-rich that sustain daily independent living. The devices would be considered durable medical equipment.

Individuals will be eligible to participate in the demonstration project only after completing a clinical evaluation performed by an ophthalmologist or optometrist who would then deem a low-vision device as medically necessary. The data from the demonstration would provide valuable insight into how the eyeglasses exclusion impacts independence for senior citizens and other Medicare beneficiaries. As Americans continue to live longer into their retirement, the Centers for Disease Control (CDC) projects through their Vision Health Initiative (VHI) that severe vision loss will be a leading chronic health condition for the next thirty years, based on an increasingly aging population and demographic changes in our country. According to CDC’s VHI, blindness increases the incidence of other chronic health conditions, depression, and morbidity. Therefore, it is vital that Congress identify solutions that can sustain quality of life as Americans get older.

 

Updated ACB Radio Mainstream Schedule

 

There have been numerous updates made to ACB Radio Mainstream’s schedule. The entire schedule, by day, is as follows.

Sunday:

Keystrokes: midnight-1 a.m.
Cooking in the Dark: 1-2 a.m.
Let's Talk Low Vision: 2-3 a.m.
ACB Braille and E-Forum: 3-5 a.m.
Let’s Talk Low Vision: 5-6 a.m.
ACB Braille and E-Forum: 6-8 a.m.
World of Sports Live: 8-9 a.m.
Keystrokes: 9-10 a.m.
Cooking in the Dark: 10-11 a.m.
World of Sports: 11 a.m.-noon
Keystrokes: noon-1 p.m.
Cooking in the Dark: 1-2 p.m.
Let’s Talk Low Vision: 2-3 p.m.
ACB Braille and E-Forum: 3-5 p.m.
Let’s Talk Low Vision: 5-6 p.m.
ACB Braille and E-Forum: 6-8 p.m.
Sound Prints: 8-9 p.m.
Juno Report: 9-10 p.m.
Keystrokes: 10-11 p.m.
Sound Prints: 11 p.m.-midnight

Monday:

Juno Report: midnight-1 a.m.
Keystrokes: 1-2 a.m.
Main Menu: 2-3 a.m.
On the Inside Track: 3-4 a.m.
Eyes on Success: 4-4:30 a.m.
Speaking Out for the Blind: 4:30-5 a.m.
Main Menu: 5-6 a.m.
On the Inside Track: 6-7 a.m.
Eyes on Success: 7-7:30 a.m.
Speaking Out for the Blind: 7:30-8 a.m.
Sound Prints: 8-9 a.m.
Juno Report: 9-10 a.m.
Keystrokes: 10-11 a.m.
Sound Prints: 11 a.m.-noon
Juno Report: noon-1 p.m.
Keystrokes: 1-2 p.m.
Main Menu: 2-3 p.m.
On the Inside Track: 3-4 p.m.
Eyes on Success: 4-4:30 p.m.
Speaking Out for the Blind: 4:30-5 p.m.
Main Menu: 5-6 p.m.
On the Inside Track: 6-7 p.m.
Eyes on Success: 7-7:30 p.m.
Speaking Out for the Blind: 7:30-8 p.m.
ACB Advocacy Update: 8-8:30 p.m.
News Reel Sampler: 8:30-9 p.m.
Council Connection: 9-10 p.m.
iACast Technology Show: 10-11 p.m.
ACB Advocacy Update: 11-11:30 p.m.
News Reel Sampler: 11:30 p.m.-midnight

Tuesday:

Council Connection: midnight-1 a.m.
iACast Technology Show: 1-2 a.m.
World of Sports Live: 2-3 a.m.
In Perspective: 3-4 a.m.
Cooking in the Dark: 4-5 a.m.
World of Sports: 5-6 a.m.
In Perspective: 6-7 a.m.
Cooking in the Dark: 7-8 a.m.
ACB Advocacy Update: 8-8:30 a.m.
News Reel Sampler: 8:30-9 a.m.
Council Connection: 9-10 a.m.
iACast Technology Show: 10-11 a.m.
ACB Advocacy Update: 11-11:30 a.m.
News Reel Sampler: 11:30 a.m.-noon
Council Connection: noon-1 p.m.
iACast Technology Show: 1-2 p.m.
World of Sports Live: 2-3 p.m.
In Perspective: 3-4 p.m.
Cooking in the Dark: 4-5 p.m.
World of Sports Live: 5-6 p.m.
In Perspective: 6-7 p.m.
Cooking in the Dark: 7-8 p.m.
Let’s Talk Low Vision: 8-9 p.m.
ACB Braille & E-Forum: 9-11 p.m.
Let’s Talk Low Vision: 11 p.m.-midnight

Wednesday:

ACB Braille & E-Forum: midnight-2 a.m.
ACB Advocacy Update: 2-2:30 a.m.
ACB Reports: 2:30-3 a.m.
Tech Talk from Accessible World: 3-4 a.m.
Sound Prints: 4-5 a.m.
ACB Advocacy Update: 5-5:30 a.m.
ACB Reports: 5:30-6 a.m.
Tech Talk from Accessible World: 6-7 a.m.
Sound Prints: 7-8 a.m.
Let’s Talk Low Vision: 8-9 a.m.
ACB Braille & E-Forum: 9-11 a.m.
Let’s Talk Low Vision: 11 a.m.-noon
ACB Braille & E-Forum: noon-2 p.m.
ACB Advocacy Update: 2-2:30 p.m.
ACB Reports: 2:30-3 p.m.
Tech Talk from Accessible World: 3-4 p.m.
Sound Prints: 4-5 p.m.
ACB Advocacy Update: 5-5:30 p.m.
ACB Reports: 5:30-6 p.m.
Tech Talk from Accessible World: 6-7 p.m.
Sound Prints: 7-8 p.m.
Main Menu: 8-9 p.m.
On the Inside Track: 9-10 p.m.
Eyes on Success: 10-10:30 p.m.
Speaking Out for the Blind: 10:30-11 p.m.
Main Menu: 11 p.m.-midnight

Thursday:

On the Inside Track: midnight-1 a.m.
Eyes on Success: 1-1:30 a.m.
Speaking Out for the Blind: 1:30-2 a.m.
ACB Braille and E-Forum: 2-4 a.m.
Juno Report: 4-5 a.m.
ACB Braille and E-Forum: 5-7 a.m.
Juno Report: 7-8 a.m.
Main Menu: 8-9 a.m.
On the Inside Track: 9-10 a.m.
Eyes on Success: 10-10:30 a.m.
Speaking Out for the Blind: 10:30-11 a.m.
Main Menu: 11 a.m.-noon
On the Inside Track: noon-1 p.m.
Eyes on Success: 1-1:30 p.m.
Speaking Out for the Blind: 1:30-2 p.m.
ACB Braille and E-Forum: 2-4 p.m.
Juno Report: 4-5 p.m.
ACB Braille and E-Forum: 5-7 p.m.
Juno Report: 7-8 p.m.
ACB Advocacy Update: 8-8:30 p.m.
ACB Reports: 8:30-9 p.m.
Tech Talk from Accessible World: 9-10 p.m.
Sound Prints: 10-11 p.m.
ACB Advocacy Update: 11-11:30 p.m.
ACB Reports: 11:30 p.m.-midnight

Friday:

Tech Talk from Accessible World: midnight-1 a.m.
Sound Prints: 1-2 a.m.
Council Connection: 2-3 a.m.
On the Inside Track: 3-4 a.m.
Cooking in the Dark: 4-5 a.m.
Council Connection: 5-6 a.m.
On the Inside Track: 6-7 a.m.
Cooking in the Dark: 7-8 a.m.
ACB Advocacy Update: 8-8:30 a.m.
ACB Reports: 8:30 – 9 a.m.
Tech Talk from Accessible World: 9-10 a.m.
Sound Prints: 10-11 a.m.
ACB Advocacy Update: 11-11:30 a.m.
ACB Reports: 11:30 a.m.-noon
Tech Talk from Accessible World: noon-1 p.m.
Sound Prints: 1-2 p.m.
Council Connection: 2-3 p.m.
On the Inside Track: 3-4 p.m.
Cooking in the Dark: 4-5 p.m.
Council Connection: 5-6 p.m.
On the Inside Track: 6-7 p.m.
Cooking in the Dark: 7-8 p.m.
Speaking Out for the Blind: 8-8:30 p.m.
News Reel Sampler: 8:30-9 p.m.
Main Menu: 9-10 p.m.
In Perspective: 10-11 p.m.
Speaking Out for the Blind: 11-11:30 p.m.
News Reel Sampler: 11:30 p.m.-midnight

Saturday:

Main Menu: midnight-1 a.m.
In Perspective: 1-2 a.m.
ACB Advocacy Update: 2-2:30 a.m.
ACB Reports: 2:30 – 3 a.m.
Let’s Talk Low Vision: 3-4 a.m.
iACast Technology Show: 4-5 a.m.
ACB Advocacy Update: 5-5:30 a.m.
ACB Reports: 5:30-6 a.m.
Let’s Talk Low Vision: 6-7 a.m.
iACast Technology Show: 7-8 a.m.
Speaking Out for the Blind: 8-8:30 a.m.
News Reel Sampler: 8:30-9 a.m.
Main Menu: 9-10 a.m.
In Perspective: 10-11 a.m.
Speaking Out for the Blind: 11-11:30 a.m.
News Reel Sampler: 11:30 a.m.-noon
Main Menu: noon-1 p.m.
In Perspective: 1-2 p.m.
ACB Advocacy Update: 2-2:30 p.m.
ACB Reports: 2:30-3 p.m.
Let’s Talk Low Vision: 3-4 p.m.
iACast Technology Show: 4-5 p.m.
ACB Advocacy Update: 5-5:30 p.m.
ACB Reports: 5:30-6 p.m.
Let’s Talk Low Vision: 6-7 p.m.
iACast Technology Show: 7-8 p.m.
World of Sports Live: 8-9 p.m.
Keystrokes: 9-10 p.m.
Cooking in the Dark: 10-11 p.m.
World of Sports Live: 11 p.m.-midnight

 

Social Security, SSI and SGA to Increase in 2020

 

Social Security and Supplemental Security Income (SSI) benefits for nearly 69 million Americans will increase 1.6 percent in 2020, the Social Security Administration announced recently.

The 1.6 percent cost-of-living adjustment (COLA) will begin with benefits payable to more than 63 million Social Security beneficiaries in January 2020.  Increased payments to more than 8 million SSI beneficiaries will begin on December 31, 2019. (Note: some people receive both Social Security and SSI benefits.) The Social Security Act ties the annual COLA to the increase in the Consumer Price Index as determined by the Department of Labor’s Bureau of Labor Statistics.

The Substantial Gainful Activity (SGA) level for blind people in 2020 will be $2,110 per month.

 

ACB’s Audio Description Project to Hold Audio Description Institute

 

The 16th Audio Description Institute will be held Saturday, February 22nd through Monday, February 24th, 2020, in conjunction with ACB’s 2020 D.C. Leadership Meetings. The hotel is the Holiday Inn & Suites Alexandria, phone (703) 548-6300.

If you’re working as a freelance description writer or describer for broadcast television, a local performing arts program, or visual art exhibits, or if you’re an experienced audio describer who wants a refresher course, this Institute is for you!

The Institute includes:

  • Three full days of intensive, interactive training;
  • A Monday luncheon will be provided;
  • Each registrant will receive a signed copy of Dr. Joel Snyder’s ACB-published “The Visual Made Verbal: A Comprehensive Training Manual and Guide to the History and Applications of Audio Description.”

The interactive sessions (limited use of lecture, questions/discussion throughout, generous use of media, and individual and group writing exercises) are designed to provide immediate feedback and “give and take,” allowing for adaptation according to a sense of participants’ grasp of the material.  In addition, experienced users of description are a part of the Institute’s faculty, providing an important perspective throughout the sessions. 

Topics include:

  • Audio description history and theory
  • The “Four Fundamentals of Audio Description” ©
  • Active seeing/visual literacy-developing skills in concentration and observation
  • The art of “editing” what you see
  • Vivid language: “The Visual Made Verbal”™ 
  • “Speak the speech, I pray you”-using the spoken word to make meaning   

To register for the Institute, visit http://weblink.donorperfect.com/Feb_2020_ADP_Registration. Space is limited, so don’t delay!

 

Registration Is Now Live for the 2020 D.C. Leadership Meetings

 

Registration is now live for ACB’s Presidents’ Meeting and Legislative Seminar. Register today and join us for what promises to be a fantastic set of meetings!

To register, go to http://weblink.donorperfect.com/DCLeadershipmeeting.

2020 Schedule of Events:
Saturday, February 22: Board Meeting
Sunday, February 23: Affiliate Presidents’ Meeting
Monday, February 24: Legislative Seminar
Tuesday, February 25: Meeting with Legislators on Capitol Hill

Hotel Information:
Holiday Inn & Suites Alexandria - Old Town
Room rates (pretax): $109/night (king/double)
Address: 625 First Street, Alexandria, VA 22314
Phone number: (703) 548-6300
Holiday Inn Old Town Reservations (enter group code “ANC” under more options): https://www.ihg.com/holidayinn/hotels/us/en/alexandria/axehd/hoteldetail

 

­ACB Applauds Supreme Court Decision to Decline Appeal on Domino’s v. Robles Case

 

ADA Applies to Websites

On Monday, October 7, the U.S. Supreme Court declined to hear an appeal on Domino’s v. Robles. The American Council of the Blind (ACB) and its nationwide membership applauds this decision and commends the Supreme Court for their action. The unanimous ruling by the U.S. Court of Appeals for the 9th Circuit made it resoundingly clear that the Americans with Disabilities Act (ADA) applies to websites, and by declining to hear Domino’s appeal, the Supreme Court upholds the civil rights of people who are blind and visually impaired in online commercial settings.

As we celebrate 29 years of the ADA, it is important to note that guidelines and best practices for digital accessibility have existed for decades. The World Wide Web Consortium developed the Website Content Accessibility Guidelines (WCAG), and these guidelines are included in the federal government’s Section 508 standards.

“ACB has worked with numerous companies to seamlessly integrate accessible universal design into their digital offerings; this makes it more difficult to understand Domino’s position that their website is not for customers who are blind and visually impaired. Companies like Domino’s should welcome the flexibility created by these guidelines and standards to implement accessibility in a way that makes their products and services available to all paying customers,” said Eric Bridges, ACB’s Executive Director.

The ADA is not the problem, and weakening civil rights protections for people with disabilities is not the answer. Rather than settling for a quick fix, or attempting to weaken the equal access protections of the ADA, companies should ensure that all Americans have equal physical and digital access to their products and services.

To this end, the American Council of the Blind is prepared to collaborate with Domino’s and other companies to create and implement innovative accessibility and universal design solutions that make their products and services available to all consumers, regardless of ability.

 

Cartwright, McKinley Introduce Bill to Improve Educational Services for Students with Hearing and Vision Disabilities

 

To read this article online, go to https://cartwright.house.gov/media-center/press-releases/cartwright-mckinley-introduce-bill-to-improve-educational-services-for.

Washington — On Oct. 23, 2019, Representatives Matt Cartwright (PA-08) and David B. McKinley (WV-01) re-introduced bipartisan, bicameral legislation to improve educational services for students who are blind, visually impaired, deaf, hard of hearing, or deaf-blind. Senators Ed Markey (MA) and Shelley Moore Capito (WV) introduced companion legislation in the Senate earlier this afternoon.

The Alice Cogswell and Anne Sullivan Macy Act, named after the first deaf student formally educated in the United States and the teacher of Helen Keller, respectively, would strengthen existing requirements of the Individuals with Disabilities Education Act of 1975 (IDEA) to provide the best possible education to students who are blind, visually impaired, deaf, hard of hearing, or deaf-blind. This bill would improve state reporting and evaluating measures for students with hearing and vision disabilities and guarantee that educational resources are appropriately targeted.

“This bill takes decisive steps to ensure that students with hearing and/or vision disabilities have the resources they need to thrive in school,” said Congressman Matt Cartwright. “Only by meeting these students’ unique learning needs can we hope to finally close the achievement gap that exists between them and their hearing and sighted peers.”

“Americans have made great strides since 1975 toward improving the lives of children dealing with hearing and sight disabilities but there is still more work to be done,” Rep. McKinley said. “We need to ensure the nearly-half a million kids with these disabilities have the same opportunity as other children to learn and develop skills. This is a common sense step to ensure we are helping these children.” 

Specifically, the Cogswell-Macy Act would amend the Individuals with Disabilities Education Act of 1975 (IDEA) by:

  • requiring states to identify and evaluate children who are deaf, hard of hearing, blind, visually impaired, or deaf-blind;
  • expanding knowledge about the scope and quality of special education and related services provided to students who are deaf, hard of hearing, blind, visually impaired, or deaf-blind;
  • encouraging states to conduct strategic planning that guarantees all students who are deaf, hard of hearing, blind, visually impaired, or deaf-blind receive the specialized instruction and services they need; and
  • increasing the U.S. Department of Education’s responsibilities to monitor and report on states’ compliance with requirements relating to specialized instruction and services for students who are deaf, hard of hearing, blind, visually impaired, or deaf-blind.

The bill is supported by over 75 organizations including, the Conference of Educational Administrators of Schools and Programs for the Deaf (CEASD) and the National Association of the Deaf.

“School systems have been required to appropriately serve deaf and hard of hearing students since IDEA was passed, however, many gaps in services remain,” said David Geeslin, the President of the Conference of Educational Administrators of Schools and Programs for the Deaf (CEASD). “Deaf and hard of hearing students can achieve high levels when their language, communication, and educational needs are addressed. The Alice Cogswell and Anne Sullivan Macy Act will help ensure that personnel and resources are available to support the success of these students.”

"In our country of opportunity for all, the Cogswell-Macy Act is a powerful bill that truly ensures opportunity and success for all children particularly those who are blind or visually impaired and those who are deaf or hard of hearing,” said Howard Rosenblum, Executive Director of the National Association of the Deaf. “The National Association of the Deaf asks all legislators to join in a bipartisan show of support for all of these children.” 

Other organizations endorsing this bill include: American Association of the DeafBlind, American Council of the Blind, American Foundation for the Blind, American Society for Deaf Children, Cerebral Palsy and Deaf Organization, Children's Center for Communication/Beverly School for the Deaf, Deaf Focus, DeafBlind Citizens in Action, National Association of the Deaf, National Coalition on Deafblindness, National DeafBlind Intervener Initiative, National Family Association for Deaf-Blind (NFADB), National Intervener Association, Pennsylvania Partnership for the Deafblind, Telecommunications for the Deaf and Hard of Hearing (TDI), and The Global Foundation for Peroxisomal Disorders.

The Cogswell-Macy Act is co-sponsored by: Rep. McKinley (WV-01), Rep. Fitzpatrick (PA-01), Rep. Norton (DC-At-Large), Rep. Pete King (NY-02), Rep. Lujan (NM-03), Rep. Moulton (MA-06), Rep. Moore (WI-04), Rep. Peters (CA-52), Rep. Schakowsky (IL-09), Rep. Schiff (CA-28), and Rep. Swalwell (CA-15).

 

FCC Grants USA Network a Limited Waiver

 

On Monday, Oct. 7, the FCC’s Media Bureau granted a limited waiver of the Commission’s video description rules, requested by NBCUniversal, LLC, on behalf of its wholly owned non-broadcast programming network, USA Network, as long as USA Network airs at least 1,000 hours of described programming each quarter without regard to the number of repeats and describes at least 75 percent of any newly produced, non-live programming that is aired between 6 a.m. and midnight per quarter.  However, the FCC declined to grant NBCUniversal’s proposed safe harbor from the description requirements for other similarly situated, top five non-broadcast networks.

The decision by the FCC is in line with Resolution 2019-04 passed by the ACB membership in convention this summer. This limited waiver will last for two years and does not extend to other non-broadcasters covered by the CVAA. The FCC took into consideration the outreach conducted by NBCUniversal to the disability community, and the high levels of audio-described content previously aired and created by USA Network when granting this petition.

The FCC included a good faith roadmap for other covered entities to pursue if they would like to request a limited waiver similar to USA Network: “Finally, we note that parties seeking relief from the Commission’s video description rules may submit an individual waiver request, which will be evaluated on its own merits, pursuant to the general waiver authority in section 1.3 of the Commission’s rules.  As mentioned in the 2017 Order, the Bureau will look favorably upon waiver requests demonstrating that (1) all pre-recorded programming between 6 a.m. and midnight in the relevant calendar quarter is being described, even if not all of it can be counted toward the rules and (2) the petitioner commits to provide additional hours of video description in calendar quarters other than the one for which it is seeking the waiver, or commits to provide the additional hours of video description in the same calendar quarter but on an affiliated network.”