How to Handle Relay Calls at a Small Business: Menu Tests

Executive Summary

To handle relay calls at a small business, accept the call, address the customer directly, allow the conversation to be relayed, and verify that the customer can complete the same business task through the chosen route. Staff should ask questions separately and allow each response, rather than treating a pause as the end of the call. Department of Justice (DOJ) guidance expressly tells covered businesses to accept relay calls; Minnesota Relay explains why typing or revoicing can extend the conversation. ^{[1] [2]}

The relevant U.S. framework is Title III of the Americans with Disabilities Act (ADA) for covered private public accommodations. Importantly, its own regulation, 28 CFR § 36.303(d)(1), requires automated attendants, voicemail, messaging and interactive voice response systems to provide effective real-time communication with people using specified auxiliary aids and relay services. This is not a rule confined to state and local governments under Title II. Business size does not automatically remove Title III coverage. A successful greeting or a vendor feature list therefore cannot establish that the complete customer interaction is effective. ^{[3] [1] [4]}

This report supplies an uncompleted caller-path test sheet and a staff response card. Owners should recruit a representative relay user or an accessibility practitioner with relevant telephone and relay expertise, then observe realistic tasks through announcement, selection, timeout, transfer, delay, no-answer, voicemail, callback and after-hours paths. World Wide Web Consortium (W3C) guidance supports task-based involvement, varied participants and reporting evaluation limits. ^[5] This report adapts that web methodology, rather than presenting a telephone certification method. Record successful recovery separately from initial failure.

Several numbers need careful interpretation. 711 is a relay access route, not a universal callback method: the FCC's consumer guide excludes specified internet and captioned relay forms from 711 access. 24-hour relay availability does not establish a business's staffing schedule. As of October 2026, autoattendant.io lists $29 monthly for the company and a menu with up to nine options; those are published commercial specifications, not measured accessibility results. The owner decision is whether to keep the current configuration, shorten it, add a usable human route, arrange an effective alternative, or engage a specialist communication service. A separate interaction requiring qualified interpreting needs that service, rather than an assumption that routing a call supplies it. ^{[6] [7] [8]}

Introduction and Background

A customer might telephone to ask whether an item is available, change an appointment, or discuss an invoice. The operational question is whether that task remains achievable when communication passes through a relay assistant and the business routes calls to employees' existing mobiles. Relay is not limited to customers using a text telephone. State guidance describes video relay through a regular telephone at the hearing participant's end, and Speech-to-Speech assistance that repeats a customer's speech when needed. ^{[9] [10]}

Telecommunications relay service (TRS) connects people with hearing or speech disabilities and voice telephone users through communications assistance. Video relay service (VRS) uses an interpreter for a signing telephone user. A text telephone (TTY) supports typed communication; other arrangements and preferences differ. The business's receiving endpoint need not become a video terminal merely because the caller uses VRS. Washington's official guidance explains that relay reaches business associates without specialized telephone equipment. ^{[11] [12]}

This analysis concerns U.S. private businesses that are covered public accommodations, rather than every organization with a telephone number. DOJ's small-business primer describes businesses providing public goods and services within the covered categories. Title II covers state and local government services and must be considered separately. ^[11] Federal procurement guidance also has its own scope: the Access Board's telecommunications tutorial addresses federal agencies' Section 508 responsibilities, not a general private-business procurement mandate. ^{[1] [13]}

The report separates published requirements, practical advice, and unmeasured outcomes. No live relay test of a vendor, customer number, employee mobile, or fallback was performed. The proposed worksheet is a way to obtain that evidence. W3C recommends reporting scope and cautions against overgeneralization. ^[5] Apply that caution to the proposed telephone evaluation.

The output of a test should be a specific owner decision: which route works for the tested task, which employee owns recovery, and what must change before the route is relied upon. A blank result is an unknown, not an accessibility finding.

Key Changes: From Accepting the Call to Completing the Task

Apply the actual Title III telephone rule

These are recommended operational changes, not claims that a new law took effect. Title III already addresses automated telephone systems. Its telecommunications provision explicitly includes automated attendants, voicemail and messaging, and interactive voice response (IVR), the systems that receive spoken or keypad responses and direct callers. The requirement is effective real-time communication with users of covered auxiliary aids and approved relay systems. ^[3]

The same regulation separately requires responding to TRS calls in the same manner as other telephone calls. These duties explain why training an employee to recognize a relay introduction is necessary but does not answer whether the menu, transfer or fallback works. A caller who reaches the greeting but cannot reach an employee has not demonstrated a usable complete path. ^[3]

Acceptance, routing, and task completion should therefore be separate observations. Acceptance records whether staff continue the call. Routing records whether the selected destination and fallback remain reachable. Completion records whether the customer obtains the intended business outcome. These are proposed operational categories, not official legal scores.

Choose communication around the person and the interaction

Appropriate assistance depends on the individual's communication method and the nature, length, complexity and context of the exchange. Consultation is useful, but the selected method must actually produce effective communication. Email, voicemail or a written transcript cannot be assumed sufficient merely because they contain text. Their usefulness must be assessed for the person and the task. ^[14]

For example, a short exchange of written notes may work for a simple retail question, according to DOJ guidance. That observation does not establish that written communication works for a detailed consultation or for every customer. Similarly, knowing that someone is deaf does not establish that sign-language interpreting is their preferred or effective method. ^{[1] [11]}

Extend staff responsibility through the fallback

An employee's role should include checking what happens after an unsuccessful transfer, rather than merely selecting another extension. The National Association of the Deaf (NAD) identifies interactive menus, messaging, holding, forwarding and transfers as relevant telephone features in its functionally equivalent telecommunications position statement. That is user-organization advocacy, not a test result for any particular product. ^[15]

The owner should name a fallback owner, train the people who receive forwarded calls, and keep instructions available where those people answer. Treating accessibility as a single menu setting misses the human part of the customer journey.

Implementation Considerations and Process Changes

Map the complete caller journey

The following diagram represents a common assisted call path. Relay forms differ; it does not imply that every captioned or speech-assisted call follows identical steps. VRS can connect a signing customer with an employee using an ordinary telephone, while Speech-to-Speech assistance can repeat difficult speech. ^{[9] [10]}

Customer using a chosen relay service
                |
     Communications assistant or interpreter
                |
        Business announcement and menu
                |
       Selected employee's mobile
                |
    Answer and complete the customer's task
                |
  If unresolved: named person owns the fallback
                |
   Reconnection, voicemail or agreed callback

Where appropriate: a reachable alternative contact route
or a separately arranged specialist communication service

Map the alternative route alongside the telephone route. Record its location, who monitors it, and how an unresolved request gets back to a person. National Deaf Center guidance recommends making accommodation-request information and contact details easy to find. Publishing an email address without assigning responsibility is not a completed operational design. ^[16]

Before testing, capture the actual greeting, menu choices, response windows, ring destinations, schedule and fallback. Ask the vendor which behaviors are configurable and which are fixed. Then compare that account with observed calls. W3C warns that automated web evaluation tools cannot assess all accessibility aspects; this report adapts the underlying need for human judgment to telephone testing, without treating web tools as telephone evaluators. ^[4]

Configure an answerable mobile route

Assign an employee who is available during the advertised service period, and a backup for missed calls. Inspect each receiving mobile's actual behavior during the drill, including unanswered calls and any screening that intervenes. These are test conditions to investigate, not claims that a particular carrier or handset blocks relay traffic. State guidance confirms that a hearing participant can use a standard wired or wireless telephone for relay calls. ^[2]

Do not design the process around the assumption that every call begins with an identifiable relay announcement. North Carolina's staff guide says introductions vary and that a short initial delay can occur. Accordingly, train staff to give a caller time to respond and to listen for the interaction, rather than demanding a particular opening formula. ^[17]

Useful preparation steps are:

• Name the destination owner: identify the person accountable for each menu route.
• Check the backup: document what the caller experiences when that person is busy or unavailable.
• Prepare transfer language: tell the customer what is about to happen and who should answer.
• Publish access contact details: make the monitored route for assistance easy to locate. ^[16]
• Reserve realistic conditions: test the mobile and schedule settings that staff actually use.
• Keep test notes minimal: record the path and outcome, rather than unnecessary details of the customer's communication.

Accessibility testing should observe the customer experience, not infer success from an administrator seeing a call in a dashboard.

Relay Call Training and a Staff Response Card

What staff may hear

Depending on the service, staff may hear an assistant voicing typed words, a video interpreter, or an assistant repeating speech. California's relay program describes Speech-to-Speech choices ranging from repeating difficult words to repeating every word. Staff should follow the interaction being used rather than impose a script designed for another relay form. ^[10]

Pauses can be part of the conversation. National Deaf Center advises waiting for the full message and allowing response time when interpreting or captions introduce delay. Minnesota Relay explains that relaying by typing or revoicing can take longer than an ordinary voice call. Overlapping questions may therefore make a simple request harder to complete. ^{[16] [2]}

Address the customer in ordinary first-person language: “How can I help you?” or “Which appointment would you like to change?” Wisconsin's VRS description specifically describes first-person conversation. Clear speech at a moderate pace is preferable to yelling; the Hearing Loss Association of America recommends repetition or rephrasing when needed. ^{[9] [18]}

Staff response card: keep beside the answering instructions

The following card is a proposed training aid. It turns official relay-handling guidance into actions for employees who answer forwarded business calls; it does not supply a universal timing threshold or an interpretation of every legal obligation.

• Answer and stay on the call. State the business name and your name. Continue the interaction as a customer call, consistent with DOJ's relay-acceptance guidance. ^[1]
• Address the customer directly. Use “you” and “I.” Do not ask the assistant to “tell the customer” what you can say to the customer yourself. ^[17]
• Ask what assistance is useful. For example: “What would help us communicate about this request?” Follow the person's stated preference instead of guessing from a disability label. ^[16]
• Allow each turn to finish. Ask a question, wait for the response, and then continue. Avoid stacking several questions together. ^[2] Follow the relay operator’s turn-taking directions. For relay methods that use this convention, say “go ahead” when required to signal that you have finished speaking. ^[17]
• Use clear, manageable language. State the appointment, item or amount plainly. Repeat or rephrase a message that did not get through.
• Explain a transfer before making it. Give the destination and proposed fallback, then check whether the customer wants to continue that way.
• Verify callback preference. Ask which number or service-specific method to use and whether a message is useful. California Connect documents direct dialing of assigned VRS and IP Relay numbers, but that does not make every relay callback identical. ^[10]
• Own the unresolved path. Tell the customer who will act next. Record the routing problem and agreed follow-up without unnecessary personal information.

The card should be practiced through actual customer tasks. It should also distinguish relaying a telephone call from supplying interpreting for another interaction. The National Deaf Center explicitly says VRS should not replace video remote interpreting (VRI). Scheduling a separate meeting may require arranging an appropriate service, not assuming the relay connection continues to cover it. ^[19]

A Task-Based Caller-Path Test Sheet

Recruit and brief the tester

Invite a representative relay user, or a qualified accessibility practitioner who understands the intended relay methods, to attempt realistic tasks. Agree the tasks, contact method and observation process beforehand. W3C recommends task-based involvement and varied user input. ^[5] This report adapts its web method; the proposed telephone worksheet is not an official standard.

Match the participants to the customer population without expecting someone to represent everyone with the same disability. NAD identifies users with varied needs, including DeafBlind people and people with additional disabilities. A test limited to a single signing video-relay caller cannot establish outcomes for text, captioned or speech-assisted callers. ^[15]

Ask the tester to accomplish a task rather than merely confirm that the greeting is audible to the assistant. Suitable tasks include asking about availability, changing a booking and finding the person responsible for an invoice. Use test information agreed in advance, and do not ask an employee to simulate a deaf customer's experience by guessing what the assistant might do. The following preparation checklist is part of the proposed workflow:

• Agree the task: define the business outcome the tester should obtain.
• Identify the method: record which relay arrangement the participant chooses.
• Capture the configuration: retain the greeting, destinations and schedule used in the drill.
• Brief the observer: collect events and outcomes without coaching the employee through them.
• Agree intervention: decide how the participant can stop or report a difficult path.
• Arrange the debrief: ask both caller and employee what reached them and what remained unresolved.

Run the worksheet under actual routing conditions

Table 1 is the proposed caller-path test sheet. Its observed-result fields are intentionally blank. It includes related checks within a row so an owner can use the sheet without turning it into a product feature checklist. The Access Board's historical federal telecommunications tutorial explains how menu response limits can become barriers while an assistant conveys the prompt and answer. That technical observation informs the test; its federal scope does not turn the worksheet into a private-business Section 508 audit. ^[13]

Interpret the sheet as task evidence, rather than a count of menu features. A connection without a completed request should remain unresolved. Conversely, a working recovery path deserves its own note so the owner knows what helped. W3C recommends documenting evaluation scope. ^[5] For this proposed telephone test, record the service, task, menu version, conditions and participant profile alongside results.

Observe the entire delay or missed-call path without prompting staff unless intervention is needed to end the test. Ask the tester afterward what reached them, what required repetition, and which alternatives were usable. The purpose is to expose gaps that an administrator cannot see from configuration alone.

Decide what counts as a usable result

Use the labels completed, completed with recovery, unresolved, and not tested. These are proposed local reporting labels, not a standardized rating. Preserve the underlying observation: for example, “the employee answered, explained the transfer, and the customer obtained the booking change.”

Set the decision around the customer task and communication needs. Title III's aid-selection provision considers the interaction's complexity and the person's method of communication; it does not justify declaring an entire system accessible from one successful call. ^[14]

Choosing Fixes and Testing Vendors

Change the part that the observation identifies

Where the menu response window prevents a useful choice, ask about shorter announcements, repeat options, configurable timing and an answerable human route. Where the transfer reaches an unavailable person, change the assignment or fallback. These are proposed remedies to test, not guarantees that any setting resolves every relay user's needs. The Access Board's explanation of relay-related menu timing supports examining the actual prompt-response sequence. ^[13]

Table 2 compares configuration and service choices, rather than ranking vendors by unmeasured accessibility. The direct routing provider appears as a row because it sells the kind of menu-and-mobile path being evaluated. The published specifications are separated from the tests still needed.

The table supports a diagnosis, not a blanket purchasing recommendation. Changing the menu cannot substitute for arranging necessary communication assistance. The business may need an aid or service matched to the interaction; a customer should not be required to bring someone to interpret simply to make the transaction possible. ^[14]

An answering service can provide staff on the business's behalf, but any such choice still needs the same relay-handling and caller-task checks. A routing service leaves the human answering responsibility with the customer's team. A contact-centre platform may offer additional operational controls; the presence of controls alone does not measure accessibility.

Questions to put to the vendor and the owner

Separate questions the vendor can answer about configuration from questions that require an observed call:

• Timing: which prompt, silence, response and voicemail limits can be changed?
• Recovery: what happens after no input, an invalid selection or a repeated attempt?
• Transfer: can the caller reach an employee while retaining the original interaction?
• No answer: which configured route actually receives the call next?
• Schedule: which greeting and destinations apply outside business hours?
• Evidence: what test conditions support any compatibility claim, and do they match this business?
• People: who trains the receiving employees and completes follow-up?

For a separate meeting that requires interpreting, choose the appropriate professional service. Wisconsin distinguishes remotely interpreted in-room communication from a VRS telephone call. DOJ also describes VRI as a fee-based interpreting arrangement. Neither distinction makes VRI suitable for everyone; the individual and interaction still matter. ^{[9] [11]}

Data Analysis and Evidence

The available evidence supplies regulatory text, relay instructions and commercial specifications, rather than a measured accessibility pass rate for mobile-routed small businesses. This report generated no live-call performance data. Its strongest quantitative contribution is therefore a disciplined separation of documented numbers from observations an owner must collect.

Table 3 summarizes the numbers and limits that can be supported, together with the operational measurements that remain unknown.

The distinction matters because service availability, routing capacity and effective communication answer different questions. A relay operator being available says nothing about whether an employee is on duty. A published menu limit says nothing about whether a caller can receive the options and respond. Likewise, a message delivered to a mailbox does not show that the customer received the answer.

An owner can add measured elapsed times after testing, but should retain the underlying conditions. Report the relay method, task, route, business schedule and recovery alongside each time. Avoid a single average that combines fundamentally different interactions, and avoid calling a small sample a universal pass rate. W3C recommends reporting parameters and limiting generalizations. ^[5] Its scope remains web evaluation; this report adapts that reporting method.

The numerical access guidance also affects callbacks. California Connect explains direct dialing of assigned VRS and IP Relay numbers, while the FCC guide lists forms that cannot be reached through 711 access. Staff should obtain the individual's specific callback method instead of automatically dialling 711 for every returning call. ^[10]

The appropriate owner output is a measured local record: completed tasks, failures requiring changes, and paths still untested. There is no evidence here for an invented national small-business failure rate, vendor comparison score, or certified accessibility result.

Implications and Future Directions

For a small mobile-routed team, the durable improvement is an owned process: the menu owner controls the announced route, employees know how to continue a relay conversation, and a named person resolves missed calls. Training should preserve ordinary customer interaction while allowing the relay method to work. Minnesota advises asking questions individually; Wisconsin describes first-person VRS conversation. ^{[2] [9]}

Re-test after changes to the business number, provider, menu, schedule, receiving mobiles or fallback assignments. This is a proposed change-control practice, not a cited statutory interval. Repeat the tasks affected by the change, and include the fallback when the change affects availability. Keep the previous worksheet so the owner can see whether the modification actually improved the caller's outcome. A proposed maintenance checklist keeps those responsibilities visible:

• Number or provider change: repeat incoming selection, transfer and callback tasks.
• Menu or timing change: repeat announcement, selection and recovery tasks.
• Schedule change: repeat the affected business-hours and after-hours paths.
• Employee or mobile change: repeat receipt, turn-taking, no-answer and follow-up tasks.

Broaden participation when the customer population or communication methods warrant it. NAD's description of underserved users and National Deaf Center's account of varied preferences support avoiding an assumption that one relay method covers everyone. Recruitment should seek relevant experience without asking a participant to represent an entire disability category. ^{[15] [16]}

Where a complex interaction needs qualified interpreting, the owner should plan that service and its backup rather than treating a phone menu as the complete solution. NAD's definition focuses on the interpreter's ability to convey the communication accurately, effectively and impartially, including specialized vocabulary. ^[8]

The future evidence worth collecting is practical: which task was completed, under which communication method, through which route, and after which correction. Accumulating these records can guide configuration and training. It cannot turn a small internal drill into a universal technology certification.

Frequently Asked Questions (FAQs)

How should an employee answer a telecommunications relay call?

Identify the business, remain on the call, address the customer directly, and allow responses to be relayed. Ask questions individually rather than stacking them. The business-acceptance rule and Minnesota's conversation guidance support treating this as ordinary customer service with appropriate turn-taking. ^{[3] [2]}

Can a private business use an automated attendant for relay calls?

Title III explicitly addresses automated attendants and related telephone systems. A covered business's system must provide effective real-time communication for specified auxiliary-aid and relay users. The practical question is whether the configured menu, employee route and fallback achieve that outcome in the relevant interaction. ^[3]

Does a relay customer always need a sign-language interpreter?

No. National Deaf Center describes communication preferences that include speaking, signing, typing and writing. California's relay program also describes Speech-to-Speech assistance. Ask about effective communication for the task rather than assigning a method from the person's disability. ^{[16] [10]}

Is voicemail or email an adequate fallback?

It depends on the person and interaction. The selected method must result in effective communication. Test whether the individual can use the fallback and whether an accountable employee completes the request; do not declare sufficiency from the presence of text or a stored recording. ^[14]

Does a completed test prove legal compliance?

The proposed sheet documents particular tasks and conditions. W3C cautions against generalizing limited studies. ^[5] Treat these results as evidence for local improvement, keeping unresolved and untested paths visible, rather than a legal certificate or a product-wide accessibility conclusion.

Conclusion

Handling relay calls requires a receiving team that continues the customer interaction, a usable route to the right person, and a fallback that carries the task forward. Covered businesses must respond to relay calls as they do to other calls, and Title III separately addresses effective real-time communication through automated telephone systems. These are reasons to evaluate the full caller journey rather than stop at recognition of a relay introduction. ^[3]

The owner can use the staff card to train employees and the caller-path sheet to obtain evidence from a representative user or a practitioner with relevant expertise. Record what the caller experienced, which employee owned the next action, and whether the request was completed. Keep not tested distinct from a successful outcome. W3C supports task-based involvement and reporting evaluation limits. ^[5] Those principles inform this adapted method.

When a path remains unresolved, change the part identified by the observation: the announcement, response window, available human route, fallback assignment or communication method. Match any alternative to the individual and the interaction, and arrange qualified assistance where necessary. The selected method must be effective, rather than merely convenient to administer. ^[14]

The resulting decision is concrete: retain a demonstrated route, correct and re-test an unresolved route, or arrange another effective way to complete the customer's task. That record gives a small team an actionable basis for serving relay callers while keeping unmeasured technology claims out of the decision.