Our Five Asks
Contract approved unanimously on October 20, 2026
These are the five recommendations the Campaign for Criminal Justice Transparency brought to Kalamazoo County before the Board of Commissioners approved the new jail phone and video contract. Each one explains what we asked for and why. Under each one, you can see where it landed.
We are requesting that the County establish a publicly accessible and regularly updated transparency process for jail telecommunications agreements and related financial information. This would include the annual publication of telecommunications contract terms, per-minute call rates, fee schedules, ancillary service charges, and any revenue or commission payments received by the County through the contract.
At present, access to this information has been limited. The full terms of the County's 2020 telecommunications contract, including commission structures and payment provisions, were not publicly available through routine disclosure and instead became accessible through a public records request submitted by NowKalamazoo in 2025, approximately five years after the agreement was executed.
Establishing a proactive disclosure process would improve public accessibility to information related to publicly administered telecommunications services and would reduce the need for formal records requests to obtain foundational contract and pricing information. Public availability of these materials would also support greater transparency regarding how telecommunications systems are structured, funded, and administered within the local correctional system.
Where it landed
The full contract was posted publicly with the October 20 agenda, before the vote. That is a big change from 2020, when the terms only came out through a records request five years later.
We would still like to see rates, fees and any money the county receives from the contract published every year.
People leaving jail frequently maintain unused balances in prepaid telecommunications accounts associated with jail phone and communication services. In many cases, individuals and their families are unaware that these funds may be subject to inactivity or dormancy policies that can result in the forfeiture of remaining balances after a specified period of nonuse. Because this information is often not communicated clearly or consistently at the time of release, individuals may unknowingly lose money that was deposited by family members or support networks for communication purposes during incarceration.
This concern is not isolated. National litigation addressing industry-wide inactivity forfeiture practices found that, over a ten-year period, approximately $96 million was collected from incarcerated individuals and their families through unused account balance forfeitures. Although that litigation resulted in a federal settlement, implementation of consumer protections and notification practices continues to vary significantly at the local level.
To promote transparency, fairness, and informed decision-making, we recommend that the County establish a formal balance notification and recovery procedure as part of the jail release process. Prior to release, individuals should either:
- Be assisted in recovering or transferring any remaining telecommunications account balance; or
- Receive a clear verbal and written explanation outlining:
- the existence of any remaining balance,
- the applicable inactivity or forfeiture policy,
- the timeframe in which action must be taken, and
- the steps required to reclaim remaining funds.
As part of this process, individuals should be provided an opportunity to acknowledge receipt of this information through a signed disclosure form.
Implementing a standardized notification procedure would represent a low-cost and administratively feasible reform that advances consumer awareness, strengthens institutional transparency, and helps protect individuals and families from preventable financial loss.
Where it landed
This is handled by the jail, not the vendor contract, so it was not part of the vote. On October 20, CCJT asked the Board for every person leaving the county jail to get written instructions on how to recover their balance. We will keep asking.
We are requesting consideration of a contract structure that does not rely on revenue generated from incarcerated individuals and their families through jail telecommunications services. This would include eliminating percentage-based commission payments tied to call revenue, as well as avoiding upfront signing incentives connected to the awarding of the telecommunications contract.
The FCC's updated rules, effective April 6, 2026, establish this as a federal minimum: site commissions are prohibited on new inmate communications contracts. The new contract approved on October 20 (RFP #2026009) is subject to this requirement. What we asked the County to do went one step further: to write that prohibition explicitly into the local contract language as an enforceable term, rather than relying solely on federal compliance mechanisms. Federal enforcement is complaint-driven and can be slow. A contract-level prohibition gives the County its own direct grounds to act if a vendor attempts to introduce commission arrangements during the life of the agreement.
Under the 2020 contract, the County received a substantial percentage of revenue generated from jail phone calls. That arrangement directly impacted the cost of communication services and contributed to local call rates that were significantly higher than those charged within the Michigan Department of Corrections for comparable services provided by the same vendor. Following the removal of commission-based provisions during the Michigan Department of Corrections contract renegotiation process, call rates were reduced substantially. This demonstrates that alternative contract models are operationally feasible and can materially reduce the financial burden associated with communication access for incarcerated individuals and their families.
Where it landed
There is no commission on calls. The contract gave the Sheriff's Office the option to collect 2¢ a minute in cost recovery, about $62,000 a year, and the Sheriff's Office declined it.
The contract does list a one-time $25,000 tech grant. The Sheriff's Office told the Board it may or may not be used. Under the 2020 contract, the county received 80% of phone revenue plus a $325,000 signing payment.
We are requesting that the County write a defined per-minute rate ceiling into the final contract, with a maximum allowable rate set at or below $0.10 per minute for voice calls.
The FCC's updated rules, effective April 6, 2026, establish the federal minimum for a facility of this size. Kalamazoo County Jail, with an average daily population of approximately 500, falls under the Medium Jails tier (350-999 ADP). Under the 2025 IPCS Order, the effective rate cap for audio calls at a facility in this tier is $0.12 per minute. The 2020 contract rate of $0.18 per minute would not meet the requirements of the updated rules if the contract were signed today. The new contract approved on October 20 (RFP #2026009) had to come in at or below that $0.12 federal ceiling.
What we asked the County to do went one step further. The federal ceiling is a maximum, not a target. A rate of $0.12 per minute would still represent a significant cost to families over the life of a contract. We asked the County to push below that ceiling and make $0.10 per minute the maximum allowable rate in the contract itself.
This is an achievable ask. The Michigan Department of Corrections renegotiated its telecommunications agreement with the same vendor that currently serves Kalamazoo County Jail and achieved a rate of $0.0735 per minute, down from $0.14 per minute, following the removal of commission-based provisions. A $0.10 ceiling sits between the federal floor and what the state prison system already pays. It is a reasonable and well-supported benchmark, not an aspirational one.
Without a written rate ceiling in the contract, the vendor may charge rates that comply with the federal cap but still leave families paying more than necessary. A written ceiling in the contract itself is how meaningful cost reductions are locked in for the full contract term.
Where it landed
Phone calls are 7¢ a minute. That is below our 10¢ ask, below the 12¢ federal limit, and below the 7.35¢ Michigan state prisons pay. Video visits are 12¢ a minute. Both rates are written into the contract's pricing schedule.
We are requesting that the County include explicit contractual language within the new telecommunications agreement prohibiting the use of deposit fees, transaction fees, live operator surcharges, and similar ancillary charges associated with communication services.
The FCC's updated rules, effective April 6, 2026, establish this as a federal minimum: ancillary fees of this type are prohibited on new inmate communications contracts. The new contract approved on October 20 (RFP #2026009) is subject to this requirement. What we asked the County to do went one step further: to write that prohibition explicitly into the local contract language as an enforceable term. Federal enforcement is complaint-driven, which means a violation may continue for some time before any federal action is taken. A contract-level prohibition gives the County its own direct grounds to hold a vendor accountable if ancillary fees are charged, independent of any federal process.
These fees operate independently from both per-minute call rates and commission-based revenue structures. As a result, the elimination of commission payments alone would not prevent the continuation of additional service charges that increase the overall cost of communication for incarcerated individuals and their families. Under the 2020 contract, transaction-related fees could substantially increase the effective cost of a call beyond the stated per-minute rate.
Federal regulatory agencies have also identified concerns regarding the transparency and disclosure of ancillary telecommunications fees within correctional communication systems, including circumstances in which consumers were not provided clear or timely notice regarding the charges being assessed prior to payment. Absent specific contractual restrictions at the local level, ancillary fees may continue under a future agreement regardless of whether broader commission structures are modified or eliminated.
Where it landed
The contract's pricing lists no deposit, transaction or live operator fees, and federal rules now ban them. The contract does not include its own written ban, which was the extra step we asked for.
Federal rules that took effect on April 6, 2026, already prohibit commissions and ancillary fees in new contracts. With those practices now off the table, a rate ceiling of $0.10 or below is both reasonable and achievable. At the same time, federal regulations governing this industry have been repeatedly challenged, delayed, and subject to changing interpretations. Simply stating that a vendor will comply with applicable federal law does not provide families with the certainty they deserve. That is why we asked for these protections to be written explicitly into Kalamazoo County's contract itself, creating clear, local standards that are transparent and enforceable regardless of future changes at the federal level. We were not asking for anything extraordinary. We asked for a contract that reflects what families in Kalamazoo County can realistically afford while preserving the relationships that help people successfully return to the community.