With the FCC’s proposed restructuring of the VRS rate structure, the fate of sign language interpreters is called into question. Brandon Arthur suggests the path forward requires mobilization and participation.
In some circles, VRS providers are viewed as the newest of the Coyotes on the scene of the sign language interpreting industry. Whether you subscribe to that view or not, what the FCC is ‘seeking public comment’ on (i.e. prepared to do unless there is significant feedback in opposition) will have an impact on you as an interpreter—regardless if your position is “I don’t do VRS.” In the Further Notice of Proposed Rule Making relative to the Structure and Practices of the VRS Program released on Thursday, December 15, 2011, the FCC outlines a dramatic change to the structure of the Video Relay Service.
What is Being Proposed?
Generally, the FCC is seriously exploring the concept of moving VRS providers from the current tiered model of compensation (paid on a per minute basis) to a “per user” model (paid a monthly fee per active user) and having qualified providers bid for one of a small number of contracts to deliver the service.
The reason this is significant to the sign language interpreting industry is because of the 12 eligible VRS providers only one is currently of size and/or operationally efficient enough to operate within the “per user” model. Therefore, only one is currently qualified to bid for a contract. Consequently, the FCC acknowledges the necessity of a phased transition plan to give providers an opportunity to restructure to operate within the new model and to obtain sufficient size to qualify to bid.
What Can Sign Language Interpreters Expect?
These structural adjustments to the industry will necessitate a reorganization of the majority—if not all—of the VRS providers delivering services today. The basis of these reorganizations will be deep cost cutting. This will be done in order to enable providers to deliver services at a deeply reduced rate and position them to redirect monies into expansion activities.
Falling Compensation
The largest cost when providing VRS is the cost of interpreter compensation. The FCC knows it. VRS providers know it. Sign language interpreters know it. Consequently, providers will be seeking to accommodate the new model by implementing more aggressive performance metrics (FCC is considering reducing provider required ASA as part of the restructuring), reducing opportunity for higher paid interpreters (most qualified), and/or compensation adjustments.
Further, a reduction to the number of VRS providers will result in a lack of competitiveness on points of interpreter compensation and benefits, which means the continued declination of hourly rates offered to newly hired interpreters. Worse, it will likely mean an even larger percentage of working sign language interpreters struggling to find work at a livable wage.
Under Valued Credentials
As a result of the immense pressure to fit within the new model, providers will to seek interpreters who command a lower hourly rate. Logically, these will be interpreters who have yet to obtain their national certification, have fewer years of experience, don’t have the skill-set to effectively do the work, or worse will be qualified, certified professionals simply looking to survive. All of which will mean that the investments made by sign language interpreters to seek out and/or maintain their certification will be less valuable than it is today.
How to Brace for Impact?
The most important thing is to acknowledge that further change is coming. In the face of this inevitability, it is necessary for interpreters to mobilize and provide comment to the FCC directly. Further, sign language interpreters must insist that those who are paid and elected to represent them do so immediately.
What should we be lobbying for?
There are a few fundamental things that will help contain the erosion of our position as sign language interpreters within the new model. They are as follows:
Rate Differential for Use of Certified Interpreters
The rate providers are compensated per active user should be subject to a differential for use of nationally certified interpreters. This differential should be calculated according to the percentage of nationally certified interpreters employed by a provider. A differential would ensure the continued interest of providers in employing certified interpreters and protect the spirit of functional equivalency for the end user. Further, it offers a point of competition among providers relative to a “new-to-VRS” user’s election of a default provider.
An example,
Provider A:
Active Users: 10
Monthly Rate Per User: $175.00
Certification Differential: $5.00 (potential per user)
% of Interpreters Certified: 80%
Differential Compensation: $40.00 (8 x $5)
Monthly Total Compensation: $1790.00 ($175 x 10 + $40)
Establishing a certification differential aligns the interests of the Deaf community, sign language interpreter, VRS providers and the FCC. Importantly, it reinforces within the VRS arena that to be nationally certified is a professional commitment and an accomplishment.
Reporting Transparency
There is value in insisting that providers include a line item in their reports that specifically indicates the direct cost, and only the direct costs, associated with the compensation of interpreters. This would more clearly validate the cost of employing interpreters across the VRS arena. Further, it provides clarity at the FCC regarding the costs, the largest of all the costs, associated with the provision of the service. At a minimum, it would mean the cost of interpreters will be clearly considered as the commission works to reduce the overall cost of the TRS Fund.
Qualification Process for Interpreters
As comment is being sought on a qualification process for “new to VRS” users, the FCC should be urged to implement a qualification process for “new to VRS” sign language interpreters. This should take on the form of a set of requirements providers are to comply with prior to having an interpreter sit in a station.
Requirements should include:
-Minimum of 3 years of professional experience
-Credential validation
-40 hour mandatory training on the provision of VRS
Topics might include:
-History of VRS
-Effective provision of the service
-Regulatory compliance
-Cultural sensitivities
-Whistleblower policies
Further, and to address the continued qualification of interpreters working in a VRS setting, providers should be required to provide an annual refresher training on the topics above and confirm a credential check.
The implementation of a qualification process by the FCC would prevent the pilfering of students from ITP/IPP programs, ensure interpreters working in the VRS arena have some professional foundation for their work, and necessitate that some level of training is provided to working interpreters annually. Again, this works in the interest of all VRS stakeholders.
Repeal the Ban on Working from Home
In an effort to create an additional option for providers to reduce costs (i.e. not solely targeting interpreter compensation), the FCC needs to overturn the decision to ban providers from delivering VRS from an at home solution. This gives providers an opportunity to reduce infrastructure costs (i.e. the cost of leases, networks, etc.), which supports their ability to work within the new model. Further, it offers sign language interpreters the opportunity to reduce the costs (i.e. gas, parking, and time) associated with reporting to a center. Equally important, it supports the end user by increasing the supply of available interpreters. Again, this is a win for all VRS stakeholders.
How to Work with Sign Language Interpreters
The FCC is also seeking comment on the concept of their supplementing provider’s outreach activities by campaigning to educate the public on VRS. These activities would be paid for by the TRS fund. If the FCC is to use TRS funds, it is important that this campaign include how to work with sign language interpreters. This will serve to improve the efficiencies of the service (i.e. reduce the costs to the fund) and at the same time provide a better experience for both the end user and the sign language interpreter.
Will History Repeat Itself?
While it is uncomfortable to be faced with continued change on the VRS side of the sign language interpreting industry, it is important that this discomfort not paralyze. Make no mistake, whether you choose to file a comment with the FCC or not, the changes afoot will impact your local sign language interpreter economy. The Community side of the industry is quickly becoming a refuge to interpreters seeking greater stability. This continued migration of interpreters from VRS to Community will serve to establish a new paradigm in most communities—interpreter supply exceeding demand.
The FCC is accepting public comment for the next 45 days (approximately). Let’s not be found past feeling nor reinforce history by allowing these types of fundamental changes to our industry go on without the voice of the sign language interpreter being heard.
Join the mobilization by filing comment directly with the FCC by clicking here. Simply add your name, address, and upload your letter.
Note, comments should be address to:
Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554
As you consider filing comment with the FCC, please review these suggestions.
If you are interested in reading the other comments filed (I found some of them fascinating) on the VRS structural reform, you can find them by clicking here.
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44 Comments on "Will Sign Language Interpreters Remain Silent on FCC VRS Reform?"
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I am definitely planning to comment. Janet Bailey called moving into the VRS business, “crossing paradigm creek”. Many of us crossed and are thoroughly enjoying the other side. Some didn’t make it. Some crossed and found that the other side wasn’t what they thought and went back to community.
I believe that the service is valuable and will hang in there with it, regardless of the FCC changes. (Assuming, of course, that my company survives the changes!)
Lindsey,
Thanks for the comment.
I would agree with the ‘crossing paradigm creek’ concept Janet put forward. I am hopeful that regardless of where people ended up, that they will take time to ensure their voices are heard at the FCC. This type of reform won’t likely come around again and we need to ensure the interests of the sign language interpreter are represented and considered.
I hope you found the links at the bottom of the article helpful in expediting the filing of your comment.
Brandon
I currently work in the UK as a BSL interpreter and have just started working with a company providing VRS services. It is in its infancy in the UK and so it’s really interesting to see the US model and how it is developing. If there is anything I can do to help your campaign please let me know. I would also be interested in contacting you off group as I am hoping to move to the states next year and I am in a quandary about what I can do.
Liana,
Send me a note through the contact page and we can discuss. Happy to point you to as many resources as I am aware of.
You can help by pushing the word out among your colleagues. I think the issues being confront here in the US VRS model will eventually be confronted in the UK model. Hopefully, this will be a lesson your side of the pond can learn from to improve the position of interpreters as your model develops.
Brandon
Sir, I agree with all that is in me that the interpreting profession needs a representative organization, dare I say, a union. Funny thing is that I am a very conservative man, and even I see the need for a interpreter’s union. RID is not in the business of representing interpreters, only credentialing them. We need a national interpreter’s union now more than ever, and given the leanings of the current President and his administration, now is the time to do it. Please feel free to email me, and I will help any way I can.
Jim,
Note my response to Lindsey Antle below regarding unions. I don’t think it in our interest at all. However, I am in favor of organizing a lobby group to represent interpreters on labor related matters.
Brandon
I agree, Meg. The sign language interpreting industry is not a zero sum game. There is room for everyone. With that said, and to your point, we need to ensure that while accommodating people of various skill-sets and perspectives, we don’t lose sight of our core values.
Given Gina’s’ excellent point, I think that certification decisions need to be addressed by a broad panel of stakeholders (including populations we don’t typically include, who have been serving for years outside the certification structure for various reasons) advising the FCC. While I agree we need to do something to ratchet up quality of service provided, it’s be nice if we could avoid doing damage (both short-term and long) in the name of doing merely “something”.
Brandon
Thank you for taking the time to write. These issues once again point to the need for a strong Sign Language Interpreter’s union. Had we provided a powerful representation in the early stages of VRS, we might be having a different conversation… there’s power in numbers. Thanks again for your article.
Derryn
Dwight,
Thanks for your response here.
Regarding your comment as to why we aren’t hearing from RID on this issue, in time I believe we will. You will note from Jackie’s comment below, and a review of the FCC docket, not many organizations have filed comments at this point. I believe organizations are evaluating the points of the FNPRM and will respond in short order.
Brandon
Wow, thank you for bringing this issue to light. I do have a question, I’m trying to read some of the other comments filed, but I only see one related to this specific topic (written by “Sheri” under “Recent Public Filings”), am I looking in the right place? Thanks.
Jackie,
You are looking in the right place. Note, the docket you are looking at was open in February of 2010. The FCC has been reviewing the structure and practices of the VRS program since then and the recent FNPRM is the culmination of that work (and the fact that the fraud case against Viable has largely concluded).
Keep an eye on the docket, more will be coming over the next 45 days.
Brandon
Ed,
Thanks for your post.
I agree, interpreters have valuable insight to contribute relative to the success of Video Relay as it moves forward. Further, I agree that interpreters need to be active in ensuring their interests are represented to both providers and the FCC.
I am hopeful that the readers of this blog will take a moment to share this post with their colleagues and employers, as VRS is an important part of the Deaf/Interpreting economy.
I welcome all insight!
One other thing to add under: Qualification Process for Interpreters
besides what you have already listed
Is mandatory quarterly stress meetings for interpreters on a one-on-one basis; i.e. to address cumulative secondary trauma.
With the exception of national certification, your article is excellent, and I will definitely comment in support of what you have outlined.
Beth,
Great question here relative to the slowing the output of students from ITP/IPP programs. Unfortunately, I am not close enough to effectively weigh in on the question. With that said, I have asked Lindsey Antle to comment as she is closer to the issue and may have an answer or be able to point the group in a direction for more information.
Again, great question!
Beth and I can talk off-line and, after that, I’ll post something for the group.
Beth, I would love to talk to you off-blog. I am with the Commission on Collegiate Interpreter Education — the group that accredits interpreter education programs.
My email is ccieantle@gmail.com. Let’s chat.
But simply having a lobbyiest is insufficient. There are too many interests, so it would necessary for a democratic vote on which issues are most important to the most interpreters. A lobbying body alone leaves too much power in the hads of a few, which is the problem we are combating as it is. I will pay $15-25 a month but only to an organized, unionized movement.
[…] of a local interpreting economy. Particularly, if what Brandon Arthur stated in his article, Will Sign Language Interpreters Remain Silent of VRS Reform, regarding falling compensation, under valued credentials, and supply exceeding demand holds […]
[…] response to the December 15, 2011 FCC FNPRM referenced above, I wrote, Will Sign Language Interpreters Remain Silent on FCC VRS Reform? In that post I stated that should VRS reform occur without specific recognition for the cost and […]
[…] [3] See Brandon Arthur’s article Will Sign Language Interpreters Remain Silent on FCC VRS Reform? StreetLeverage.com (Dec.21, 2011) for a discussion on the pressure for VRS providers “to seek interpreters who command a lower hourly rate. Logically, these will be interpreters who have yet to obtain their national certification, have fewer years of experience, don’t have the skill-set to effectively do the work…” http://www.streetleverage.com/2011/12/will-sign-language-interpreters-remain-silent-on-fcc-vrs-refor… […]