Will Sign Language Interpreters Remain Silent on FCC VRS Reform?

December 21, 2011

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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Member
Lindsey Antle

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!)

Member

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.

Member
I will definitely provide feedback. I’d hate to see VRS go the way of community interpreting: becuase of the federal and economic forces which you have already mentioned and becuase my state does not require certification, I am seeing the least qualified interpreters being sent on jobs as the de facto standard in most agencies and deep cuts in hourly wage. I obtained BS and MA degrees plus certification becuase I wanted to. I plan on getting further certification and education becuase those are my values. But until RID becomes as respected as say, the AMA or as passing the… Read more »
Member
Jim Cabbage
You think RID is not respected? You must be kidding. RID’s monopoly power is too great as it is. When RID convinced the NAD to give up its certification process it further solidified its monopoly hold on interpreters. I remain shocked that there was not an anti-trust investigation into that merger. What RID teaches about deaf culture is badly out dated and has little to do with VRS. Further more, RID’s complete lack of respect for those of us naturally born to interpreting is ultimately contemptible and frankly offensive. Funny, I spend a great deal of time bailing out RID… Read more »
Member
MaeBelle Barger , CSC CI & CT
Amen Jim Cabbage, I could not agree with you more. I have been totally turned off by RID for many years and this year I refuse to support them any longer. I will not go for useless CMP’s that in no way pertain to the job I have done my whole life. I have been told by many, many deaf people that they do not understand much of what some young Certified interpreters are saying to them because they use signs that these folks do not know, or because they use too much english structure. Many deaf people (especially senior… Read more »
Member
Terp Christine
Jim, RID did not convince NAD to give up its certification process. NAD leased a testing instrument from California to use for its certification test. When the lease was up, the California group said, sorry–we are taking the test back and they tried to take control of all the NAD interpreters too. By that point NAD and RID were in talks to make a merger of their two tests–which ended up being the NIC and RID took us NAD certified terps under their CMP system and recognized our certs. I applaud the RID and NAD for working together and not… Read more »
Member
YES I AM willing to give up $ for lobbying, and volunteer 10 hrs/month! And I might say Brandon, that was the politest kick in the butt I have ever recieved! I also think we need to patiently and repeatedly explain the effacy of what you’re saying to those opposed to it or not yet acquainted with it and not merely think of them as stealing our jobs. We are all in this together by necessity. I remember a few of the greats in our profession having extreme but forceful patience with me when I started, so I guess we… Read more »
Member
Will all respect to Janet Bailey — and there are few people in our field who I respect more — I’m not sure the creek we’re in is named “paradigm.” Too many syllables. All of the above is one more reason why I’ve avoided VRS like bedbugs. Too much regulation by ignorant governmental bodies, too much money concentrated in too few hands, profit motive trumping the demand for quality… this is perhaps the first time that sign language interpreting has become really big business, and the actual practitioners are treated more or less as widgets — after the initial siren… Read more »
Member
Derryn Grey

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

Member
Hi Brandon, et al., I read as much as I could of the 109 page document. Skimmed really. Like Dan, VRS is like Bedbugs to me personally, possibly even closer to Earwigs slowly eating my brains to try to get out to the other side (even though that is a myth). I see the incredible benefit to so many Deaf users. But the thought of being chained up in a cubicle is just too much for me. To be fair, I tried working VRS. Definitely NOT for me. Regardless, I see the benefit and will comment as well as spread… Read more »
Member

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.

Member
Brandon et al, I read your post with great interest. Take it from an old hand that helped push VRS to its implementation; persistence is the key. Keep hitting FCC and RID or any organizations that have influence to the FCC. Brandon, you’re right, the moment is now. That NPRM will impact on how VRS is gonna be governed big time. Your post is well thought out and clearly represents video interpreters. I don’t think it would hurt if you or others contact VRS providers and get their thoughts and express your thoughts to them. (I know it is not… Read more »
Member
Gina Gonzalez

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.

Member
Thank you, Brandon, for this article. You have highlighted many of the changes and dilemmas that I have foreseen and I know we have discussed at least superficially over the years. I am thrilled to see someone sounding the alarm. I think a large portion of community interpreters, in DC especially, truly believe that they are immune to this VRS plague. But, like you, I beg to differ. So again, thank you for spreading the news. Specific to your mention of the upcoming reversal of interpreter Supply-Demand Ratios, do you know if anyone is doing any work or talking about… Read more »
Member
Lindsey Antle

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.

Member
Carissa D. Huffman
All my esteemed colleagues: I am a certified interpreter who would be looking for a new field if not for VRS. In my locality, VRS and state licensing have raised the qualification bar. I was already the highly credentialed one who never got called. It was either work VRS, or get a Joe job. I am so grateful for the opportunities my VRS company has provided. I do, however, see increased emphasis on numbers and profit. I do work for a company who seems committed to quality in the work, and using qualified professionals. I really would like to see… Read more »
Member
Lindsey Antle
Brandon, thank you for posting this on your blog and for giving me the information I needed to make comments. Dwight said, “why didn’t we hear about this from RID?”. My question is, why didn’t I hear this from my VRS company. I had to learn about this on a blog that I just discovered a few weeks ago! I will be sending in my comments and encouraging the Colorado RID members to do the same. However, I will also be asking my company how they are soliciting the interpreter’s voice in their comments. I will also contact Janet Bailey… Read more »
Member
Judith A Kroeger
The Registry Interpreters of the Deaf has been working with the FCC in order to be on the forefront of developments regarding video relay interpreting. In their collaboration they have helped the FCC to identify RID as “a professional interpreter organization that is ready and willing to serve as a resource of the interpreter’s voice to the FCC.” RID has, through the development and implementation of the Government Affairs Program (GAP), submitted formal statements to the FCC on issues regarding the use of certified interpreters, mandated training (particularly in 911 call handling), and interpreters working from home. (Copies of official… Read more »
Member
“The FCC is very aware that providers are rallying their interpreters to bring their voice to the FCC, but continuing to pay out their investors millions and asking interpreters to work with less.” I think Judith is saying it’s a complicated issue. We may mobilize, but one large problem is the lack of transparency from providers. Yes, perhaps providers don’t mind putting in the least qualified interpreters and saving costs. But is that the FCC’s problem? Perhaps the private company provider model is broken. Is the problem greed on the part of the providers, protecting investors (the one percent), CEOs,… Read more »
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[…] 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 […]

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[…] 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 […]

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[…] [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… […]

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