Will Sign Language Interpreters Remain Silent on FCC VRS Reform?

Censored Sign Language Interpreter Working in Video Relay

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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About the Author

Brandon is a nationally certified sign language interpreter and passionate industry entrepreneur. He has worked on both the practicing and business sides of the industry for the past 15 years. His father is deaf and his mother is a sign language interpreter. He is a devoted father and husband and enjoys the sport of triathlon.

43 Enlightened Replies

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  1. Lindsey Antle says:

    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

    • Liana says:

      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

  2. Meg Klein says:

    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 bar for Lawyers, it is a mute, impotent organization with its hands tied for those of us who love it and watch “collegues” and all players at the table thumb their nose at it. We must all take up the reigns of personal leadership as Brandon does but still I must ask…what about RID!?!?!? Why isn’t RID a STRONG player in all of this? And why is aligning ourselves with RID and it’s standards increasingly a moot point in our profession?

    • Jim Cabbage says:

      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 certified interpreters on a daily basis, and the only credentials I have are those bestowed upon me by my deaf mother and the deaf community in which I was born and raised. I will take that over the much ballyhooed RID certification any day.

      • MaeBelle Barger , CSC CI & CT says:

        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 citizens) long for interpreting “the old way”. RID is so consumed with Linguists that they have forgotten the culture they are supposed to serve. I took the time and trouble to become Certified in 1984 thats 28 years ago, add that to the many years of interpreting for parents and friends, and there has never been any consideration given to me or others as CODA’s. I missed my CMP cycle by 2 days, calling on Jan. 4th to ask if I could be classified as Certified, Retired and was told “TOO Late by 2 days.” C- Ya.. Well I guess they don’t need my money and YES I’m upset with their “We don’t give a hoot” attitude. I do take responsibility for missing the deadline by 2 days…It was my fault and so be it!!!

        • MaeBelle,

          Sorry to hear about your situation.

          Recognizing that I don’t know the details of your situation nor the call into RID, I have to believe that there is something you can do or someone you can talk to at RID now that leveler heads are prevailing.

          Is the issue one of not earning sufficient CEU’s in order to satisfy your CMP requirements? If that is the case, you do have the once in a lifetime cycle extension available to you, which might bridge the gap.

          As a CODA myself, I am appreciative of your comments of the “old way.” While I think the “old way” has less to do with linguistics and more to do with an authentic connection to the Deaf Community and their plight for communication access, it is important that seasoned veterans remain present, particularly those with native voices, remain in the field.

          To that end, I am hopeful that you’ll take another run at RID to see what can be done. Ask to talk to the acting Executive Director, Matthew O’Hara. He is a problem-solver. Maybe he can help.

          Good Luck!

      • Terp Christine says:

        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 leaving us in the lurch.

  3. Meg,

    Unfortunately, the phenomenon you are seeing in your state relative to falling hourly rates, which in my mind is why the less qualified are getting first right of refusal on assignments, is occurring throughout the country. VRS, as it has for nearly a decade, continues to drive market rates for sign language interpreters. Sadly, it is driving rates downward and that trend will continue.

    It is unfortunate, but as with most things we appreciate them when they are no longer available. Well, gone are the days where interpreter hourly rates were growing at 10%+ per year. Gone are the days where you could say to the Community agency, “I can get $X.00 more at the VRS center down the street, if you don’t match it that’s where I am headed.” Gone are they days where the money and perks were so good it made up for the requirement to just “go along.”

    The question is, are we ready to act now that the elixir is gone?

    I would argue that the challenges you have mentioned relative to RID are symptoms of a much more precarious issue, interpreter apathy. It is our apathy that allowed VRS to unfold in the industry without so much as a single challenge related to interpreter practices. It is our apathy that has driven, or not as the case may be, the priorities at RID. Yes, we need a professional organization that has the resources and priorities to effectively represent us. Yes, we need a professional organization that isn’t stymied by the inherent conflict between certifying body and professional association. Yes, we need an organization that can mobilize its interpreter constituency and lobby successfully to ensure that the interests of interpreters are protected.

    In my view, RID has some reorganizing to do in order to effectively represent the sign language interpreting profession in this political and economic climate. The question is, who is going to assist?

    Are we going to stand up and be part of that change? Are we each willing to give a couple of hundred dollars a year for lobbying activities? Are we each willing to give 10 hours a month volunteering? Are we willing to work together to set-up and fund a lobbying group to represent the interest of interpreters?

    Meg, to me, aligning ourselves with RID is a moot point in our profession because we have allowed it to be.

    • Jim Cabbage says:

      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

  4. Meg Klein says:

    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 need to “mentor” not only those who are least qualified, but must forcefully “mentor” the FCC and any other body who threaten the values we hold dear. I still am a firm beleiver that if you do what you love, with the highest standards the money will follow. I look forward to more concrete ideas from Streetleverage!

    • 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.

  5. Dan Parvaz says:

    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 song of steady pay and benefits, they are faced with reductions in pay, autonomy, and a corporate culture they have always been free to leave at the end of an assignment. The real profits go to those who provide the infrastructure, and who don’t always have interpreters’ (or even Deaf people’s) interests at heart. While it’s easy to point at medical diagnostic companies in the VRS business, being a member of the Deaf or interpreter communities is no guarantee either.

    On the dilution of certification. That, I’m afraid, I’ll have lay squarely at the doorstep of the certifiers. Those not disgusted with the recent alterations — to say “developments” would be overstating the matter — in certification policy have simply not been paying attention. Certification *means* less quite simply because certification *says* less. I’m not sure I blame the VRS companies for seeing which way the wind is blowing. Okay, we can do something about hiring ITP students and other interpreter larvae. But certification is a tangled mess and will require, I’m sure, a radical and not-too-pleasant solution. Until that problem is solved, I want the FCC as far away from it as possible.

    I’m sure there’s more, but until I start getting better reports from the trenches, I don’t see myself setting foot in a VRS cubicle any time soon.

    Cheers,

    -Dan.

    • Dan,

      Thanks for your comment.

      Bed bugs? And I thought the Coyote reference was stiff… :)

      I would agree with you that until VRS was formally adopted into TRS and eligible for reimbursement, sign language interpreting was a small time opportunity. With this larger stage came a host of characters, some trying to make a difference, others unfamiliar with the interpreting profession, and yet others focused solely on the profits—as you have pointed out. With all of that said, if we step back and consider what is necessary for a marketplace with VRS at the center to exist, and do the tremendous good it has done (and cause the harm it has), I think we would find we need all of these characters.

      I think the tragedy here is that as a profession, we weren’t mature enough to understand that you only have leverage at the negotiating table before you take the money. Consequently, we find ourselves here having taken the money and wanting to negotiate different terms. Unfortunately, this is a difficult proposition. It is for this very reason that the opening we have been given at the FCC is so important. As VRS is migrating to a new model, the door is slightly open to address a limited number of issues that will position us better for the longer-term.

      To me, the most important of those issues is certification. While the dilution of certification has occurred, and will continue to occur, if we can prevail upon the FCC to see the value in extending a certification differential, providers will work in support of it due to the financial incentive. This, paired with a qualification system required by the FCC will do what we as interpreters (individually and collectively) failed to do the first time around…convince the VRS side of the industry that certification is important.

      While I would like to have the time to clean up our act prior to getting regulators involved, I think we can both agree that there isn’t sufficient time. It will be years before the sign language interpreting industry and its stakeholders are organized enough to provide a coordinated response.

      Regards,

      Brandon

      • Gina Gonzalez says:

        I am concern with the push for national certification. Per your post: “The rate providers are compensated per active user should be subject to a differential for use of nationally certified interpreters.”

        There is a class of people within the profession that are even more underrepresented and powerless; the interpreters of color. Deaf/HH Latinos and non-latinos who use Spanish/ASL VRS could be adversely impacted by what you (Brandon) are proposing theoretically speaking because at this point that is all we have. I am not going to list the ways and how at this time because they are many and bottomline speculative. Your article is a great one but hypothesized nonetheless. It is definitely a good start and worth discussing further.

        I am not nationally certified (I am Texas BEI certified) and unless the current national certifying system/RID undergoes a makeover, I will never want to be nationally certified. At the risk of boasting, I am a very good interpreter. The provider I work for would not receive the differential it deserves for employing me based on the national certification stipulation you are proposing. Nonetheless, I agree that certification of some kind is the key… a vetting process that results in the provision of a seal of approval for working in VRS of some kind.

        We really need to discuss this in depth as a profession; and make sure that our voice is heard and that we have had a hand in steering the future course of service provision.

        Unfortunately, our numbers will be so small and insignicant to make an impact because we do not have the power to create change or so we think; and therefore we are. We will tell ourselves that someone is surely taking care of the big issues; RID, sign language interpreting gods, something-someone, therefore I need do nothing. And if any one person or organization asks too much of us (integrity, guts, care, passion, action, risk etc), we will attack it.

        And for those who say VRS is not for me…. your input/participation is still very valuble; especially because what happens in VRS impacts the community and vice versa. We’re interconnected/interdependent.

        • Gina,

          Long time! Thanks for your post.

          You have raised an important point regarding my recommendation relative to providers receiving a rate differential for employing nationally certified interpreters.

          Before I dive into that, let me just say that I agree with you that there is a bias in the national testing system that impacts interpreters of color. No doubt about it. Clearly, this is something that needs to be addressed in both the national testing system and in every interpreter credentialing system. In my view, none are immune.

          To your point, the definition of “certified” as offered by me will leave some interpreters viewed as more employable than others. Technically, I suppose that is true. Practically speaking, I don’t believe that to be the case.

          The basis for my suggestion is really a simple one, how to maintain the value of having a credential on the VRS side of the sign language interpreting industry (which I believe we are in agreement on) and how to slow/prevent the replacement of credentialed folks currently working in VRS centers.

          To me, it boils down to timing and the sheer number of interpreters impacted. Relative to time, we clearly can’t come together as a profession to define who is in and who is out relative to the definition of “certified” for the purposes of the FCC. Consequently, I elected to recommend national certification because it already has a definition recognized by the federal government.

          Relative to sheer number of interpreters impacted, again, I elected to recommend national certification (while I agree with you there are many credentials outside of RID certification that would qualify) because it encompasses the greatest number of credentialed interpreters working in VRS settings.

          All of that said, I do believe, should my recommendation find its way to fruition, that we can work with providers and the FCC to incrementally adjust the definition of “certified” as we move along.

          Lastly, I agree that as interpreters we need to understand that we DO have the power to create change and have an impact on the direction of our field. To do that requires complete participation.

          Thanks, Gina.

          Brandon

          • Dan Parvaz says:

            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”.

  6. Derryn Grey says:

    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

    • Derryn,

      I agree with your comment that had we (as a profession) provided powerful representation in the early stages of VRS, we might be having a different conversation. Actually, we definitely would.

      Given our collective lack of organization, coordination, and historical under representation on VRS related issues, I can see how unionizing could be viewed as a viable alternative. With that said, as a profession we would need to carefully examine the pros and cons.

      It occurs to me that the pressure the FCC is (and will be) under to contain the costs of the TRS Fund (i.e. continuing the declination of the reimbursement rate) and the inherent position of a union that we would quickly be at a place (if not already) where the viability of the service offering would be in question. This would be a lose-lose for all VRS stakeholders.

      I believe the best alternative, given our limited timing, is to organize a lobbying effort to represent our interests.

      Brandon

  7. Dwight says:

    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 the word so that others may make a determination on how and if they would like to comment.

    And Meg, I had a similar thought – WHY DIDN’T I HEAR ABOUT THIS FROM RID FIRST? To me, it is inexcusable that Janet Baily and GAP is not out there explaining all of this to us or at least telling us what stance they are taking and how they are trying to work on this issue.

    *sigh*

    Dwight

    • 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

  8. Jackie says:

    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

  9. Ed Bosson says:

    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 always easy to do it, but VIs need to be active within VRS industry and try to convince VRS providers that VIs do have voice within the VRS industry.)

    Utmost Sincerely, Father of VRS

    • 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!

  10. Gina Gonzalez says:

    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.

  11. 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 slowing the production of new interpreters coming into the field?

    Prior to VRS, there was always a need for more interpreters. VRS created an even greater demand for sign language interpreters. Larger companies invested in interpreter education programs so that they could more readily feed their machines. Although they were not always using the most qualified interpreters in the VRS centers, the community benefitted from this increased supply of interpreters. As the baby interpreters crawled into VRS, the sage interpreters burned out, and were welcomed back into the ranks of community interpreting.

    In 2000, there were only about 15 4-year programs and around 35 2-year programs across the country. Now there are 40 4-year programs, and 77 2-year programs!

    But now that the factories are closing up shop, what is being done to slow the output from ITPs? Like you said in your article, the decreased rates from the FCC will directly impact funds available to pay sign language interpreters. And as long as SOMEONE will work for less, the rates will be driven downward. As long as we continue to produce new interpreters, they will continue flock to VRS to get their experience. It will be difficult for us to break this cycle without putting a stop in the ITP/IEP Dam.

    Does anyone have perspective or information on this? Would it be reasonable to ask ITP/IEP’s to slow or temporarily suspend their programs? Who SHOULD be addressing this issue? And is there any research being done? The longer we wait to research this stuff, the longer it will take to make a case and correct the issue…

    Thanks again, B :)

    • 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!

    • Lindsey Antle says:

      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.

  12. Carissa D. Huffman says:

    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 people making FCC decisions who actually understand what our work is all about. VRS provides dignity and independence for our Deaf community. I hope we can ensure it will continue.

    • Carissa,

      I don’t believe the service itself is in danger. VRS is here to stay. The important question is in what form will it stay? As pressure to contain the cost of the fund continues, so will the pressure to reduce the cost of the labor providing the service. This is where it gets tricky for sign language interpreters.

      To me, we need to support our interest of remaining employed by working to align the interests of the Deaf community, sign language interpreters, FCC, and VRS providers on the issue of a rate differential for use of certified interpreters and a qualification process for new to VRS interpreters.

  13. Lindsey Antle says:

    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 and Matthew O’Hara to ask if RID is commenting and, if so, what they are saying.

    This is such a significant issue that I trust many VIs will comment. I choose to work in VRS and don’t jump at the opportunity to get out and do community work. I can provide a service to 100 Deaf and hearing folks in one day in VRS rather than 2 or 3 freelancing. After 51 years in the field, VRS is how I choose to use my talent.

    Brandon, you mentioned that we should lobby. Do you have ideas about how to make this happen? I’d love to hear your thoughts about how we can unite and speak with one voice.

    Thanks, again.

    • Lindsey,

      Thanks for your question.

      It is my view that we would do well to establish an independent lobbying group that is tasked to monitor the industry and endeavor to protect the labor interests of sign language interpreters. In addition to engaging lobbyists and attorneys as necessary, this group would also have the responsibility to communicate real-time on labor related issues, mobilize the interpreting constituency as necessary, and provide updates on all activities and outcomes.

      To me, it is important that this group be independent of any organization and funded directly by sign language interpreters. Honestly, this is where I see the greatest challenge. Historically, as a field and as practitioners we have been unwilling to support efforts that require us to part with our cash.

      Imagine what we could do if every interpreter committed to a donation of $15.00 per month ($180.00/yr)? For giggles imagine if we could get 10,000 working interpreters to donate monthly. The result would be $1.8M dollars annually dedicated to protecting the interests of interpreters. For perspective, that is more than 50% of RID’s annual revenue.

      If we are serious as a field about stronger representation on labor related issues, I think this is the way to go. Personally, I would like to see us to avoid the kneejerk reaction of forming a union. We need to call the interest in forming a union what it is, fear paired with a sense of helplessness. We are feeling powerless in the face of the greatest change our industry has seen and we want someone in a cape to swoop in and save the day.

      Unfortunately, there is no cape crusader coming.

      We need to stand up, dust ourselves off and begin doing the difficult work we have avoided to date.

      Lindsey, as an aside, can you respond to Beth Henrickson’s post above? She is asking a question relative to slowing the production of interpreters as a result of the decreasing demand in the market.

      Brandon

      • Jim Cabbage says:

        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.

  14. Judith A Kroeger says:

    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 filings by RID can be found on the Government Affairs Program page of RID at http://www.rid.org/interpreting/index.cfm/AID/177 ).

    While it is important to RID and it’s members, that the FCC take an invested interest in the work environment of video interpreters, the FCC continues to say that it is not responsible for employer-employee relations (interpreters and providers). The FCC is solely interested in customer service and optimizing efficiency while reducing waste and fraud. However, RID continues to try to reformulate the FCC’s perspective.

    An example that demonstrates the need for FCC involvement in employee/employer relations is taken from our recent national conference where the Video Interpreter Member Section (VIMS) hosted a panel discussion with three VRS industry stakeholders. The stakeholders were, Greg Hlibok of the FCC, Janet Bailey of Gap, and Video Interpreter Summer Chapell.

    The discussion revolved around the Deaf community seeking a faster answer time than the present allowable 120 seconds. The audience of video interpreters was then polled to determine if Video Interpreters were taking longer than 10 seconds to answer the incoming calls. No one raised their hand. This result provided further evidence that present industry practice by VRS providers are far more demanding of the interpreters than the FCC requires. Although the FCC refuses to comment on the dynamic between the VRS providers and their interpreters, the interpreters continue to push for revision to the FCC’s current “hands off” policy.

    In response to the Deaf Community’s request for faster answer times, Janet Bailey showed that at any given time, it is not the speed at which the interpreter answers, but yet the number of interpreters available and any one given time. However it should be noted that there are potentially adverse affects on interpreters and the work produced when the VRS providers place further demands on the interpreters.

    Further, RID has raised the issue of interpreter certifications in formal addresses to the FCC. In response, the FCC would like know how instituting certifications will affect the industry. Presently, statistics on the number of certified interpreters working in VRS is unavailable however VIMS’s is currently developing a survey to determine such figures. In January, the survey will be released to present VIMS members. In order to participate in this survey, please consider doing the following:

    1. Check your membership profile to include your membership in the Video
    Interpreter Member Section – members will receive this survey as a result
    2. Join the Facebook page – Search “RID Video Interpreter Member Section”.
    3. Join the VIMS Yahoo Group – send an email to me at judithakroeger@yahoo.com
    to be added to the email/listserv style discussion group.

    If you have any problems, do not hesitate to contact Judith A. Kroeger at judithakroeger@yahoo.com. As the chair of VIMS, I encourage each and every one of you to get involved, but the question then remains, do we contact the FCC or RID or both, where is our power; individually or collectively?

    Likewise, I challenge each of you to read the proposed rulemaking and begin discussions of the actual issues at hand (
    http://transition.FCC.gov/Daily_Releases/Daily_Business/2011/DB1215/FCC-11-184A1.pdf ). 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 question the authenticity of this discussion proposal given the author and their provider affiliations. With video relay and the amount of money that continues to circulate with sponsorships and investors we as interpreters are hard-pressed to see the true intentions of a rally to the FCC.

    With that, some things to consider regarding the current Notice of Proposed Rule
    Making:

    I. Requiring the use of certified interpreters in VRS
    a. Establishes a minimum baseline of quality afforded to customers using VRS
    b. Increasing call efficiency
    II. Mandated trainings for interpreters
    a. Include the current discussion on 911 call handling and that as we as interpreters “witness” what is happening, we need to be adequately prepared to provide the level of service necessary to adequately meet the needs of the Deaf community
    III. Interpreter’s working from home
    a. From the discussions at the panel discussion at national, the FCC is concerned about the gross misconduct that was found in previous instances. This is not to say that every interpreter did this, but may be this is the time to start the discussion of how can we present this to the FCC in a way that affords to the customer service side and simultaneously minimize the chance for fraud.

    • Judith,

      Thanks for your post.

      As the Chair of the RID Video Interpreter Member Section (VIMS) I am appreciative that you took the time to add perspective and contribute to the discussion.

      Given the continual rodeo occurring on the VRS side of the sign language interpreting industry, I can appreciate that you, as an official RID representative, would question the authenticity of any effort to mobilize sign language interpreters on VRS related issues. In particular, one that has one guy with a “provider affiliation” and a website calling for comment at the FCC.

      In your comment below, you raise an important question relative to what qualifies, or disqualifies as the case might be, industry professionals as being legitimate sources of information and insight.

      “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 question the authenticity of this discussion proposal given the author and their provider affiliations. With video relay and the amount of money that continues to circulate with sponsorships and investors we as interpreters are hard-pressed to see the true intentions of a rally to the FCC.”

      Are you suggesting that a “provider affiliation”— defined in this case as one receiving a paycheck from a provider—disqualifies someone from “authentically” participating in industry related issues and encouraging the involvement of their colleagues to do the same?

      Given that you yourself have a “provider affiliation,” I am sure you can appreciate my interest. Particularly, since you extended a call to action of your own in your comments.

      I believe each of us can appreciate that every membership organization lives and breathes by the contributions of its volunteers relative to the expertise, interests, and issues they are passionate about. I would suggest, in most cases, that the expertise offered comes directly from the volunteer’s work life.

      My personal experience with the leadership at RID leads me to believe that RID wouldn’t support a perspective that disenfranchises an entire group of people with active VRS experience.

      I am hopeful that as a field, instead of questioning the authenticity of each others contributions, we instead work to embrace a diversity of perspectives to assist in strengthening the whole and any effort to support our collective interests. Further, that the sharing of information and perspectives to raise the awareness of issues confronting interpreters can be viewed as a benefit to the industry and not result in a school yard scuffle over the attention of the interpreting population. Let’s not forget, not all interpreters are members of the same interpreting association.

      Now, to respond to the two part question below you posed in your comment,

      “…do we contact the FCC or RID or both, where is our power; individually or collectively?”

      I’ll start with the second part of the question. It is my position that you don’t have power in a collective without the empowerment of the individuals that make up that collective.

      The issue of VRS Reform belongs to the individual interpreters slugging it out day-in and day-out in VRS arena. Consequently, we need to directly understand the issues of reform confronting the VRS side of the profession and understand what resources are available to us to determine how to best support our interests.

      At the point at which we directly understand the issues and the resources available to us to address them, we can then be empowered as a collective. It is only at that point that the collective moves from a loosely banded group of disgruntled practitioners to an organized body of professionals that can command respect and represent their interests with authority.

      Now for the first part of your question, it has to be both. It is my view that RID is in business to empower interpreters with the resources and the “how to” guidance to represent their interests. It is at the point at which the FCC, or any organization impacting the industry, is overrun with the echo of the voice of the sign language interpreter that there will be a preference to work with the collective instead of the individual.

      I am hoping we can count on you to file a comment, Judith.

      Perhaps, we can do lunch next time I am in town and continue this discussion live?

  15. A VI says:

    “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, and other non-interpreting administrators?

    • Thanks for your post.

      To give Judith the benefit of her own voice, let’s hope that she will comment here to confirm she is saying it’s a complicated issue. With that said, I agree with you that the VRS side of the sign language interpreting industry is indeed complex.

      Regarding your comment that “one large problem is the lack of transparency from providers,” I would agree, but only to a point. It is my view that if we, as a body of sign language interpreting professionals, took the time to seek out and digest the information that is available to us in the public domain, we might be surprised how much perspective we can gain relative to providers and their positions on matters that directly impact interpreters. Public filings are an excellent source to gain perspective. I do think the FCC’s visibility related to the actual costs of employing interpreters should be improved, but you know that based on my comments in the piece above.

      Regarding your question, is the use of qualified interpreters an FCC problem? In my mind, the caliber of interpreter providing the service and functional equivalency of the service are not mutually exclusive.
      I recognize that the FCC’s definition of qualified may not be my definition, but at the end of the day they do have an obligation to ensure functional equivalency. Consequently, in my view, it is difficult to imagine the FCC would take “no position” as their final position relative to caliber of interpreters providing the service. In my view, I don’t believe the FCC has taken a final position on this matter.

      To your question, “Is the problem greed on the part of the providers, protecting investors (the one percent), CEOs, and other non-interpreting administrators?” Is it, “greed on the part of providers,” or rather ones’ long-term, or not, interest in the viability of VRS marketplace?

      I believe a case could be made that the long-term interest of all VRS stakeholders, conscious or not, has not been long-term at all. Rather, very much short-term.

      Let’s consider the practitioner side of the VRS industry, as interpreters our short-sightedness would have us believe we were deserving of a 10+% rate increases year after year (in most places) for the better part of a decade. Further, this short-sightedness helped us believe it was okay to shakedown both Community and VRS companies to honor these astronomical increases without more than a, “I’ll go down the street to ABC company if you don’t pay.” Clearly, a longer-term perspective would have helped us think otherwise.

      Professional associations are no different. In my view, many associations have accepted massive donations while failing to consider the cost associated with pocketing that money. It is my opinion that these costs have rendered some of these associations unable to publicly support their constituencies on VRS related matters due to solvency concerns (take the wrong position, donations go away). Again, a longer-term perspective would likely have left these associations better positioned to serve their various constituencies.

      Again, it is my opinion, that short-sightedness is a problem experienced by all VRS stakeholders. We have all played a role in getting us here and will all have to play a role getting us to a more sustainable place. Consequently, it is extremely important that everyone become actively involved in suggesting solutions and ensuring all aspects of the industry are considered as we go through this reform.

      Brandon

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