Mr. Ernest Garrett
Executive Director, MCDHH
1500 Southridge Drive, Suite 201
Jefferson City, MO 65109
April 1, 2014
Dear Executive Director Garrett:
These Comments are in response to the Public Notice released March 3, 2014 by the Missouri Commission for the Deaf and Hard of Hearing seeking comment on the proposed amendments to 5 CSR 100-200 et seq.
RID was established in 1964 and incorporated in 1972 as a 501 (c)(3) non-profit membership organization promoting the welfare and growth of individual interpreters as well as the profession of interpretation of American Sign Language and English.
RID commends the Commission for its work on the proposed amendments. We strongly believe that high standards are necessary to ensure that interpreters are prepared to meet the linguistic needs of the Deaf community. Adherence to high standards benefits professional interpreters, the Deaf community, and all consumers of interpreting services. In order to promote excellence in interpreting, all interpreters should demonstrate skill, knowledge, and ability through the attainment of certification. We recognize that state regulation of interpreting is a mechanism through which this goal can be more fully realized and applaud the efforts of the Commission to open dialogue around communication access in Missouri.
It is in the spirit of promoting our shared goal of excellence in interpreting that RID asks the Commission to consider the following comments and recommendations, which aim to strengthen the impact of the proposed amendments.
5 CSR 100-200.070 Performance Test and Evaluation
RID has grave concerns about how equivalency between and among various certifications was determined and set forth in the rules. The equivalency determinations, absent explanation of the psychometric data used and the reasons for the determinations, appear arbitrary and capricious. This is underscored by the exclusion of several nationally recognized certifications from the rules as accepted credentials.
The List of Certificates Recognized by the Board should be amended to include all NAD-RID recognized Certifications
RID asks that the Commission include those interpreters holding an IC/TC, RSC, or MCSC on the list of interpreters able to work in Missouri.
Holders of this certification demonstrated the ability to transliterate between English and a signed code for English and the ability to interpret between American Sign Language (ASL) and spoken English. This individual received scores on the CSC examination that prevented the awarding of full CSC certification. These exams were offered from 1972 to 1988. These exams are no longer offered.
Holders of this full certification have demonstrated the ability to interpret between American Sign Language (ASL) and English-based sign language or transliterate between spoken English and a signed code for English. Holders of this certification are deaf or hard of hearing and interpretation/transliteration is rendered in ASL, spoken English and a signed code for English or written English. Holders of the RSC are recommended for a broad range of interpreting assignments where the use of an interpreter who is deaf or hard-of-hearing would be beneficial. This exam was offered from 1972 to 1988. This exam is no longer offered.
The MCSC examination was designed with the intent of testing for a higher standard of performance than the CSC. Holders of this certification were required to hold the CSC prior to taking this exam. Holders of this certification are recommended for a broad range of interpreting and transliterating assignments. This exam is no longer offered.
An individual who holds any of the credentials listed above has been maintaining that certification through professional development since the inception of RID’s Certification Maintenance Program (CMP) in 1993. Since the Board is listing each credential individually, then it should recognize these generalist certifications as a basis for obtaining a license in Missouri.
5 CSR 100-200.170 Skill Level Standards
RID does not oppose skill level standards. In fact, our own certification system recognizes that specialty certifications in addition to a generalist certification can better indicate an interpreter’s knowledge, skills, and abilities in specialty areas such as legal interpreting. However, as previously stated, we have concern about the basis used to determine equivalency of the certification listed in the rules. Thus, absent objective psychometric data, we question any level system established thereof. As a result, the pool of qualified interpreters able to work in Missouri may be artificially limited by a subjective level system. Furthermore, all NAD-RID certified interpreters are tested on their ethical decision-making, including assessing qualifications for an assignment.
Appropriate Recognition of all RID Credentials Benefits Missouri by Broadening the Pool of Qualified Interpreters in the State
The field of interpretation is currently in an exciting period of growth as a career profession. As we work to eliminate the perception of interpretation as just a “job” that any individual with an interest can undertake, we are seeing the field gain momentum in reputation that encompasses quality and respect. With supply not meeting the current demand, interpreters have become an invaluable tool in communication access between Deaf and hard of hearing individuals. The U.S. Department of Labor predicts that “employment of interpreters and translators is expected to grow 42 percent from 2010 to 2020, much faster than the average for all occupations,” and continues, “Demand for American Sign Language interpreters is expected to grow rapidly, driven by the increasing use of video relay services, which allow people to conduct online video calls and use a sign language interpreter.”1
Amidst this increased demand for interpreters, RID broadens the pool of qualified interpreters qualified to work in a variety of settings in Missouri. Currently, there are 77 NAD-RID-certified members in Missouri and nearly 10,000 nationwide. NAD and RID use a three-pronged approach to certification, which includes the attainment of the national credential, maintenance of that credential through professional development requirements and adherence to the NAD-RID Code of Professional Conduct. This approach sets the expectation for interpreting services throughout the profession. As a result, Missouri is able to attract a pool of interpreters who can enter the state and serve the community because interpreters who hold an NAD-RID certification have demonstrated competency in the field of interpreting and are able to work across the varying state regulations and licensure laws.
The National Association of the Deaf (NAD)-RID Certification System Strengthens the Impact of the Regulations within the State of Missouri
RID’s Certification Programs maintain strict adherence to nationally recognized, testing industry standards of validity, reliability, equity, and legal defensibility. NAD and RID have developed a certification process that involves passing a series of exams. In order to attain certification, an interpreter must pass a multiple-choice knowledge exam that measures an understanding of a variety of areas from linguistics to English proficiency to ethics to influences on the interpreting process. The main tasks performed are:
1. Assess each interpreting situation to determine if qualified for the assignment. (emphasis added)
2. Prepare for assignment by determining logistics and purpose of interaction for all parties involved.
3. Maintain competence in the field of interpreting (e.g., attending workshops and classes, reading professional literature, working with a mentor).
4. Apply the NAD-RID Code of Professional Conduct for the interpreting profession.
5. Provide interpreting services that reflect awareness and sensitivity to culturally and ethnically diverse groups.
6. Facilitate the flow of communication during the interpreting process.
7. Apply the appropriate communicative mode and language register.
8. Construct equivalent discourse in the target language while monitoring message comprehension and feedback to modify interpretation accordingly.
9-A. Use ASL proficiently within expressive interpreting tasks, including choice of sign vocabulary, use of sign modification to show variation in meaning and grammatical function, and appropriate use of space, facial expression, and body movement.
9-B. Comprehend ASL proficiently during the interpreting task, including sign vocabulary choice and sign modification to show variation in meaning and grammatical functions.
10-A. Use English proficiently to construct an equivalent message in the target language, including appropriate vocabulary choice, tone, grammar, and syntax, with appropriate use of register, pausing, rhythm, intonation, pitch, and other supra-segmental features.
10-B. Comprehend English proficiently to construct an equivalent message in the target language, including appropriate vocabulary choice, tone, grammar, syntax, appropriate use of register, pausing, rhythm, intonation, pitch, and other supra-segmental features.
The current NAD-RID National Interpreter Certification (NIC) tests the ability of an interpreter to think critically about the Code of Professional Conduct (CPC). Since all NAD-RID certified interpreters agree to uphold the CPC, and we test for their understanding and knowledge thereof, we can be assured that they have an appreciation of the ethical situations that interpreters may encounter. Of particular note, Tenet 2 – Professionalism addresses an interpreter’s responsibility to assess their knowledge, skills, and abilities in relation to the assignment. “Interpreters accept assignments using discretion with regard to skill, communication mode, setting, and consumer needs. Interpreters possess knowledge of American Deaf culture and deafness-related resources.”2 This tenet supports the philosophy of the proposed level system – that interpreters should work only in assignments for which they are qualified – without arbitrarily establishing equivalency among various certifications.
The Future of Interpreting
“Standards” or the “norm” for interpreters 15 years ago are no longer relevant today. All professions go through maturation phases. In nursing, there are delineated differences among an orderly, nurse’s aide, LVN and RN; in law, the same holds true among a legal secretary, a paralegal and an attorney. In many professions, such as nursing and law, states have implemented clear-cut requirements and standards for that profession, including timelines and an organizational structure for when and how these requirements would be met. We are at a point in the interpreting profession to not only witness, but to impact the progress and journey down this path.
Since the first interpreter certification was awarded in 1972, not only has the profession changed dramatically, so have the needs of the Deaf community. The number of interpreters has grown. The need to certify practitioners has become more widely recognized at the state and federal levels, and within public and private practice. The processes and practices underlying certification have evolved. When the NIC was introduced in 2004, it was state-of-the-art, with a test that “raised the bar” for ASL/English interpretation and transliteration. Over the years, we have learned a great deal about how the NIC is adopted within the profession by interpreters, regulators and hiring entities, as well as how it is perceived by consumers.
Nearly every state across the country is faced with the issue of regulating the interpreting profession and practice within its borders. This is an issue of great importance considering the impact these decisions can have on the quality of service Deaf consumers receive, as well as the state of the interpreting profession. RID is committed to ongoing dialogue with the Commission and the Board to facilitate a smooth transition under the amended rules. RID supports the regulation of interpreters to ensure excellence in services delivered to the Deaf community. As the amended rules are promulgated, RID urges the Board to recognize the value of NAD-RID certification and the many and varied contributions NAD-RID certified interpreters have made and will continue to make to the State of Missouri and the Deaf community. The impetus is now on us to work together to implement high standards that meet the professional needs of interpreters and the linguistic needs of the Deaf community.