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Comment on Proposed Interpreter Program Regulations. Deadline October 24, 2001

Separation of Skills Assessment into 2 Different Assessments

Assessments for both Transliterating and Interpreting Skills should be taken at the same time.

In order to ensure higher skilled interpreters, both interpreting and transliterating should be tested simultaneously. If the interpreter focuses on one sign language mode, of course the other sign mode skills will suffer. Virginia Quality Assurance Screened (VQAS) interpreters work primarily in the educational setting. Mainstreaming deaf and hard of hearing students into the public school systems requires interpreters to know and be able to communicate effectively in the mode requested by the individual student. Therefore, if the assessments are separated, interpreting skills will suffer and affect services for the Deaf in a negative manner

Inclusion of a Clear Statement of Fees

Current rate for interpreter assessment is $80 covering assessment on both interpreting and transliterating skills. If separated, the cost for both assessments will cost the interpreter $120. The cost for assessment is claimed by VDDHH to be $500. This was not part of VDDHH's original statement in the proposed regulation changes and appears to be somewhat inflated. Before this regulation is adopted, the public should have a complete breakdown and documentation that the assessment per interpreter actually costs $500. Also, the National Association of the Deaf (NAD) contracts with a number of states to administer the NAD assessment for interpreters at a price of about $200 per assessment. The NAD assessment is extremely comprehensive, professional in presentation, and a cost effective, viable alternative to both the VQAS Written, Performance Assessments, and diagnostic reports. NAD provides candidates with three levels of national certification as well as two uncertified levels for aspiring interpreters.

Replacement of VQAS Level I with Novice Interpreter Designation

VQAS Level I interpreter status is "qualified" by Virginia Law and VDDHH regulation. To make this change would create a conflict with the Code of Virginia 63.1-85.4:1, which clearly states ALL VQAS Levels are "qualified." Certainly VQAS Level I interpreters are qualified to interpret in certain areas, as VQAS Level III interpreters are qualified to work in more specialized interpreting environments. By Virtue of the Code of Virginia, "qualified" carries far more opportunities and privileges than the proposed Novice Interpreter Designation. "Qualified" means Level I interpreters can legally work for state agencies like public schools, state museums, and other state and local agencies. Remove "qualified" status from the VQAS Level I credential, and the interpeters now holding those credentials will be viewed as inept. As of July 2001, 288 VQAS Level I credentials were held by interpreters in the state of Virginia. It would be irresponsible to negatively impast these interpreters' earning potential and to eliminate them from competition in the marketplace, both public and private, by way of this change.

This regulation change will also ensure any future assessed interpreters entering the field at what has been the VQAS Level I classication will also be eliminated from competing in the market for interpreting services.

Erroneous information regarding the total numbers of VQAS interpreters and VQAS Level I credentials to be affected was presented to the Department of Planning and Budged (DPB) as support for this regulation change. As a result, DPB's Economic Impact Analysis was presented to the Secretary of Finance and Governor Gilmore for approval. Since then, new information regarding the negative impact of the regulation has been submitted to VDDHH, the DPB, and the Governor's office. Until a thorough investigation of correct VQAS interpreter counts and areas of employment can be accomplished and a corrected Economic Impact Analysis is written for the Finance Department and the Governor's review, the regulation should be rejected.

Consumer Grievance Procedure

Until VQAS interpreters have a formal voice or body of representation, which does not exist at this time, the grievance procedure may result in violations of work and legal rights, discrimination and possibly state and federal constitutional rights violations. In the procedure recommended by VDDHH, there is no recourse for the accused interpreter other than the interpreter taking legal action against those persons involved in the grievance procedure. it would be a shame to go to the courts for the interpreters' protection or for the validation of their work ethic. This regulation should not be approved until more thought and advancement in VQAS interpreter rights can be established. This proposed regulation should not be adopted.

The Minimum Standard of Two Raters per Interpreter Assessment

The number of raters comes into question with the change in the regulation affecting "Assessment Team" in VDDHH's proposed regulations and is, indeed, part of a proposed regulation change. Therefore, comment on the minimum standard of two raters is in order.

The administration of assessment in the national organizations, NAD and RID, always requires more than two raters. NAD provides a panel of five rathers, one alternate rater, and an interpreter. The change of bias is almost nil considering a face-to-face encounter with one's raters. In other words, it keeps everyone as honest as can possibly be accomplished. In all cases, Virginians must go out of state to be assessed and are not, in most cases, familiar with or friends of the raters. More raters affords the candidate more confidence in the assessment process.

RID's videotaped assessment is rated by at least one hearing person, one certified interpreter, and one deaf person. Stringent rules and policies are followed to assure biases, negative or positive, do not take place. This assessment, too, for Virginians is out of state. The likelihood of being assessed by a rater who knows the candidate is very low. To date, all Virginians were required to go out of state to sit for the RID assessment. Again, more raters ensure an unbiased outcome.

The VQAS regulation allowing "the minimum standard of two raters" is irresponsible in that there are no checks or balances in place to prevent rater bias during the rating process. All of the certified interpreter raters for the VQAS assessment are RID interpreters. One RID "hearing" interpreter rating two segments of the VQAS assessment is just not acceptable under any circumstances and affords that rater a much too heavy influence on the awarded VQAS Interpreter Level. In all fairness, VQAS interpreters should be represented in the VQAS rating process, the same way as NAD and RID utilize their own certified interpreters as raters. It would be absolutely in order to train willing, advanced VQAS interpreters for the rating process. This remedy could also alleviate the dire need for additional raters and diagnosticians.

Until now, VQAS interpreters have not known who the raters are. The list of raters VDDHH released reveals husbands, wives, and family members serving as raters. While their may be no impropriety practiced among these raters, the appearance of impropriety is overwhelming.

Other raters, who may be prone to bias, are interpreter trainers, teachers, and college instructors. Should an instructor rate his/her mentoree or student? How does a candidate know the raters are being fair under present circumstances? There is no way VQAS candidates can be reasonably sure their raters will recuse themselves from the rating process when "called for". It is of paramount importance that all interpreters be assured that their are being fairly rated. The "appearance of impropriety" among the raters must be cleared away and not be a confronting issue. A VDDHH regulation to the effect and practice of always utilizing the services of at least three raters per assessment will provide more confidence in the VQAS process. Revision will ensure equitable practices and will ensure awards of valid VQAS levels.

Average of All Three Segments to Derive a Fair Score & a Fair VQAS Level

(VDDHH states this was not a proposed change)

VDDHH proposed regulation change: "Awarding of screening levels will be based on composite scores of raters for each component of an assessment. The lowest composite score on any component of the assessment will determine the level awarded, if any."
It is this proposed regulation which gives rise to the comments about averaging all three scored segments, namely the scores for voice-to-sign skills, sign-to-voice skills and interactive interpreting skills. VDDHH's response demonstrates an extreme situation in which the candidate earns 87% on voice-to-sign (expressive) segment, but receives a 52% score on sign-to-voice (receptive) and 63% on the interactive segment of the VQAS assessment. Most interpeters do not experience a spread of 35 percentage points between two of the three assessment segments, which makes this an unlikely example. Normally, there is a variance in scored segments in any language interpreter test. This is a normal occurance and is to be expected. Even Deaf consumers of interpreting services are aware American Sign Language is not, in most cases, the interpreter's native language. As such, interpreters in any language tend to be stronger in one skill or another, but this variance does not affect the interpreted message in any major way.

The skill variance is handled nicely by both NAD and RID. There is a percentage point of minimum competency for which an award will not take place. However, the 3 skills scored are averaged when each score is above or satisfies the minimum competency requirement for awarded certificates. Awarding a VQAS Level bases on the lowest segment scored is not fair, nor reflective of the interpreter's true skill. VDDHH could do better by VQAS interpreters in providing a more fair assessment based on national role models. I suggest VDDHH do more research into other language interpreting professions and base VQAS scoring techniques and awarded levels on a better model than the one we now utilize. The one "lowest... score" should be eliminated and a reasonable average of all interpreting skills should result in an awarded VQAS Level. This regulation as it is proposed should not be adopted.

These comments were delivered to VDDHH on October 24, 2001.

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