This is a thought-provoking comment by Karen Graham; check the link out.
Karen basically offered thoughts on new and much stricter VRS regulations and indicated who the victims may be as result of that.
I consider Karen a good friend even though we've not had the length of time to call it "old friend". Nevertheless, we have a mutual respect for each other. That said, I do have different perspective as compared to hers. I was fortunate for having worked in government in Texas for 20 years, and then as a co-owner of Convo that I have insight into both worlds.
First, let me cite quotable comments from Karen's article.
"The intent of the rule was to root out fraud and make VRS a more manageable industry for the federal government. Did their action lessen the probability of VRS companies acting in a fraudulent manner? Most importantly, are Deaf people receiving better service now than they were a year ago? How did the great VRS shake-up shake out?"
Keep in mind Karen along with her partners owned Interpreting Service (SignOn) and did subcontract with a few VRS providers. As you all know the FCC regulations do not permit subcontracts.
"SignOn doesn’t exist in its original form any longer. In my case, I lost a livelihood. I’ve moved into a different field altogether and the days of monitoring the FCC announcements are a thing of the past."
"But some actors in this drama, like myself, were plumb out of luck – and out of work."
"One VRS provider who proceeded with certification suggested that the strictness of the rules was a challenge and perhaps limiting to efficient business operations. Requiring interpreters to be staff is often difficult in a freelance-oriented industry. Trying to discern the meaning of regulations, the increase in costs, and the impact on cash flow were some other concerns."
I acknowledge of "trying to discern the meaning of regulations.." as being tough one. The much new stricter regulations for VRS is indeed complicated. As a co-owner of a VRS provider, we've had to hire a lawyer who is very familiar with the FCC and VRS regulations to ensure that the company is in compliance with the FCC VRS regulations. I can readily tell you that it was one big reason why Convo became certified.
"Some interpreters, not liking elements of work with the bigger VRS companies (e.g. scheduling, strictness in operations) have left VRS altogether. Some of the interpreters, who had no intention of becoming freelance-only interpreters, were propelled into the freelance world by necessity. Others just needed this push to move on to full-time freelance work, something they had been considering anyway."
" In my view, interpreters felt that they followed the FCC guidelines prior to the rule change and that they were no more conscientious and ethical than they were before the change."
" It appears as if the shift in balance moved some of the more experienced interpreters back to community freelance work as their primary source of income. If so, how has that changed the quality of interpreting both in the community and in VRS?"
Finally these conclusions by Karen:
"In my opinion the changes haven’t necessarily helped."
"Perhaps the rule has eliminated fraud (has it?), which was its original intent, but many exemplary, law-abiding stakeholders became unintended victims."
All these are valid concerns and Karen has every right to pose her concerns.
My perspective is simple enough which is that it was not the FCC who created these stricter rules; it was the nefarious and greedy individuals who forced the FCC to create a much stricter set of VRS regulations. The frauds amounted to many millions of dollars and the FCC had to take action to prevent further pilfering of the federal funds.
Also, oversight by the FCC was impossible with 50 plus VRS providers, but now with only 6 VRS providers with "ownership" clearly defined, the FCC can be assured of quality oversight to ensure that VRS providers meet the rules. As matter of fact, the FCC recently did pay visit to all certified providers and examined their books, reviewed their interpreting training, and all that. That will assure that the VRS industry will be in compliance with the federal rules and prevent further frauds.
That said, I do admit that there are good and honest individuals and a few companies who are ethical got hurt by the stricter rules. My point is that it is not the fault of the FCC for that, it is the nefarious and greedy individuals that caused all the problems.
So what will the future be like? I think that down the future, there will be opportunities to improve the regulations as to be more fair, but that only will happen if the FCC is satisfied with the integrity of the VRS industry; that may take a while.
So tell me, Gentle Readers, what do you think? Do you think FCC did wrong or what? Let us know.
eyes open & thumbs up,
Long Link: http://www.streetleverage.com/2012/10/sign-language-interpreters-the-unintended-victims-of-vrs-regulation-change/