MCDHH Response to MO-RID Petition

MCDHH Response to MO-RID Petition

Missouri Commission for the Deaf and Hard of Hearing (MCDHH) has recently become aware of heightened community conversations about the availability, quantity, and quality of Master level interpreters as a result of an online petition started by the Missouri Chapter of Registry of Interpreters for the Deaf (MO-RID). This petition is requesting that we change the rule to allow NIC Certified interpreters to be converted to Master level. While the MO-RID has updated the petition that they will no longer be delivering it to us, we continue to receive phone calls, emails, and social media posts about the contents and reasoning alluded in the petition. We have grave concerns about the misinformation and misrepresentation in this petition, and would like to take this opportunity to clarify facts and outline the reasoning behind the current rules:

RID’s Equivalence in the Missouri Interpreter Certification System

Firstly, under the current rules of MCDHH, RID’s NIC and CI/CT certifications are recognized at the Advanced level. In the petition, MO-RID suggests that they should instead convert to the Master level. According to RID’s overview of the NIC, “holders of this certification have demonstrated general knowledge in the field of interpreting, ethical decision making, and interpreting skills,” and “demonstrate[s] professional knowledge and skills that meet or exceed the minimum professional standards necessary to perform in a broad range of interpretation and transliteration assignments” (source).

It is noteworthy that this language is on par with the description of the Advanced Certificate from the Texas Board for Evaluation of Interpreters (BEI), which explains that: “The Advanced certificate sets a clear standard for an interpreter wanting to work in the majority of settings and perform a range of tasks” (source).  In contrast with this lower skill set, the BEI Master certificate is offered to interpreters with “the skills necessary to interpret in the most complex settings, including complex medical and mental health” situations. It is for this reason that the BEI Master exam specifically tests interpreters on their skills for interpreting in the most critical of situations, while the NIC does not. We have consistently maintained that those who wish to obtain Master Level Certification can always take the BEI Master Level exam here in Missouri or any other BEI states.

Number of Interpreters Impacted by Suggested Rule Change

Secondly, regardless of an interpreter’s certification level, if they do not have the specified training and experience required by current legal standards, the State Committee on Interpreters’ (SCI) Ethical Rules of Conduct requires them to decline the job. Thus, even if a certain number of interpreters are added to the pool of Master-level interpreters, it is possible that they would still be obligated to refuse Master-level jobs because they are not trained to interpret in settings that require a more elevated set of specialized skill set.

Thirdly, in their petition, MO-RID claims “Missouri cannot utilize up to 113* qualified interpreters in [Master-level] settings.” A footnote explains that the number 113 represents the number of NIC and/or CI/CT certified interpreters that reside in Missouri or within 60 miles of Kansas City or St. Louis because current regulations designate [RID’s NIC and CI/CT] at only the Missouri Advanced level.” However, this figure fails to accurately represent the facts about the number of NIC and CI/CT certified individuals that are already recognized as Master-level interpreters in the Missouri system. Only 70 of the 113 included interpreters live in Missouri. Of these 70 interpreters, 37 are already certified as a MICS or BEI Master; three others are also considered Master-level because they hold the required NIC-Master or NIC-Advanced certifications and four of the NIC or CI/CT holders in Missouri are not licensed to practice through the SCI. Thus, the fact is that this leaves only a maximum of 26 interpreters living in Missouri whose level would actually move from Advanced to Master if the suggested rule change was to take effect.

Additionally, the NIC and CI/CT tests do not specifically measure skills in areas that define Master-level work, such as felony criminal situations, juvenile and family court, and law enforcement. The interpreters who would be affected by the suggested rule change and their counterparts in the greater St. Louis and Kansas City areas might still not have the training and experience necessary to work in Master-level settings. Significantly, based on MCDHH’s Skill Level Standards and SCI’s Ethical Rules of Conduct, interpreters who do not feel confident and comfortable in a particular situation are obligated not to accept that job.

Process of Updating Missouri Rules

Lastly, the MO-RID petition claims that the reason for NIC and CI/CT certified interpreters’ categorization as Advanced-level is because “the State of Missouri had not updated their interpreter rule book.” However, MCDHH has gone through three different periods of rule changes since the CI/CT, NIC-Advanced, and NIC-Master tests were discontinued in 2011. New changes to the MCDHH rules were published in August 2014, September 2015, and October 2016.

It is not in the character of the MCDHH to resort to excuses for sticking with the status quo. Thus, in keeping with its mission to facilitate effective communication access for the Deaf and Hard of Hearing, especially in high-stake settings, the standard process of changing rules does involve serious consultations with members of the public, the Board for Certification of Interpreters (BCI), MCDHH Commissioners, and legal counsel. The goal of MCDHH is to continue to give meticulous attention to standard requirements that protect Deaf and Hard of Hearing Missourians while also seeking to make changes consistent with our mission if the need arises.

Informed Conversation in Our Community

MCDHH has received many calls, emails, and messages regarding this petition, and we are grateful to have engaged community members willing to take the initiative to speak truth-to-power. While encouraging this dialogue to continue, we also encourage the affected individuals to be willing to explore and interrogate perspectives different than their own, especially perspectives that are in the best interest of our great state. It is only through such empowered and objective analysis that we will collectively develop new ideas to move our community forward in tandem with the MCDHH upcoming Interpreters Conference and Deaf and Hard of Hearing Empowerment Symposium. The Conference and Symposium theme is “Come Together.” We hope to see many of you come together in Columbia on October 14 as we continue this conversation because we are stronger when we speak with one accord; we are mightier when we walk in unity!