Michigan Deaf Community

Dear Michigan Interpreters and Interpreter Rules and Regulations Committee:

Upon reading the draft for the proposed rules and regulations for the Michigan Interpreter Law, I had several concerns. I have heard many interpreters responses after reading this Draft and many of them are frustrated to the point of talking about moving out of state or leaving the profession. These are good interpreters we cannot afford to lose. There is already a shortage in our state. While we are all in agreement about wanting standards for interpreters to improve, I believe we must take care in how much we are expecting realistically from Michigan interpreters to continue in this profession.

The new BEI test sounds like a good, sound test and a good replacement for the Michigan QA exam. However, I am concerned about the equivalencies being made with national certifications from RID and NAD.

Many of the interpreters who have worked very hard to achieve national certification from RID or NAD are feeling frustrated that their certifications on this Draft, are being placed in a lower class than interpreters passing the brand new BEI State testing. Interpreters have worked for years at becoming nationally certified, while using state testing as a stepping stone towards that goal. Being asked to take a State test after national certification seems like going backwards.

I have 23 years of interpreting experience and spent several years doing community interpreting full time which included extensive mental health and legal interpreting and yet, according to the proposed draft, I would be excluded from these two areas. My concern is that someone who might have a “class 3″ credential may be excluded from “class 4″ assignments and yet may have experience and specialized training in that area. Whereas, someone who has just passed the BEI at a level 3, will be allowed to interpret anything and that interpreter may have no experience or training in either mental health or legal interpreting.

RID has recently put in educational requirements to sit for the national testing, or they offer an alternative pathway in lieu of the degree requirements which is pretty extensive in taking experience, education and training into account. Where does education and experience fit into the proposed rules and regulations as far as the BEI candidates go?

I would like to suggest adding in NAD IV with greater than 5 years with that certification be made eligible for Class 4. I would like to suggest an NAD III with greater than 5 years with that certification be made eligible for Class 3. This would reflect the skill levels of many interpreters in the community holding these certifications.

I have a concern about the BEI test that, to my understanding, there is no portion of the test that tests a candidates’ knowledge of the RID/NAD Code of Professional Conduct or Ethics. As seen in the Interview portion of the NIC test, RID/NAD have made demonstrated knowledge of the CPC of paramount importance in becoming certified.

I have great concern over the K-12 Educational interpreting requirements. According to the Rules and Regulations draft, someone with the lowest level of a State test (BEI I) would be considered qualified to interpret for K-12. I think higher standards should be looked at–requiring EIPA, national certification, or the higher levels of BEI. We should endeavor to provide the best possible interpreters for the deaf and hard of hearing children of Michigan.

Many interpreters already feel overextended financially. We are also affected by the current economy in Michigan. We have to pay considerable amounts of money to take the NIC tests, EIPA tests if we work in an educational setting, pay our RID/NAD membership fees annually, pay to go to workshops to earn CEUs to maintain our credentials, pay for education/student loans, pay the State of Michigan registration fee, pay our local MIRID dues, and now the State of Michigan seems to be asking to add on the BEI testing as well. This seems like an undue burden on Michigan interpreters.

For example, currently, as an NAD IV certified interpreter I am required to pay $195 per year in RID/NAD dues and the Michigan Registration fee. I have just taken the NIC performance test ($325). I have very recently returned to work in an educational setting, and I am scheduled to take both the elementary ($60) and secondary EIPA tests ($310). It is costly to work as an interpreter. I feel like taking interpreting tests is consuming all my time and resources.

These are just some of my concerns as a long time Michigan interpreter. I hope other interpreters and Deaf and Hard of Hearing people will also offer feedback to the Rules and Regulations Committee on their proposed Draft.
I have endeavored to find the email addresses of all those on the Rules and Regulations Committee to send them this email but have been unsuccessful. If any of the members of the Committee would kindly pass my concerns along, I would appreciate it very much.
I would love to hear what others have to say, so please email me…..

~Christine Alexander