NUBSLI public statement on CCS framework agreement

imageReblogged from NUBSLI’s website. This statement was published on 28th April 2016 shortly after the Crown Commercial Service send out the contract notice.

Since September 2014, NUBSLI has been in negotiation with the Crown Commercial Service (CCS) in an attempt to improve the initial drafts of a national framework agreement for Language Services (interpreting and translation). We highlighted many concerns, most notably a lack of standards and safeguards for users of BSL/English interpreting services and the waste of public funds that would occur were this framework to go ahead.

We acknowledge that some improvements have been made. However, we maintain that a large national framework, whereby public authorities can purchase contracts, is not appropriate for our profession. It has the potential to cause many interpreters to leave their careers, as evidenced by our profession exit interview report and our 2015 survey of working conditions (pdf)

In February 2015, NUBSLI launched the #ScrapTheFramework campaign, due to ongoing concerns about this large-scale privatisation of our profession and the damage it would cause to interpreters and the Deaf community we serve.

The framework commenced on 22nd April for up to four years and the suppliers were announced this week on the Government’s website. BSL/English interpreting and other services for Deaf people comes under Lot 4, and is split into regions a-e, which cover Greater London including Overseas, Southern England, Midlands and East of England, North of England and, lastly, Scotland and Northern Ireland.

Most suppliers will cover all regions. They include:

  • Clarion
  • London Borough of Newham (Language Shop)
  • Sign Solutions
  • Language Empire
  • thebigword
  • Prestige Network
  • DA Languages

From our privileged position as the service providers in this field, and with collective experience and expertise, our remaining concerns are:

  • A reduced amount of choice and control for Deaf people.
  • Poorer administration – where large agencies subcontract to smaller agencies, mistakes and wastage are more likely in the booking of professionals.
  • Poorer access – where Deaf people are provided with inappropriately qualified or experienced people, this has an impact on service delivery.
  • Poorer accountability – It is more difficult for Deaf people to complain about poor services.
  • Downward pressure on interpreters’ fees and terms and conditions to unsustainable levels.
  • Inefficient use of public funds on administration rather than access.
  • Large scale privatisation further puts at risk the ability for smaller agencies, with good local knowledge and relationships, to continue.
  • Despite a regional structure, none of the suppliers are local agencies.

NUBSLI wish to make it clear that BSL/English interpreters are not prepared to jeopardise the sustainability of their profession by accepting the diminished fees, and terms and conditions set out in the framework. These are not fitting for a workforce of extensively trained and qualified freelancers, and clearly go against market rates falling short of the industry standard. This was made clear to the CCS who have regrettably overlooked the counsel of the profession.

We have already seen the boycott of one NHS contract by interpreters in the South West. Interpreters are increasingly prepared to take a similar position with other contracts which do not meet our basic rates of pay and terms.

We will be continuing to campaign against the framework and will work with individual commissioners wherever possible.

If you are a BSL/English interpreter and are not yet a member of NUBSLI, we urge you to join. We are stronger together.


NUBSLI Statement on the Release of the National Framework Contract Notice

Reposted from The Nub:

NUBSLI Statement on the Release of the National Framework Contract Notice for Language Services from the Crown Commercial Service

The tender documents for the national framework agreement for interpreting and translation went out today. NUBSLI have been campaigning against this with our #ScrapTheFramework campaign since February 2015 and have successfully delayed the tendering process for over a year.

Today’s development is deeply disappointing and shows that the government are not interested in providing a robust service to ensure high quality access, but are merely aiming to cut cost. This will be to the detriment of the access rights of the Deaf community.

The Cabinet office were unable to provide any answers to the issues we have been raising since September 2014 regarding sustainability of the workforce, breached legislative requirements, or unmet need. The framework cannot meet the needs of the Deaf community and will undoubtedly lead to a deterioration of standards and reduced numbers of qualified BSL/English Interpreters/Translators in the UK.

NUBSLI will continue to fight for the right to fair terms & conditions and fees for its interpreters, and for high quality access for the Deaf community. Even after the launch of the National Framework, all hope is not lost. Coming together as a profession, standing firm with one powerful collective voice will make us impossible to ignore. If you are an interpreter or translator then we urge you to join us. For members of the Deaf community, it is your right to refuse services under this contract.

This government are placing BSL/English Interpreting services at significant risk in the UK.

#ScrapTheFramework latest: 1000 sign the letter, framework is not fit for purpose

As reported on the Limping Chicken blog earlier in the week, over 1000 signatories signed the open letter to Francis Maude MP, asking him to #ScrapTheFramework.

The letter included Len McCluskey, General Secretary of Unite the Union, leading campaign organisations and several MPs.

You can read the letter on NUBSLI’s campaign page.

This framework will change the way interpreting services are delivered to Deaf people in the UK, as well as covering all spoken language interpreting and other communication support such as lip speakers, deafblind interpreters, note takers and speech to text reporters. Privatisation of a whole sector in one go.

There is still work to be done in making representations to the Crown Commercial Service as there is a proposed two-hour minimum for interpreters and no travel expenses.

Aside from terms and conditions and fees the actual framework needs much more work. There are no stipulations about where Trainee Sign Language Interpreters (TSLIs) are able to work leaving agencies able to put Trainees into child protection and mental health. The NRCPD’s view. As long as registration is stipulated that is fine. It is not. Registered is RSLI: Registered Sign Language Interpreter. TSLI is on the register but not registered. Confused? So is everyone else. Trainees have yet to reach the National Occupational Standards and as such need to be protected and Deaf people safeguarded appropriately. NRCPD states on their website that Trainees should not work in legal settings and mental health. NRCPD, do what you say and tell the CCS no Trainees in mental health. Child protection should be explicitly stated too. As an unwritten rule the interpreting community has recognised this area as a no go for Trainees for years due to its legal as well as it’s moral nature.

On the spoken language interpreting side, there are low level qualifications stated for all areas, leaving the quality of provision dangerously low. Given that most agencies are motivated by profit the lowest possible common denominator gets the job not who is the most suitable. Private contracts are hardly safe when monitoring is left in the hands of private agencies who can make up their own figures (cf Ministry of Justice framework and ALS now Capita TI).

The way Deaf people are talked about is patronising and erroneous. “Non-spoken”, interpreters enable Deaf people “to access hearing” and if you are Deafblind you have access to video relay services. Hardly written from the basis of good knowledge and practice, or even common sense. No. This framework is a disaster waiting to happen.

What do you know about the new framework agreement?

This is some of what you really should know about the new framework for all interpreting and other services across the UK. You’ve probably seen that there was BSL levels 1-4 listed as interpreting qualifications and that these, due to public pressure, have been removed from the agreement. Well we haven’t seen confirmation of that yet.

The fact NUBSLI made representations about this and a number of other points, all of which have been passed over, points to a glaringly obvious fact. This framework has not being created in consultation with interpreters, the eventual suppliers of contracts which will be bought from the framework. Or Deaf people who the government hopes will have all public service interpreting via contracts from the framework.

Who has been consulted?
The Crown Commercial Service say they have consulted ‘extensively’. With who? Customers i.e government departments: NHS, DWP and … Organisations i.e. businesses, agencies and “Signature, the commercial arm of NRCPD”.

Who else have they consulted?
Suppliers. Well not the actual suppliers who are interpreters. The larger BSL agencies. Who? Clarion, Sign Solutions, Action on Hearing Loss and Newham Language Shop were the four BSL agencies present at a stakeholder day. The large spoken language interpreter agencies were present: Big Word, Pearl… amongst others.

Have they consulted NRCPD or NRPSI?
Frances Maude MP, Minister for the Cabinet Office and paymaster general, does not mention them in his reply to my letter via my MP Tessa Jowell. Tokenistic phone calls and emails seem to be the only thing that have occurred.

Who else haven’t they consulted?
Deaf people. No consultation, no equality impact assessment. In fact Deaf people have been told very little apart from “we object”. What good is that without action? Inaction is almost as good as saying “we support.”

What can we expect?
More sub-contracting – it is expected up to three agencies will be awarded places on the framework for each Lot. ‘Non-spoken interpreting’ is Lot 4. See above for the likely candidates. Although government has ‘commitments’ to support SMEs to win government contracts, the contracts get ever larger and so do the suppliers. Cross reference: UK-wide MoJ contract with one supplier: Capita, one of the big four.
How do the big suppliers fill local smaller contracts? Sub-contracting. Where does that leave the interpreter? Two businesses taking a fee and less being offered to the interpreter per job.
What does that leave the Deaf person? Usually with a signer because they are cheaper.

Two-hour minimums: interpreters have become an hourly-paid commodity with no value given to experience, training and commitment to the profession. Research shows the Deaf community want committed experienced interpreters who are involved in the Deaf community. More of us are now relying on other paid work to top up interpreting hours. Many have taken on interpreting as a second job to make up hours/pay from other part-time work. Nearly 50% are considering leaving the profession and of those most have over 10 years experience. The Deaf community are getting the opposite of what they want.

Reduced quality and standards:
In the framework if a supplier can not get a qualified interpreter they can just put in the next best thing. As we have seen with existing contracts, that will be anyone with a basic sign language qualification. The standards quoted are lip service, with next to no monitoring of government contracts (link) the agencies will run riot.

How wide-spread is this framework likely to be?
It will operate across the UK.
80 customers have been consulted: government departments, local authorities, the NHS, DWP i.e. AtW.
A clause in the draft language specification states that agencies with a place on the framework must encourage other statutory organisations to purchase contracts from the framework. The clear intent is that all interpreting UK wide, signed and spoken, will go through one very large framework with up to three suppliers on each lot.

What about monitoring and evaluation?
There is none. Well companies do their own which means the same thing. They are always going to come out looking great, despite what is happening on the ground.

And where are we currently? Months behind their deadline CCS are rushing through what will be the biggest disaster for both the interpreting profession and Deaf people. Contracts are supposedly with lawyers and there are no reassurances that when back they won’t just be put out for tender without consultation. Notices are supposed to go out by the end of January and the go live date is April. But then with a contracts this full of loopholes why would the government want to consult with anyone?

Join NUBSLI, we oppose the framework.