Signature must release their NRCPD cash cow: part 1

  Although interpreters pay to be regulated, any register does not belong to them, nor do they get a say in how the regulator they use is run. However, they do have a right to see where their money goes and that it indeed goes towards the actual public protection of people who use that regulator. I do not just mean Deaf people but the many people who place their trust in a register to provide them with information on who is qualified or in training, has insurance, is police checked and safe to book for their service/organisation to provide access to Deaf people as per statutory duties.

The holder of the NRCPD registers is Signature which is the trading name of CACDP. Another subsidiary of which is Signature Commercial Limited. A company which declared losses of £96k in the year ending 2013 and £160k for 2014. The accounts show website costs, two employees but barely any more information than that as they have “taken advantage of financial reporting standard 8 whereby subsidiary undertakings do not have to disclose inter-group transactions if 90% or more of their shares are controlled by the group”. Who knows what costs are being squirrelled away in the commercial arm.

This is one example of a lack of transparency. The next accounting practice will be more shocking to those that pay money to the register. Especially for those like myself who have called for independence of NRCPD from Signature and received the answer that it costs too much money to run the register and it could not survive without funding from Signature to keep it afloat.

In the accounting year ending July 2011, the register made a profit of £36k as follows:

Income  130,434    Expenditure  94,478     PROFIT  35,956

In July 2012:

Income  161,394    Expenditure  279,339   LOSS   -117945

In July 2013:

Income  180,810 Expenditure    285,450   LOSS   -104640

In July 2014:

Income  212,409   Expenditure  335,162   LOSS  -122,753

Why the spiralling costs of running a register? There are no separate accounts for NRCPD as CACDP/Signature does not have to provide them. The annual reports for NRCPD reveal nothing but a promise to improve transparency in their finances. A promise yet to be fulfilled.

The only clue is in the way that expenditure is apportioned to each activity in the CACDP/Signature accounts and what this percentage of overheads amounts to as a total of all expenditure. In July 2011 registration was deigned to have cost 6% of all of CACDP/Signature’s expenditure. A fairly reasonable cost which resulted in an overall profit of £36k that was made by CACDP/Signature.

Why the loss of £118k in 2012 despite an income of £161k? A whopping 18% of CACDP/Signature’s expenditure was attributed to the activity “registration” which amounted to £279k. This stayed at 18% for 2013 and has now increased to 21% for 2014.

So CACDP/Signature, with many different activites, apportions 21% of ALL of its costs to registration i.e. NRCPD supposedly costs CACDP/Signature £335k. Put in perspective a much smaller 16% is apportioned to development of examinations, training and materials.

Does it really cost £335,000 to run a register? Only if you apportion 21% of your overheads against registration. 21% of every single staff member at Signature is paid for by the register, despite the fact that not all staff members work for NRCPD.

It is time that the finances of CACDP/Signature were more transparent for registrants and Deaf people alike. It is time for the NRCPD registers to be truly independent at a time when we need them to be, more so now than ever in this political climate. Interpreters, other registrants and Deaf people need to call for independence so we finally make this happen. NRCPD’s so-called independent governance no longer cuts it, it is tied by these accounting procedures. An income of £212k is more than enough for a successful register to survive and furthermore, with not just the financial ties cut from CACDP/Signature, with employees working solely in its interests the register is much more likely to grow and succeed.

Does Signature Support a Lowering of Standards?

For a while now various parties have been pushing for a register of CSWs. This may seem like a sound idea in principle but it is far from it. It seems that this is closer to becoming a reality and Signature is not helping matters:
1) CSWs are not fit for purpose. I started my career with the old EdExcel qualification and saw many people pass that course that should never have worked with Deaf students. Why? A lack of language skills and sound ethical practices. Most of the Deaf students I worked with in colleges and universities needed someone to interpret for them. I never did AtW bookings as I thought I’d be doing a disservice to the Deaf person who surely needed a trained interpreter. As an ex-Chair of ASLI used to explain it: anyone who is listening to English and picks up their hands to relay this into BSL for someone or watches someone produce BSL and relays that information into English is interpreting and therefore should have met the National Occupational Standards (NOS) for Interpreting.2) So why then has Signature created an interpreting unit within the NVQ level 4 BSL qualification? CSW associations have been pushing for an interpreting unit within the EdExcel course for a number of years. ASLI has rightly fought against a lowering of standards. Now Signature has included an interpreting unit which will inevitably be used as a lower benchmark for interpreting, one which is lower than the NOS. All the arguments ASLI has made over the years about the National Occupational Standards are now effectively being ignored. Signature/NRCPD would stand to make funds from both the NVQ qualifications and a CSW register but perhaps has not considered the risks of further alienating interpreters. If this unit becomes a licence to interpret, as it surely will, then quality of interpreting provision will fall substantially. The term level 6 interpreter or level 6 CSW (both misnomers) will be no doubt be banded about and cause further confusion.3) And where is ASLI in all of this? ASLI has got too close to NRCPD to represent its members effectively. It has a place on the practitioners’ forum, which seems to be how NRCPD communicates fixed plans rather than how they get feedback from professionals in order to shape their direction. The ASLI Chair is on the board of NRCPD and has compromised his position in being able to effectively represent his own Association, a position which favours and defends NRCPD registration too heavily to be open to any criticisms ASLI members have of the register.

4) Meanwhile the DWP now seem to be pushing for more CSWs to work in AtW assignments especially for emails and phone calls. I’ve had appalling emails from Deaf people with terrible English grammar written by CSWs and had a plethora of appalling phone calls. Interpreters are not just for meetings. These are skilled jobs where you still need to have achieved the NOS in order to know what you are doing. Why aren’t NRCPD doing more to represent interpreters and the skills they have worked hard to attain? If they will soon also be registering CSWs then perhaps that does not matter to them. Why is no one talking about quality? AtW is designed to allow Deaf and disabled people equality in work, to find and retain jobs. The DWP would happily force people to use CSWs as quality for them is not an issue. It comes down only to cost regardless of value for money even when an unqualified Support worker charges not much less than an interpreter and cannot provide the same service. A register of CSWs rather than enabling registration for this group will inevitably be used against Deaf people by the DWP. Some Deaf people want CSWs. My personal opinion is that public money should not be wasted on unregulated and unskilled personnel. This also should not become the norm for those who do not want them and choose registered professional interpreters. The use of CSWs in education is another matter and regardless of how many self-published books support this, it still does a disservice to the BSL-using Deaf student.

5) Would a register of CSWs be used for schools only? No. For the reasons stated above. Would it benefit schools? Maybe. Would it benefit the Deaf student who is a BSL user. No. They would need a Registered Interpreter (see above). ACSW and NATED have now merged and formed ADEPT which puts CSWs in a stronger position.

Unless those supporting a CSW register stop pushing for CSWs to be used in areas outside of education such as AtW, for CSW courses to have interpreting units, for ‘career CSWs’ who do not develop skills and a qualifications body which goes against the NOS then I doubt interpreters will support moves by Signature or CSW organisations for registers or interpreting units where they do not belong.

Are Statutory Regulation and CPD cure-alls for the ills in interpreting?

photoRoger Beeson NRCPD Registered BSL/English Interpreter (since 1988)

Roger Beeson is a self-employed interpreter based in London. He was a founding member of ASLI and has held various offices, including Chair. He is a regular attendee at its London & South-East Region meetings. He was made a Fellow of ASLI (FASLI) in 2008. He is co-founder and still one of the co-owners of the long-lived independent online interpreting discussion forum “e-newsli”. He is chair of trustees of 3 Deaf organisations, drawing on the experiences of a lifetime spent living and working with Deaf people. He is scaling down his interpreting work, aiming to work a maximum of 3 days a week.

So NRCPD surveyed views on Statutory Regulation and CPD, and will no doubt come up with the expected results. What about the unasked questions?

  • What are Deaf people’s experiences of using NRCPD yellow badge holders?
  • Does the NRCPD yellow badge assure competence and quality?
  • What do interpreters see that’s not right in interpreting?
  • How many more would complain if it was as easy as pressing a button?
  • Is the NVQ system fit for purpose?
  • How do NRCPD’s CPD requirements address interpreting shortcomings?
  • Do we need a more rigorous test of interpreting, post qualification?
  • Is NRCPD really policing interpreting?
  • Does NRCPD have the personnel to understand what is happening on the ground in the interpreting world, or to find imaginative and sustainable solutions?

What would address shortcomings?

  • Statutory regulation? I don’t think so.
  • CPD in its current form? I don’t think so.

In recent months there have been two high profile court cases in London, involving Deaf defendants on serious charges, where registered interpreters have been told to stand down by a judge, following complaints by Deaf defendants and other interpreters. This is serious stuff. But nobody complained to NRCPD (as far as I know).

We could go on and on with anecdotes about sub-par performance, but we know why only a tiny number complain. Interpreting is a transient event, usually in a private space and rarely recorded.  This makes it difficult to gather evidence for a formal complaint.  However, it is clear when talking to Deaf consumers and interpreters, that there are worrying registered interpreters out there. Why can’t NRCPD proactively monitor interpreters when concerns are raised which are difficult to turn into formal complaints? Why isn’t there an interpreters’ MoT to identify weaknesses?

Before NRCPD points the finger at “cowboys” outside the fold, what is it doing to sort out what is under its control?

I’ve been a long-time supporter of the principle of registration. Even if the rhetoric rarely matched the reality, I paid my annual fee. I’d imagined that once the majority of people being paid to interpret were registered, that standards would be cranked-up. But far from that, NRCPD has become a pointless encumbrance, driving people away from registration. NRCPD is now part of the problem, not the solution.

What’s the connection between doing a CPD activity, writing about it, and high interpreting performance? Is there really any realistic prospect of Statutory Regulation in the next decade?

NRCPD needs to urgently reform itself if the whole registration system is not to go into melt-down (and I’m conscious that this contribution could precipitate that). Where is the credibility and leadership to address the real concerns of Deaf people and interpreters?

NRCPD Statutory Regulation Survey

The NRCPD have sent out a survey to communication professionals to assess their thoughts on statutory regulation. The deadline is Friday 11th July.

My answers are below. If anyone has any comments please post in response:

1. Do you support the NRCPD aim of statutory regulation? Yes

I support the aim of statutory regulation. I am not convinced the NRCPD are the right body to hold this as it is still not independent from Signature/CACDP and I haven’t been happy with the way UKCoD have dealt with the AtW enquiry and how interpreters have not been involved as much as they should have been.

2. Do you think requiring registrants to agree to a code of conduct is a good thing? No

The Code of Conduct is too prescriptive and does not allow for the breadth of ethical decision making that a BSL interpreter has to practice every day. The Code of Ethics was much better and reflective of other professions. A teological approach to ethics rather than deontological would be much more suited in the case of interpreters. This is a much more up to date way of thinking in the interpreting profession (see Dean and Pollard’s Demand Control schema).

3. Do you think requiring registrants to continue their professional development is a good thing? Yes

I agree with CPD but do not agree with the way that NRCPD have mandated that some hours should be structured but also limited to only courses about interpreting. This has created a market for CPD courses but not increased the value of CPD to practitioners of more than five years post qualification. For example I would like to attend courses on voice production, mime and another language. I believe these would all enhance my work as a practitioner but none of these courses would fit the NRCPD’s criteria. I have completed most of the courses that are on offer in the market and am struggling to find anything that would enhance my professional development.

The rather arbitrary numbers allocated to structured and unstructured do not make sense and were not created in consultation with interpreters.

The more experience one has the more unstructured CPD is completed rather than structured: peer supervision groups, clinical supervision, evaluating ones work, attending or facilitating interpreter meetings, volunteering for interpreter organisations, reading research and articles.

I also do a number of hours of voluntary interpreting which I often record and evaluate.

I would recommend that NRCPD readjust the hours of structured and unstructured or rather put the total amount of hours an interpreter should complete without being prescriptive.

I would recommend that NRCPD allows courses indirectly related to interpreting to be counted as CPD.

I would recommend that NRCPD consult interpreters when reviewing CPD.

4. Are you willing to meet with members of the NRCPD Board to discuss statutory regulation, continuing professional development and the code of conduct’ if the opportunity arises? Yes

Further comments:

The NRCPD should consider asking TSLIs to take an ASLI trained mentor and provide funding to ASLI to provide this. Currently any RSLI can support a TSLI and they would not necessarily have the skills to offer that support.

Before any statutory regulation takes place Signature should be completed independent from NRCPD.

The alternative would be that another body holds the power to regulate.

When representations about interpreters are made to government the NRCPD should be representing the interests of interpreters as well as Deaf people rather than the view of Signature or UKCoD. This represents a direct conflict of interests and independence is paramount

PSA accreditation: It has nothing to do with the medical model

PSAThe NRCPD has sought answers from the Professional Standards Authority (PSA) as to whether they could apply as a voluntary register to be accredited. We still have no clear answer but is this really a move towards what some perceive as aligning interpreting to a medical model?

Our history as an emerging profession of Sign Language Interpreters has lead us from the DWEB (Deaf Welfare Examination Board) interpreters to CACDPs first register in the 1980s which mostly consisted of those already working with Deaf people – social workers and Teachers of the Deaf. In the late 1980s funding was sourced and the Citi Services course became the first training course for interpreters. We were moving away from the helper model towards a more professional route into interpreting.

At the same time models of Deafness went from the medical model to social model i.e. there is nothing wrong with the individual that needs to be treated but rather that it is society that causes barriers. Then to a cultural model in which Deaf people have their own culture and language.

If only the government saw Deaf people that way. What we have had since 2010 is an tidal wave of outsourcing of interpreting services which has seen the lowest bidder win contracts across all sectors. This has been especially bad with cash strapped hospitals, mental health trusts and primary care services. Many NRCPD registered interpreters can no longer get any medical bookings now. Many Deaf people are not provided with registered interpreters when attending appointments. The examples of interpreters being used are few and far between. Just see the Our Health in Your Hands work for surveys and, for real life examples, the BSL Act Spit the Dummy campaign. Contract holders often send BSL users to hospitals to interpret who then tell Deaf people they left their yellow badge at home (the NRCPD one).

Outsourcing contracts to providers who are able to get away with not using registered personnel is going back in time and it goes against the government’s health and social care agenda. The only antidote to this is to ensure that all medical services book a NRCPD Registered Interpreter for Deaf people at their appointments. We know the damage it does if they do not. See the RNID’s A Simple Cure report, the TEA report. See the current work by OHIYH. See SignHealth’s long awaited Sick of It report, launching soon.

To ensure only NRCPD Registered Interpreters are used in medical settings is not going back to a time when the medical model is the prevailing paradigm. Sign Language Interpreters will not have to change their behaviour whilst interpreting nor will they be recognised as only being used for appointments. It is merely a step towards providers only being allowed to book Registered Interpreters rather than the situation now where Deaf people sign consent without knowledge of what they sign, struggle to understand how to take medication, their diagnoses, their prognosis and any treatments prescribed.

Whether PSA accreditation will actually get us a step closer to statutory regulation is unknown. Yet. PSA takes responsibility for both overseeing statutory regulators as well as voluntary registers. It requires registers to undertake audits, to make themselves more fit for purpose. The PSA can only improve the NRCPD and strengthen our position in getting ourselves seen as professionals and ensuring Deaf people have appropriate access. At medical appointments.

We will still work in the media, in courts, at police stations, at art galleries, at wedding and funerals, in work places, at conferences and anywhere else that Deaf people are present and want to gain access in a culturally appropriate way, in sign language. Let’s not confuse models of deafness with one of the areas in which we work. Or used to. With some work by the register we may well work in medical settings once more.

Yellow Fever: Causing Confusion over Registered Interpreters

Sign Language Interpreters in the UK are regulated by the NRCPD. The main, and only for most, professional membership association is ASLI. The differences are clear cut. One regulates: provides a register, deals with complaints and looks at how to become a stronger regulator to ensure that in future the profession will be protected. One supports and develops the profession by providing training, CPD, information and guidance, representation at all levels and strong networks of interpreters so we are all in contact locally and nationally.

The NRPCD could still do some more work on publicising the register. They initiated the Sign Safe campaign this year, trademarking the term along with the yellow registration badge. With the additional hard work of interpreters the message has been getting out to the Deaf community: an NRCPD registered interpreter has a ‘yellow badge’. A registered interpreter is a mark of someone who has been through training and is safe to practice. Someone who turns up at an appointment with no badge is someone who has not yet gone through training or is not committed to providing a certain safeguard for Deaf consumers, or to those bookings interpreters, where users can submit a complaint.

The system may not be perfect but it is still important we have faith in that system and all work towards improving it.

Even interpreters who have been long time opponents of the register have joined up in recent years. We have come to a watershed moment. The NRCPD have made a few unpopular decisions recently causing uproar. This is partly due to the legality of CRB checks. It is apparently safer to ask interpreters to hold their own CRB checks and to ask the consumer to check them. Not easy when not using a reputable agency, not easy for Deaf people trying to book direct. This decision is in part due to the government changes from CRB to DBS checks and the decision that the spoken language interpreters’ register, NRPSI, could not hold details. (NB: NRPSI after representations from professional associations now includes standard CRB/DBS checks and provides details of security clearances in their listings.) All interpreters know how easy it is for them to be in situations where they are left alone with the vulnerable. The government is of the opinion that interpreters will be in the presence of other professionals at all times which is not the reality. An unscrupulous interpreter could very easily do a lot of damage, were they that way inclined, to the Deaf person they are with. The naivety of the government in making these blanket decisions about interpreters is astounding. They clearly have not consulted nor listened.

Just as we have seen over the last 18 months, the continuing solidarity of NRPSI registered interpreters, despite criticisms or government changes, is still as apparent today. They are supporting and publicising their register in order to distinguish trained professionals from those with no interpreting qualifications.

All Sign Language Interpreters seem to want the same thing: regulation, an independent register, more protection of our title and profession; we just cannot agree on how to do it. Perhaps it is easier for us to rally against each other? Perhaps the only time some of us feel we have a voice is when we are arguing with each other? Or perhaps some of us just do not want to work together or know how. Just as we have seen a split in those supporting the register, we have a seen a split in those willing to be part of ASLI.

A few years ago an alternative membership organisation was set up under the guise of disagreeing with compulsory CPD, a move that later saw a u-turn decision usually only seen in government departments. This very cheap organisation, offering no benefits bar insurance and a badge, attracted interpreters by cost who did not value being part of a profession. Whereas for even less than the membership fee, at around £35, interpreters can get insurance from companies such as Hiscox.

Why bother to mention this association when there are bigger things to focus on? One wonders why interpreters would support an organisation such as this and what the motivation is behind the latest move which does not support the interpreting consumer’s need for clarity, undermines the register and is more evidence of a lack of support for the profession: the latest membership badge is yellow.


BSL Presentation on Interpreters: A Change of Contract or a Change of Heart

A big thank you to Paul Neal of Neal Communications Agency (NCA) for making this video.

It is a completely accurate description, in BSL (transcript in English available), of what is currently happening to the sign language interpreting profession in the UK.

The registration system for interpreters is often misunderstood with Deaf people confusing level 6 in BSL as qualified and not realising interpreters need to complete interpreter training as well in order to register.

There is a good summary of the risks of using signers or CSWs, not only the obvious immediate risk to the Deaf community, but the short and long-term risks to the interpreting profession as a whole and the subsequent effect that will have on Deaf access if these trends are allowed to continue.

Other agencies seem to have misunderstood, are unaware of these risks or are actively using this to increase their own profits. Shockingly there are some Deaf-led agencies guilty of this, who do not have the insight to see the damage they do to their own community.

For me, NCA is the benchmark other agencies, especially Deaf-led, should aspire to follow as an agency with a complete understanding of the market, the risks to the interpreting profession and most importantly to the Deaf community we are all supposed to be here to serve.