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Our office has recently learned that there will be a
hearing this Thursday, April 8, before the Joint Committee on
Administrative Rules (JCAR) regarding the proposed amendment to 5
CSR 100-200.170 (Skill Level Standards Rule). In particular, a few
people have convinced JCAR to hold a hearing so that
they can complain about the proposal to allow RID CI/CT and CSC
holders who move into Missouri to work only in settings where an
MICS Advanced (Level 4) certification holder can work. We need
people who are willing to come to Jefferson City this week and
testify in support of the proposed rule. The
hearing is scheduled to be held in the Senate Lounge and will start
at 12:00 noon. Please let me know no later than tomorrow morning if
you will be able to testify, as I will need to submit the names of
supporting witnesses on Monday afternoon. You can let me know by
sending e-mail to remiller@mcdhh.state.mo.us, calling 573-526-5205
(Voice/TTY), or faxing to 573-526-5209.
Clarification of the Issue for JCAR
The issue is one that has been talked about ever since the Missouri
Interpreters Certification System (MICS) became law in 1994. At that
time the law was written so as to require that all interpreters
working in Missouri had to be MICS certified. At that time, everyone
with certain RID or NAD certifications was "grandfathered" into the
MICS (meaning they were given an MICS certification without having
to test here).
After the grandfathering period ended, any RID certified interpreter
who moved into our state had to either "convert" their RID
certification to an MICS certification or take the MICS test and get
an MICS certification. At that time, the Registry of Interpreters
for the Deaf was contacted and asked for the necessary information
with which to reasonably "convert" various RID certifications (we
needed to know the cutting scores that they used). The RID office
refused to share the needed information, so for a period of years no
one could "convert" an RID certification to an MICS certification.
The only way they could get a Missouri license was to take the MICS
performance test.
Then in 2001-2002, the Board for Certification of Interpreters (BCI)
made the decision to automatically convert any RID CI/CT or CSC
holder to an MICS "Advanced" (Level 4} certification. Some people
felt that the RID CI/CT was an "entry level" certification, and they
should be given an "Intermediate"
(Level 3) MICS certification. Others, especially some St. Louis RID
Chapter members, felt that the RID certification was the best, and
that all CI/CT or CSC holders should be converted to an MICS
"Comprehensive" (Level 5). With knowledge that some RID CI/CT and
CSC were excellent, and that others were not so good, the BCI
adopted the position that they would automatically convert them all
to an "Advanced" MICS certification.
Then in August 0f 2002 the law was changed to require the
recognition of RID CI/CT and CSC holders in Missouri (again at the
request of some St. Louis RID interpreters). Then in the Spring of
2003 the State Committee of Interpreters (SCI) adopted a rule that
said an interpreter could not work in settings beyond their skill
level as specified in the Skill Level Standards rule of the MICS.
But at that time there was no mention in our Skill Level Standards
rule of CI/CT or CSC certifications. So, the BCI recommended and
the Commission approved an amendment that would add to our Skill
Level Standards rule the stipulation that an RID CI/CT or CSC holder
could work in settings where an MICS "Advanced" certification holder
could work (thus making it equivalent to the conversion scheme that
had been adopted two years ago.
The proposed rule was published in the Missouri Register on December
15, 2003, and the period for public comment ended on January 14,
2004. Of the comments that were received concerning the proposed
amendment to the Skill Level Standards rule, 86% of the commentators
supported the proposed rule
change while only 14% opposed the proposed change. Several people
who are opposed to the rule (they want RID CI/CT and CSC holders to
be able to work anywhere that an MICS "Comprehensive" holder can
work) complained loud enough to JCAR that JCAR has scheduled a
public hearing regarding the RID
placement issue.
If you feel that CI/CT or CSC is reasonably placed equivalent to an
MICS "Advanced" then we would appreciate your support on this issue.
WHAT YOU CAN DO
1. You can come to Jefferson City and testify in support of the
proposed rule amendment this Thursday at noon (the hearing will be
in the Senate Lounge). If you are able to testify please notify me
of your intention by Monday morning, as I have to turn in a witness
list on Monday afternoon.
2. If you can't come to testify, you can immediately send an e-mail
or letter to the following person expressing your support for the
proposed amendment to 5 CSR 100-200.170 (Skill Level Standards
Rule):
Ms. Cindy Kadlec, Director
Joint Committee on Administrative Rules
State Capitol, Room B-8
Jefferson City, MO 65101
E-Mail: ckadlec@senate.state.mo.us
In your testimony, letter, or e-mail you should do the following:
1) Give your full name and address.
2) Indicate that you support the proposed amendment to 5 CSR
100-200.170 (Skill Level Standards Rule).
3) Briefly indicate why you think it is reasonable to treat an RID
CI/CT or CSC certification holder as if they were an "Advanced"
(Level 4) certification holder.
Talking points might be:
1) RID developed its own "Legal Specialist" certification because
they don't consider CI/CT or CSC holders competent to work in
courtrooms. But if we gave them a "Comprehensive" in the Skill Level
Standards rule they could work in any Missouri courtroom.
2) The RID tests are pass/fail tests. RID has refused to provide
cutting point scores for their tests. If the cutting point were as
low as 60% to pass, then we clearly would have a great range of
skills in CI/CT and CSC holders, ranging all the way from some who
could only accurately interpret 60% of what they see and hear to
others who were nearly perfect. But if the cutting point were 98% to
pass, then all CI/CT and CSC holders would be very good. BUT WE HAVE
NO IDEA WHERE THE CUTTING POINT IS FOR RID TESTS, and thus we have
no way of knowing how good a particular interpreter is.
3) The RID CI/CT and CSC certifications are referred to by RID as
"generalist" certifications, and they have been referred to in the
past as "entry level" certifications.
4) The Missouri Interpreters Certification System converts only the
"top" in other certification systems to the "top" in the MICS. With
that in mind, we convert a person who holds a CI/CT or CSC plus the
Legal certificate to our "Comprehensive" (Level 5).
5) An RID interpreter moving into Missouri who thinks they are more
skilled than the “Advanced” MICS certification can always test in
the MICS system and demonstrate their skills.
6) If you have any personal "horror" stories involving the lack of
skills among RID CI/CT or CSC holders, you should feel free to talk
about your experiences.
JCAR will probably decide immediately after the hearing whether or
not they will accept the proposed amendment. Therefore, if you are
going to write a letter or send an e-mail supporting the proposed
amendment it has to be done immediately, so that JCAR will receive
it before next Thursday.
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