DIG's position on telework for permanently employed federal sign language interpreters
Deaf in Government (DIG) is a national nonprofit organization that empowers deaf and hard of hearing1 federal employees by helping resolve accessibility issues and promoting an inclusive work environment. DIG collaborates with external entities, including the Office of Personnel Management, the Equal Employment Opportunity Commission, Congress, the White House, the Hearing Loss Association of America, and the National Association of the Deaf (NAD).
This position statement has been developed to guide federal employers in establishing administrative telework policies that preserve and promote the highest standards of communication accessibility and reasonable accommodations for deaf employees, specifically in regards to sign language interpreters.
Teleworking offers significant advantages within the federal sector, such as saving costs and being conducive to employee work-life balance. At the same time, it poses significant challenges for agencies, such as adapting their operations to accommodate teleworking. This is especially true for provisions of sign language interpreting for deaf employees. DIG has learned that increasing numbers of sign language interpreters employed full-time by the government are requesting to work remotely, using video conferencing technology to provide interpreting services.
DIG’s position is that telework is not a viable option for permanently employed federal sign language interpreters and can lead to serious limitations on the ability of federal employees who are deaf to perform their job duties.
Challenges Posed by Video Remote Interpreting (VRI)
Sign language interpreting, by its nature, requires interpreters to be present in a communication setting. With the advent of video networking technology, video remote interpreting may initially seem like a cost-effective alternative to on-site, in-person interpreting; however, it has major drawbacks.
According to the NAD website:
While there are many benefits to using VRI services, there are limits to the effectiveness of VRI in some settings including but not limited to medical, legal, and court situations. In such settings, the NAD strongly believes that VRI services should be provided only if on-site interpreter services are unavailable.
The NAD also states that the following must be considered when determining if video interpreting services are acceptable:
The number of people actively talking or participating (which affects the interpreter’s sight line and therefore the deaf individual’s access to environmental and auditory information)
Whether the situation or matter can be discussed in a two-dimensional manner
Furthermore, the Registry of Interpreters for the Deaf (RID) has a standard practice on video remote interpreting that states:
Situations involving high interactivity, such as multiple participants with less structured turn-taking protocols;
Situations with complex dialogic exchange, such as abstract philosophical interchange or dialogue with veiled intentions or multiple meanings;
Situations involving communications of a sensitive nature;
Situations involving individuals with a secondary disability (e.g. low vision) that impedes their ability to utilize the technology.
When an interpreter, employed by the government to perform sign language interpreting duties on a full-time or part-time basis, provides such services remotely via video, challenges are numerous:
Limits the range of available communication settings. Because of the complex technology requirements needed to facilitate VRI, it is only available in select situations where the deaf employee has access to a video-streaming capable device, high quality audio input, and a high-speed Internet connection.
Not having assurance of quality interpreting. One of the challenges of interpreting services provided via video is the susceptibility of video quality, which depends on numerous factors including Internet speeds, firewalls, connectivity, the lack of seeing (or the interpreter hearing) environmental information.
Interpreter’s access to information is restricted. When an interpreter is not physically present in a communication setting, they miss non-verbal communication information, thus limiting the amount of information they can transfer to the deaf employee. This is especially problematic for conference calls, where an interpreter may only be able to listen in on a conversation and not be able to identify who is talking and/or follow along with on-screen presentations, which degrades the quality of interpreting.
Interpreter’s quality is restricted. Oftentimes, Internet access and technological problems can hinder, or even prevent, the interpreting process from happening successfully. This is among the most common complaints of using VRI. This subsequently affects the quality of interpreting, and oftentimes creates a domino effect in access to information.
Impact on Deaf Employee(s)
Being forced to focus on a screen and not the live action and speakers in the room. With VRI, deaf employees are forced to focus completely on a single screen, limiting their peripheral vision. This creates a plethora of disadvantages, including difficulty in looking back and forth from the interpreter to the PowerPoint presentations or visual aids, not having a sense of connection to the participants, and missing out on visual cues.
Being unable to participate in ad-hoc situations. The interpreter not being physically present eliminates the ability to participate in impromptu interactions, such as conversations in passing, face-to-face meetings in the hallways or offices, and even work get-togethers. These significant but overlooked communication situations facilitate team-building and camaraderie.
Experiencing degradation of communication medium. Receiving signs through a two-dimensional screen can be difficult and straining, especially for extended periods of time. This is exacerbated for people who also have vision issues, such as deaf-blind individuals. This then leads to greater opportunities for misunderstandings and errors.
A number of resources, including the U.S. General Service Administration website, clearly dictate that those ineligible for teleworking are those who have “daily on-site duties or daily handle secure materials” — which includes interpreters.
Telework Enhancement Act of 2010
The Telework Enhancement Act of 2010, Section 6502, “PARTICIPATION,” states that if an employee wishes to telework, the agency must “ensure that telework does not diminish employee performance or agency operations.” If a sign language interpreter attempts to provide interpreting services via telecommuting, this does affect employee performances for both the interpreter and the deaf employee(s) who need the interpreting services. This, in turn, can potentially diminish agency operations—violating the Telework Enhancement Act.
DIG recommends that federal agencies require full-time staff interpreters to interpret in person and on site for deaf employees during all normal business hours. DIG further recommends that staff interpreter positions be excluded from teleworking by default, with any exceptions made on a case-by-case basis and only after careful consideration of the possible impact on deaf employees. Any telework privileges granted to interpreters should be reviewed regularly to assess if they are still compatible with deaf employee needs and preferences.
Additionally, DIG recommends that agencies adopt a perspective wherein the accessibility needs and preferences of deaf employees are prioritized, as a matter of ensuring sound business operations, over interpreters’ unentitled privileges.
National Association of the Deaf. (2008). Position statement: VRI services in hospitals. Retrieved from http://nad.org/issues/technology/vri/position-statement-hospitals
Registry of Interpreters for the Deaf. (2010). Standard practice paper: Video remote interpreting. Retrieved from https://drive.google.com/file/d/0B3DKvZMflFLdTkk4QnM3T1JRR1U/view
Telework Enhancement Act of 2010, 5 U.S.C. § ‘‘§ 6502 (2010).
U.S. General Services Administration. (2014). Chapter 6: Telework Eligibility. Retrieved from http://www.gsa.gov/portal/content/121955
1DIG uses the term “deaf” to include individuals who are deaf, deaf-blind, hard of hearing or late-deafened