SB863 and Workers’ Compensation Interpreters Fee Schedule-Letter To DIR Director Christine Baker SB863 rulemaking, is uncalled for, wrong headed and unfair to all concerned. SB863 and Workers’ Compensation Interpreters Fee Schedule To : Christine Baker, Director, Department of Industrial Relations; Destie Overpeck, Acting Administrative Director, Division of Workers Compensation. RE: SB863 and Workers’ Compensation Interpreters Fee Schedule My name is Angie Birchfield and I am the Unit Chair for TTIG-The Translators and Interpreters Guild. We represent Independent Court Certified and Registered Interpreters throughout California and nationally. We are submitting our comments regarding the fee schedule update mandated by Senate Bill 863 (Ch. 363, Stats. 2012). Revisions to the interpreter fee schedule adopted per SB863 must take into account the freelance interpreters’ scheduling needs, our contracting through agencies/Language Services Providers (LSP) and the myriad other challenges we face in earning a living wage while providing a crucial service. There are many fine LSP’s in California who provide excellent services and scheduling conveniences for their clients, the insurance carriers and law firms. However, if insurance carriers value this service they should be willing to add a premium to pay for it and not expect the independent interpreter to cut their already low fees to accommodate the convenience and price setting benefits that insurance carriers currently enjoy through their LSPs. Preferred Provider pricing, higher liens fees and independent reviews ought not to cut costs at the expense of independent, self-employed, freelance interpreters who already carry the burden of managing their work schedule, doing outreach, maintaining their certification as well as paying self employment tax, paying into individual retirement accounts and covering their own medical insurance. Nor should cost cutting come at the expense of using certified interpreters. The number of available Court Certified Spanish Interpreters has recently increased. This is due in part to a fall off in hiring by the Court System and recent changes in the State Exam process. As a whole, the interpreting field in California has remained in a rate slump for the past 10 years due to the economy. However, the cost of living continues to rise and the standards and protocol of our profession must and should be maintained. An interpreter’s qualifications should only be tested and certified by the entities that have been put in place to do so. These consist of experts in the field of linguistics and interpretation. An interpreter should not be qualified by an insurance administrator, especially in light of the glut of certified interpreters in California. This practice, proposed in the SB863 rulemaking, is uncalled for, wrong headed and unfair to all concerned. The Independent Contractor should be entitled to earn a full day’s wage and the only way that can be attained is by working on a 3-hour/6-hour per diem basis whether it is for a deposition or a Med Legal assignment. Otherwise, the ability of independent interpreters to earn a living wage is unfairly curtained. It is our pleasure and desire to continue our working relationship with all involved in the Worker’s Compensation field. We have developed many long lasting relationships with the legal community as with the LSP’s that facilitate our work. We look forward to what the future holds for us and are grateful for changes that improve the quality of the work product and implement the use of Certified Interpreters. Sincerely, Angie Birchfield TTIG Unit Chair
Posted on: Thu, 28 Aug 2014 05:32:46 +0000
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