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Protection of Title
AGM Presentation
March 26, 2006

Protection of Title in Word Format

To aid in the discussion, we provide some definitions:

Licensure - (Exclusive Scope of Practice) - This is where, by law, only members of the specified association can “do this job”. Practitioners must meet the educational standards and pass the qualifying exams set by the association in order to be licensed to work in that field. Teachers, doctors, lawyers would fall into this category.

Protection of Title - (Right to Title) - This is where a “title” or “brand name” is reserved for use by only members of the association. Non-members can still “do the job”, but they do not have the right to use the reserved “brand name”.

Comments from the Community seem to indicate that the two concepts are being used interchangeably. For this reason, we feel it is necessary to reiterate that:

Protection of Title…
… is not licensure nor is it our first step towards licensure.
· The profession of Sign language interpreting can never be licensed as Exclusive Scope of Practice because we are not able to regulate the educational curriculum of practitioners.
… does not prevent unqualified people from self- identifying or working as interpreters.

Clear of any misconception, we are now able to analyze the true benefits and impacts of this initiative …

Protection of Title…
… does establish a protected title restricted for use by ACRID members.
· does not prevent non-members from doing the same job under a similar title. There is no recourse for ACRID or the Deaf Community
· does not prevent non-members from using the protected title. ACRID would be responsible for monitoring/rectifying the situation (potentially high cost both financially and in volunteer hours)
· does not protect the Deaf Community from the assumption that hiring a self identifying “title” equates to hiring an ACRID member

… allows members to call ourselves ‘professional’ as a name/title recognized under the government.
· success of receiving approval of P/T depends on the current government’s political climate which determines the definition of ‘public interest’
· the application may not be successful if the government determines that our chosen criteria ‘limits’ opportunities for employment
· ACRID may or may not be named in the legislation as the regulatory body (again dependant on the government’s position)
· as a regulated body under the government, ACRID’s autonomy / flexibility for change is restricted by the regulating government Act
· changes to ACRID criteria could be made (ie. membership criteria) however, it would require the time and red tape that is associated with any government process
· ACRID bylaws would need to be changed to coincide with the government Act
· changes made to the Act would require ACRID to revamp accordingly
· ACRID would be required to clean up its documentation to meet government standards
· ACRID would be required to maintain the services of a Registrar
· cost in volunteer hours - high; financial costs - unknown

… gives government recognition which may provide more “clout” when lobbying for change.
· it appears that the current Legislative definition of “access” means providing CART services instead of interpreters.
· having a “title” may not be effective in creating a change in the government attitude
· ACRID’s limited resources may be better used to advocate with the Deaf Community for their rights as tax-payers in a concentrated lobby campaign

… determines a minimum educational standard for ACRID membership.
· ACRID could achieve this standard without Protection of Title by adopting the new membership criteria proposed by AVLIC
· because AVLIC’s definition of “educational standard” is broad, POARA may require documentation of the specific criteria that ACRID would use to define the baseline of minimum educational criteria
· because our members are graduates from a variety of programs, ACRID would be required to evaluate / document the educational criteria standards within those interpreting programs for comparison with our baseline minimum educational criteria
· to verify the educational standards of new members, ACRID would be required to regularly reevaluate programs’ standards to determine if those standards continue to meet our educational criteria
· once approved, any changes to educational criteria standards would have to be passed through law which could take 1-2 years
· cost in volunteer hours - very high; financial costs - unknown

… increases credibility to employers and public by ensuring a minimum education standard.
· Protection of Title does not obligate / require employers to hire ACRID members
· though a minimum education standard will be established through the proposed AVLIC membership criteria, ‘credibility’ as a profession will still rest entirely on the professional behavior of interpreters
· the promotion of hiring ACRID members is already mandated by our Society Objects without Protection of Title
· currently, our human resources are not adequate for a concentrated effort of this magnitude

… would allow us to establish a policy determining minimum criteria standards for membership (creating levels of interpreters and their scope) through screening tests.
· requires a very strong, complex argument proving that this would be in the publics’ best interest
· our application may be declined as the current government is not accepting these types of policies (seen as limiting opportunities for employment)
· would require ACRID to develop/administer screening evaluation tests and periodically re-evaluate those test materials
· could “borrow” the AVLIC COI standards as one of the levels, however, ACRID wouldn’t be able to say that holding the COI automatically makes an interpreter eligible for membership (COI is a standard established outside of the provincial government’s jurisdiction)
· must have documentation to aid in evaluating, comparing certificates from outside AVLIC to determine qualifications for those members from outside Alta/Canada
· the whole idea of an ‘evaluation’ process may deter interpreters from wanting to apply for ACRID membership
· cost in volunteer hours and finances - exceedingly high

… increases our accountability as a profession - to government, Deaf community, and ourselves with a regulated grievance/discipline procedure.
· the grievance/discipline procedure applies only to ACRID members - it is not a recourse against non-members
· ACRID’s current grievance procedures would need to be revamped to comply with the procedures outlined in the government regulations
· would restrict ACRID’s flexibility to determine discipline resulting from a grievance
· AVLIC’s DRP would not be accessible to ACRID members as part of the appeal process because the province will not recognize procedures developed outside of its jurisdiction
· a regulated discipline process has the potential to create an environment of less accountability as interpreters may become even more reluctant to bring forward a grievance against another interpreter
· cost in volunteer hours - high; financial cost - potentially high

Issues specific to a POARA regulated ACRID and its relationship with AVLIC (summarized from above info) -
· potential conflicts may arise because a national organization’s policies/standards are not recognized under the provincial government
· changes made at a national level would be difficult and time consuming to incorporate and may be a challenge to comply with depending on the requirements of provincial regulation
· if the ability to determine levels of interpreters is approved, the COI would not be recognized as an automatic qualification for membership because it’s nationally produced and out of AB’s jurisdiction
· DRP could not be used as part of the appeal process currently available to ACRID members as it too is outside jurisdiction

Expectations from POARA and the government -
· Realistically, we know that we currently do not have the number of interpreters needed to meet the Community’s demand. The addition of VRS may further complicate this situation. Any effort to convince the government that we do have the numbers would be in contradiction to the Deaf Community’s argument of a “shortage”, thereby damaging the greater goal of establishing an interpreter training program.
· financial viability to sustain the requirements of a regulated body. Currently, due to cancelled fundraising efforts and the effects of lowered gaming profits, ACRID is struggling to raise funds to maintain basic operating needs.

Finances required to pursue this initiative - (does not include the potential costs of program evaluations that may be needed to determine the specifics of our minimum education criteria)
$ 1,500 for advertising
$ 2,400 for stakeholder consultation meetings
- this total is based on a minimum number of required meetings at an averaged price of $150 per meeting; costs are dependant on location and/or the need for interpreters. POARA requires 4 rounds of consultation meetings with interpreter, Deaf, and employer stakeholder groups in both Edmonton and Calgary:
· basic consultation, education (two meetings left)
· justification of chosen regulations (six meetings)
· clarification and further consultation if any group states opposition (one meeting in each location included in above total)
· defining the details of the chosen regulations (six meetings)
$ 750 application fee
$15,000 contingency legal fund - this fund would be on hand to cover any legal fees arising from making the required changes to the bylaws, grievance procedure and to rectify situations of non-members using the “title” illegally. Gaming monies may not be included in this fund.
$ 400 annual fee - could be covered by increasing membership fees

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