Unless you've been hiding from the world, you're probably aware of all the controversies swirling around the Registry of Interpreters for the Deaf (RID) lately. This blog post is not about the controversies, but focuses instead on an idea that I keep seeing mentioned in various social media spaces and blog posts.
One idea currently bouncing around the social media echo chamber is that the time has come to explore competing organizations offering interpreting credentials. There is even a motion that has been referred to committee with the National Association of the Deaf (NAD) to do exactly that.
Focusing on the argument that monopolies are inherently bad, we first need to examine what monopolies actually are. A monopoly is an economic principle that suggests an entity has control of a particular commodity and can limit the available supply of that commodity. This is characterized by three key features: a lack of competition, a lack of viable substitute options, and a price point that is far above the seller's marginal cost that leads to an artificially high profit margin.
Let's take each of these features in turn.
First, the commodity that RID sells is an interpreting certification. In order for them to be a monopoly, they would have to be the only ones selling a certification. They aren't.
For a long time, NAD hosted their own interpreting certification. Texas instituted the Board of Evaluation of Interpreters (BEI) Certification Program, which is now used in whole or in part by several other states. Numerous states have hosted various incarnations of state qualification tests. Boys Town National Research Hospitalanswered the demand for educational credentialing by creating the Educational Interpreter Performance Assessment (EIPA). RID has never been in the business of chasing down other organizations and forcing them to close their services in order to protect their own branded credential.
RID's respectful distance to the BEI testing framework is notable. Offering certified status to EIPA holders was done in response to a concerned community wanting continuing education evaluation of interpreters in the exploding educational market and the interpreters practicing in that arena desperate for professionalization to bolster their wages and provide support to them in an often hostile and oppressive employment environment. Hardly a hostile takeover. The ill-fated collaboration with NAD to create the NIC was also never about defending RID's brand, but about responding to the demands of the community served by both organizations. The evolution may have been botched, but the foundation was never about killing off the NAD credential (which still many interpreters still proudly hold and rightly use to claim themselves as certified).
The second criteria is the lack of viable substitute options. As mentioned above, there are numerous other credentials floating around. We can argue whether those credentials are truly viable. RID is easily the most well-known provider of interpreting credentials. Plenty of hiring entities that use RID's credentials, and no others, as the minimum standard to consider an applicant for employment. However, RID is not responsible for the actions of a government employee who writes a requirement for RID certification into a solicitation or for a VRS company who requires a certification in order to achieve a certain wage point.
When people complain about a state license that is tied to an RID credential, that is the fault of those who wrote their law. I've been working for around nine years now to get license legislation passed in Maryland and our working group saw early the danger of tying a law to a single credential. When RID retired the Certificate of Interpretation (CI) and the Certificate of Transliteration (CT) for the National Interpreter Certification (NIC), several states scrambled to revise their laws to reflect the change in credentials. Writing a law that is too prescriptive is a mistake, but not RID's. When asked, they have offered us guidance in drafting our legislation, but they have never once demanded that RID be established as the standard in our state for licensing. Without a lobbying firm on retainer or even a consistent member of staff charged with lobbying activities, RID clearly lacks the capacity (not to mention the desire) to jealously guard their market share.
Now, let's examine the idea that RID is charging prices that artificially pad a high profit margin. Social media arguments repeatedly accuse RID of getting rich off of our testing fees. If you have been paying attention to the controversies, you have probably seen arguments around RID hemorrhaging cash for the very expensive fiasco of the New Orleans conference and a couple of pricey lawsuits. People with no idea how to read a financial statement look at the bottom line and cluck their tongues at the nearly $3 million dollars in "assets". They don't bother to actually read the report to see that only around $356K of that is actually cash in the bank and, of that, only $109K is available for general use. The rest of that $3 million figure is tied up in liabilities and debt.
We grouse about laying out money for the testing, but most of RID's income is from our membership dues. In 2017, RID collected only $54,867 in certification testing fees. Dues amounted to $1,423,570. Even looking at 2016, when certification fees were over half a million dollars, dues still represented three times the income of the organization. RID's net profit in 2017 was just $12 per member. In 2016 it was a measly $3. I hardly think that qualifies as a high profit margin. When more people take the test, more subsidizing from the membership pot is required as the fees collected do not cover the costs of testing.
RID contributed ~$190K to CASLI to support the development of the new test. Consider how much CASLI will have to charge per test to pay back the investment of development (which is not completed and will likely total around a million dollars), to pay for the costs of maintaining and operating the credential, and to set aside funds for future cycles of test development as the test ages and needs to be revised to reflect changing market trends.
Market Confusion Hinders Us
The features of a monopoly aside, the biggest problem with this argument is that we are conflating an economic principle with the issue of quality controls. No one seriously considers the Bar exam a monopoly. We don't look at the medical field and accept certifications outside of the Board examinations either. Why do we think it's a good idea to have multiple certifying bodies in our field? We've all dealt with clients who don't understand the alphabet soup of certifications floating around as it is. How many CDIs have been cold contacted by organizations looking for hearing interpreters? The acronyms in our field are rich with meaning for us, but mean very little to a naive reader.
RID seems to agree with the community that they've been doing a bad job of certification for quite some time now. CASLI is their attempt to fix that process by creating an independent organization that is solely responsible for certification, leaving RID free to pursue advocacy, scholarship, research, publication, and more. However, CASLI is going to cost us a great deal in the future as the price for testing will no longer be subsidized by the rich pot of annual membership dues. We already speak about pipeline problems (not enough qualified people entering the profession) and a supply problem (not enough qualified people now) that is only going to get worse as the older generation exits our top heavy field. How much of a barrier will a thousand dollar (or more) test constitute in the new world order?
There is a great deal to discuss around the idea of establishing an entirely new testing organization under the auspices of NAD. But using the argument that RID represents a "monopoly" isn't a valid point. In fact, as shown above, the abundance of competing credentials is an argument against yet anotherorganization tossing more acronyms into the already confusing array of letters floating around our field.
Let's not muddy an already complicated discussion by drawing false comparisons to economic theories.