Comment from Diana Kautzky

Thank you for the opportunity to comment on this rule proposal. First and foremost I support the proposed rule.

This is a rule change that has been needed to recognize the Independent Contractor aspect in the field of language interpretation. Clarifying the rule will complement the standard in which language interpreters have historically worked and it also suits the way in which services are provided.

As an Owner of a interpreting agency for the last 25 years, I see the important role interpreters bring in assuring equal access through the Americans with Disabilities Act (ADA) and how much interpreters contribute to the economy, due process, national security, health care and all other aspects of life. Our business primarily provides sign language interpreting and this allows for Deaf and hard of hearing individuals to lead productive lives through their work and contribution to our economy. Access gives Deaf and hard of hearing people the ability to participate and the benefactors of such access affects all of the American companies, markets, agencies and institutions.

The language industry, which includes sign language interpreters are considered essential workers. They provide hundreds of millions of communication access services whether its over video phone, in person or telephonically. And in a wide variety of settings. We support the Intelligence Community, domestic law enforcement, and the Department of Defense by providing interpreters and translators to a myriad of federal agencies.

We do this with a workforce that is 80% freelance, and has been so for more than 70 years. And the compensation we provide to our professional, educated, and middle-class workforce is well above the average annual income in the US. The median earnings of translators, according to the American Translators Association, is more than $80,000 per year.

Finally, repeated third-party surveys of the workforce indicate that an overwhelming majority feel the Independent Contractor status suits they way in which interpreters are secured to provide services and to do business. While employee status may work for other labor sectors, Interpreters and Translators do not fall within this sector when they are working as a private practice for multitudes of customers including referral agencies such as mine, using a professional knowledge base to complete their work, managing their own work schedules, and handling of all of their incidental expenses (insurance, travel, marketing, equipment, taxes, etc.)

I commend you in proposing this modification and look forward to a swift process to implement this change. Its long overdue. If there is anything I can do to offer further support, please feel free to contact me.

Comment ID: WHD-2020-0007-0139 | 18-Oct-20

Categorized under Health, Independence

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