#ScrapTheFramework latest: 1000 sign the letter, framework is not fit for purpose

As reported on the Limping Chicken blog earlier in the week, over 1000 signatories signed the open letter to Francis Maude MP, asking him to #ScrapTheFramework.
The letter included Len McCluskey, General Secretary of Unite the Union, leading campaign organisations and several MPs.
You can read the letter on NUBSLI’s campaign page.
This framework will change the way interpreting services are delivered to Deaf people in the UK, as well as covering all spoken language interpreting and other communication support such as lip speakers, deafblind interpreters, note takers and speech to text reporters. Privatisation of a whole sector in one go.
There is still work to be done in making representations to the Crown Commercial Service as there is a proposed two-hour minimum for interpreters and no travel expenses.
Aside from terms and conditions and fees the actual framework needs much more work. There are no stipulations about where Trainee Sign Language Interpreters (TSLIs) are able to work leaving agencies able to put Trainees into child protection and mental health. The NRCPD’s view. As long as registration is stipulated that is fine. It is not. Registered is RSLI: Registered Sign Language Interpreter. TSLI is on the register but not registered. Confused? So is everyone else. Trainees have yet to reach the National Occupational Standards and as such need to be protected and Deaf people safeguarded appropriately. NRCPD states on their website that Trainees should not work in legal settings and mental health. NRCPD, do what you say and tell the CCS no Trainees in mental health. Child protection should be explicitly stated too. As an unwritten rule the interpreting community has recognised this area as a no go for Trainees for years due to its legal as well as it’s moral nature.
On the spoken language interpreting side, there are low level qualifications stated for all areas, leaving the quality of provision dangerously low. Given that most agencies are motivated by profit the lowest possible common denominator gets the job not who is the most suitable. Private contracts are hardly safe when monitoring is left in the hands of private agencies who can make up their own figures (cf Ministry of Justice framework and ALS now Capita TI).
The way Deaf people are talked about is patronising and erroneous. “Non-spoken”, interpreters enable Deaf people “to access hearing” and if you are Deafblind you have access to video relay services. Hardly written from the basis of good knowledge and practice, or even common sense. No. This framework is a disaster waiting to happen.

What do you know about the new framework agreement?

This is some of what you really should know about the new framework for all interpreting and other services across the UK. You’ve probably seen that there was BSL levels 1-4 listed as interpreting qualifications and that these, due to public pressure, have been removed from the agreement. Well we haven’t seen confirmation of that yet.
The fact NUBSLI made representations about this and a number of other points, all of which have been passed over, points to a glaringly obvious fact. This framework has not being created in consultation with interpreters, the eventual suppliers of contracts which will be bought from the framework. Or Deaf people who the government hopes will have all public service interpreting via contracts from the framework.
Who has been consulted?
The Crown Commercial Service say they have consulted ‘extensively’. With who? Customers i.e government departments: NHS, DWP and … Organisations i.e. businesses, agencies and “Signature, the commercial arm of NRCPD”.
Who else have they consulted?
Suppliers. Well not the actual suppliers who are interpreters. The larger BSL agencies. Who? Clarion, Sign Solutions, Action on Hearing Loss and Newham Language Shop were the four BSL agencies present at a stakeholder day. The large spoken language interpreter agencies were present: Big Word, Pearl… amongst others.
Have they consulted NRCPD or NRPSI?
Frances Maude MP, Minister for the Cabinet Office and paymaster general, does not mention them in his reply to my letter via my MP Tessa Jowell. Tokenistic phone calls and emails seem to be the only thing that have occurred.
Who else haven’t they consulted?
Deaf people. No consultation, no equality impact assessment. In fact Deaf people have been told very little apart from “we object”. What good is that without action? Inaction is almost as good as saying “we support.”
What can we expect?
More sub-contracting – it is expected up to three agencies will be awarded places on the framework for each Lot. ‘Non-spoken interpreting’ is Lot 4. See above for the likely candidates. Although government has ‘commitments’ to support SMEs to win government contracts, the contracts get ever larger and so do the suppliers. Cross reference: UK-wide MoJ contract with one supplier: Capita, one of the big four.
How do the big suppliers fill local smaller contracts? Sub-contracting. Where does that leave the interpreter? Two businesses taking a fee and less being offered to the interpreter per job.
What does that leave the Deaf person? Usually with a signer because they are cheaper.
Two-hour minimums: interpreters have become an hourly-paid commodity with no value given to experience, training and commitment to the profession. Research shows the Deaf community want committed experienced interpreters who are involved in the Deaf community. More of us are now relying on other paid work to top up interpreting hours. Many have taken on interpreting as a second job to make up hours/pay from other part-time work. Nearly 50% are considering leaving the profession and of those most have over 10 years experience. The Deaf community are getting the opposite of what they want.
Reduced quality and standards:
In the framework if a supplier can not get a qualified interpreter they can just put in the next best thing. As we have seen with existing contracts, that will be anyone with a basic sign language qualification. The standards quoted are lip service, with next to no monitoring of government contracts (link) the agencies will run riot.
How wide-spread is this framework likely to be?
It will operate across the UK.
80 customers have been consulted: government departments, local authorities, the NHS, DWP i.e. AtW.
A clause in the draft language specification states that agencies with a place on the framework must encourage other statutory organisations to purchase contracts from the framework. The clear intent is that all interpreting UK wide, signed and spoken, will go through one very large framework with up to three suppliers on each lot.
What about monitoring and evaluation?
There is none. Well companies do their own which means the same thing. They are always going to come out looking great, despite what is happening on the ground.
And where are we currently? Months behind their deadline CCS are rushing through what will be the biggest disaster for both the interpreting profession and Deaf people. Contracts are supposedly with lawyers and there are no reassurances that when back they won’t just be put out for tender without consultation. Notices are supposed to go out by the end of January and the go live date is April. But then with a contracts this full of loopholes why would the government want to consult with anyone?
Join NUBSLI, we oppose the framework.