The DWC is hopeful a draft Interpreter Fee Schedule will be posted on the DWC webpage within the next 4 weeks. The DWC will send out a 'newsline' announcing the posting and letting the public know they can comment on-line regarding the proposal.
After the DWC reviews the comments on the draft regulations, they may make revisions to the draft regulations and will begin the formal rulemaking process. The proposed regulations will issue, and the DWC will hold a public hearing approximately 45 days later.
At this public hearing, the public will be allowed to make oral comments and/or submit written comments.
If further changes are required, the revised regulations will issue again for a 15-day comment period, during which the public may submit written comments.
Eventually, the final regulations will be filed with the Office of Administrative Law for approval. The DWC will notify the public when the regulations are final and the effective date.
IGA makes special note of the public review and comment provisions in the upcoming regulation process.
These are opportunities for all of us, the independent interpreters most affected by the new rules, to make our unified voices heard.
We need to invite community groups and immigrants' rights organizations to join us in calling for safeguarding professional language access services for injured workers.
Rest assured that the insurance lobby will weigh in, pressing for "cost containment". But our fees, our livelihood, is not where cost containment can happen, we are down to the bone. We are the self employed, on the hook for everything from collections to insurance to retirement benefits. We've already paid and trained to become certified and continue to pay and train to stay certified.That is why all an agency has to do is call the numbers on a list posted online by the AOC. No training or vetting required, no benefits paid and no exposure other than the agency's own overhead.
So why is it that the fees paid directly to the independent certified interpreter have become the target of cost containment? Why would the interpreter need to become part of an MPN (Medical Provider Network)?
The 3-hour half day minimum and the 3-6 hour full day.
The 24 hour cancellation policy.
The full day rate for starts between 10:30am and 1:30pm.
Make you opinion count, make your voice heard.