TN 42 (09-17)

A. Policy to interview deaf or hard-of-hearing (DHOH) customers

Section 504 of the Rehabilitation Act of 1973 (P.L. 93-112) mandates that a customer who is DHOH has meaningful access to the Social Security Administration’s (SSA’s) programs, activities, and facilities. This policy requires us to provide sign language interpreter services if a customer who is DHOH indicates he or she needs an interpreter to communicate effectively with SSA.

A customer who is DHOH is not required to use a sign language interpreter with whom he or she cannot effectively communicate. If the interviewer or the DHOH customer determines that effective communication is not occurring, we do not require the customer to continue using that sign language interpreter. Protect the filing date, if applicable, and terminate the interview until we locate an appropriate interpreter. For a description of appropriate interpreters, see GN 00203.012B in this section.

The customer who is DHOH has the option to provide his or her own sign language interpreter at no cost to SSA. When we provide interpreter services, the interpreter must be a certified and qualified sign language interpreter, as defined by the Americans with Disabilities Act (ADA). Managers and Administrative Law Judges (ALJ) are the approving officials who authorize payment for sign language interpreter services and related expenses arranged by SSA. Such payments are subject to prior approval by the approving official. This authorization is within the local purchase authority.

B. Definitions of sign language interpreters

1. Sign language interpreter

A sign language interpreter is a person trained to translate between spoken and signed language. The sign language interpreter listens to speech and repeats it back to the DHOH customer using sign language interpretation, lip reading, cued speech transliteration, or hand gestures. While American Sign Language (ASL) is the most common form of sign language for DHOH customers, there are other sign languages.

2. Certified sign language interpreter

A “certified” sign language interpreter is any person certified by the National Registry of Interpreters for the Deaf (RID), certified by the National Association of the Deaf (NAD), or holds a Level III State screening credential from any State Registry of Interpreters for the Deaf.

3. Qualified sign language interpreter

A “qualified” sign language interpreter is a person who is able to interpret effectively, accurately, and impartially, both receptively and expressively, using specialized terminology necessary for effective communication with us.

C. Procedure to interview a DHOH customer

When initiating communication with a customer who is DHOH:

1. Provide a certified and qualified sign language interpreter for the interview if the customer schedules an appointment and requests an interpreter in advance.

2. Notify management if the SSA-arranged interpreter fails to attend the scheduled interview. Then, contact the SSA-arranged interpreter to inquire about his or her availability to attend the interview. Promptly offer to reschedule the appointment, arrange for another certified and qualified interpreter, or provide an SSA employee who is a qualified interpreter, if available.

3. Inform the customer seeking SSA services who does not have a scheduled appointment that there may be a wait while we serve customers with appointments at their scheduled time. Advise the customer that we can schedule an appointment in the near future and provide an interpreter for the appointment.

   To schedule future appointments, see TC 10010.020.

4. Allow the customer to select his or her preferred method of communication using the 11 x 17 inch DHOH options card when:

   1. The customer does not request an interpreter in advance of the scheduled interview;

   2. The scheduled interpreter fails to attend the interview; or

   3. It is a walk-in interview.

   For more information on the options available on the DHOH options card, see GN 00203.012F in this section.

5. Make sure the customer understands what is taking place during an interview. Pay special attention to how well the customer communicates.

6. Conduct and complete the interview using the communication method preferred by the customer. However, if the customer is unable to communicate effectively using his or her selected method of communication, he or she may select a different method of communication.

7. Use the services of the interpreter accompanying the customer unless communication is ineffective or becomes difficult during the interview.

   In this event, offer to provide another interpreter, or suggest that the customer select another method of communication.

8. When using the services of a non SSA-arranged interpreter, follow the instructions in GN 00203.011H.

9. If the customer provides his or her own interpreter, and you believe that the interpreter is not acting in the customer’s best interest or is not providing accurate information to us, follow the instructions in GN 00203.011I.

D. Procedure to purchase sign language interpreter services and related expenses

1. Who authorizes the cost of interpreter services and related expenses

Managers and ALJs are responsible to identify and retain the services of qualified and certified sign language interpreters as defined in GN 00203.012B in this section. The manager or ALJ is the approving official and authorizes the cost of interpreter services and applicable related expenses prior to the interview with a DHOH customer. For more information on authorization of paid interpreters, see GN 00203.011E.

NOTE: If a customer who is DHOH makes his or her own private arrangements for an interpreter (e.g. bringing a friend, relative, or volunteer to the interview to serve as an interpreter), SSA does not pay for the interpreter’s services.

2. Procedure to pay for interpreter services

The approving official:

1. Contacts agencies or organizations for the deaf to determine a reasonable hourly rate for local sign language interpreters;

2. Pays travel expenses according to Federal Travel Regulations in the Administrative Instructions Manual System (AIMS) Guide; and

3. Pays an approved and reasonable compensation fee for the interpreter’s services. In addition, we compensate the interpreter if we arrange his or her services prior to the interview and the customer who is DHOH fails to attend the interview.

E. Procedure to use the DHOH options card

The 11x17 inch laminated DHOH options card illustrates and explains the communication options available to a customer who is DHOH. The card provides options in both English and Spanish. The card has a laminate finish to provide an easy to erase surface to mark options that are available or unavailable on a daily basis.

Field offices (FO) and card centers must always place the DHOH options cards near the reception windows to provide easy access to the public.

If a customer who is DHOH approaches a reception window without an interpreter, use the DHOH options card by showing it to the customer and ask him or her to select the option he or she prefers.

F. Communication methods listed on the DHOH options card

Deaf or Hard-of-Hearing Options Card

1. Certified and qualified sign language interpreter.

   For the definitions of certified and qualified interpreters, see GN 00203.012B in this section.

2. Certified and qualified video remote interpreter (VRI).

   VRI uses video teleconferencing equipment to provide sign language interpreting services for deaf, hard-of-hearing, or speech-impaired customers through an offsite interpreter.

3. Social Security employee who is a qualified sign language interpreter

   The employee does not need to be a certified interpreter. However, both the customer who is DHOH and the employee conducting the interview must agree the interpreter is qualified.

4. Hand-written notes.

5. Lip reading or speech reading.

6. Social Security employee, if available, who knows American Sign Language (ASL). This employee is not a certified sign language interpreter or a qualified sign language interpreter. Currently, employees who know sign language, but are not certified or qualified, can directly communicate with the customer who is DHOH. The employee cannot interpret between the customer and another employee. This option allows the customer to communicate directly with an employee, one-on-one in person, or through video conferencing technology.

7. UbiDuo.

   The UbiDuo is a portable, two-way communication device that works similarly to text messaging. For instructions on using the UbiDuo, see GN 00203.012G in this section.

8. Another way. If a customer who is DHOH indicates he or she prefers another option, refer to Non-Standard Accommodations GN 00211.001B.2.

NOTE: Advise the customer who is DHOH that he or she may choose one of the currently available options if he or she would like to conduct business with us that day. Otherwise, reschedule the appointment and await a decision from the Center for Section 504 Compliance.

G. Procedure to use the UbiDuo to communicate with customers

Follow these instructions when a DHOH customer chooses the UbiDuo method to communicate with us.

1. If there is a customer at the UbiDuo who is not using it, or who is not helping the customer who is using it, ask the customer who is not using it to step back from the UbiDuo. This ensures protection of the person’s Personally Identifiable Information (PII) while using the UbiDuo.

2. Never connect an UbiDuo device to any workstations or server.

3. Delete any stored conversation after use. Management is responsible for verifying the deletion of stored conversations after each use. This process ensures the removal of all information, including PII.

4. Secure both UbiDuo devices when not in use. If you need to step away from the interview area, secure both devices to prevent a customer from leaving the office with the device.

5. Ensure the Auto-Link feature, which automatically connects the UbiDuo to another UbiDuo without permission, is set to “Off.”

H. References

• GN 00203.011 Special Interviewing Situations: Limited English Proficiency (LEP) or Language Assistance Required

• GN 00203.000 Interviewing – Table of Contents

• TC 10010.020 General Rules for Referrals and Appointments