The CCS Language Services (interpreting and translation) framework agreement: Frequently Asked Questions
1. What is a framework agreement?
A framework agreement is an ‘umbrella agreement’ that explains the terms (costs, terms and conditions and standards etc) under which individual contracts can be made throughout a fixed period of time; usually up to 4 years.
2. What is good about framework agreements?
They save the government from having to deal with lots of smaller contracts.
3. What is bad about them?
Providing BSL/English interpreting through big agencies means a loss of local services and well established relationships.
For some services (printing, for example) it makes sense to create large centralised services to reduce cost. This model does not work for services where you are paying for people’s time. The erosion of BSL/English interpreters’ fees is placing the profession at risk. This is contrary to the EU guidance on frameworks which places workforce sustainability as a central consideration (EU Public Procurement Directive 2014/24/EU).
4. Who can use the Language Services framework?
Any public service throughout the UK. This includes criminal justice, legal, medical and medical trauma, pharmaceutical, financial, IT, media, children, mental health, transportation, engineering, procurement, marketing, housing, benefits, immigration, defence, security, technical and government (central and local).
5. What does it actually mean for BSL/English interpreters and Deaf people?
The Crown Commercial Service (CCS) has announced that its national framework for Language Services (interpreting and translation) contracts started on 22nd April 2016. BSL/English interpreting and translation is included under the framework under Lot 4. You can read about the framework here.
For BSL/English interpreters it will mean changes to the terms and conditions interpreters work to and an erosion of fees. The framework sets out 2 hour call out, hourly fees and no mandatory requirement to pay for travel. It risks the sustainability of the work force as we anticipate interpreters leaving the profession as a result of these changes.
For Deaf BSL users it will mean that their access to services are at risk as fewer interpreters are likely to accept bookings from contracts under the framework.
6. What are “Lots” and what do they mean?
“Contracting authorities are encouraged to break contracts into lots to facilitate SME participation.” (EU Public Procurement Directive 2014/24/EU).
Lots are different categories that group together different kinds of language services. The services that relate to Deaf people come under Lot 4 of the framework (Non Spoken Face to Face and Video Language), which includes written translation and transcription, telephone and video interpreting services, non-spoken face to face and video interpreting and face to face Interpreting. This covers BSL/English, ISL/English, international sign, Deafblind interpreting, Deaf Relay, speech to text reporting, note taking, cued speech/Makaton and lipspeaking too.
7. Who has won the contracts for the Lots that are relevant to us?
Clarion, the London Borough of Newham Language Shop and Sign Solutions have Lots 4a – 4e, which means they will be providing face to face and video interpreting all over the UK.
Language Empire, thebigword and Prestige Network have Lots 4a – 4e too, plus Lot 1 (the main contract).
Capita and WorldWide Resources Ltd have Lot 1. This is likely to be sub contracted.
DA Languages have Lots 1 and 4a (Greater London including Overseas)
8. What does it mean that one Lot is won by several suppliers?
- Where the terms laid out in the framework agreement are detailed enough for the purchasing authority to be able to identify the best supplier for that particular requirement, then the authority can award the contract without re-opening competition.
- If the terms laid out in the framework agreement are not specific enough for the purchasing authority to be able to identify which supplier could offer them best value for money for that particular requirement, a further mini-competition would be held between all the suppliers on the framework agreement who are capable of meeting the need.
9. What about sub contracting?
Sub contracting remains a concern in the framework.
10. Is it required that NRCPD / NRPSI interpreters are used? Or not?
11. What are NUBSLI’s views/concerns on the framework?
- There is a 2 hour call out fee. Rates are paid hourly. This goes against the industry norm.
- Travel and related costs are to be included within the interpreter rates at framework level. This means that interpreters are expected to absorb the costs. When NUBSLI challenged this, the CCS said: “There are provisions within the specification for customers to agree with suppliers reimbursement for additional travel.”
- Complaints monitoring won’t be made public. We were advised to use Freedom of Information requests, which would be unlikely to provide this information. Late payments with some of the agencies named is already an issue and concerns have already been raised by members.
12. Why didn’t anyone ask us for our views first?
13. What has NUBSLI done about all this?
Since February 2015, NUBSLI has been campaigning against the establishment of a national framework for Language Services (interpreting and translation). See details of our #ScrapTheFramework campaign.
We spent the next ten months in negotiation with the CCS in an attempt to improve the initial drafts, highlighting concerning loopholes and trying to ensure that the framework would maintain standards and safeguard the service users.
14. What is NUBSLI doing next?
- We have already started work with Unite’s legal department on more robust terms and conditions and have been offered support in negotiating contracts directly with providers/agencies.
- We are updating our fees guidance, with interpreters’ input, to make sure it reflects what people are currently charging.
- We have a new freelancers’ pack/buddy scheme and hope to provide more support for TSLIs.
- We will be providing free webinars to members on “How much you charge” and the “Cover My Job” app.
15. What can BSL/English interpreters do?
- Maintain your reasonable fees and terms and conditions.
- Take collective action to prevent erosion of fees, terms and conditions, and customer choice.
- Join NUBSLI (if you aren’t already a member).
16. But doesn’t everyone lose out if BSL/English interpreters refuse to take interpreting work under certain contracts?
Refusal to work for certain contracts is seen as a last resort but is in fact in the best interests of the Deaf community. If unsustainable rates and terms and conditions are being offered, interpreters will leave the profession. Unqualified communication support will be used in its place. In protecting interpreters’ working conditions, we are safeguarding Deaf people’s rights to qualified interpreters and to maintain the quality of access.
17. What can Deaf people do?
- Say what you need and don’t accept less.
- Complain if not given the service required.