As the Language Access and Inclusion Director at Gateway Maryland (a Baltimore City Non Profit approaching 100 years of service in 2026; 30+ years of providing interpreting services), as a certified interpreter and interpreter educator for over 25 years, and with a doctorate in Urban Education Leadership focused on sign language interpreting practices, I commend the Maryland’s Governor’s Office of Deaf and Hard of Hearing and the State Board of Sign Language Interpreters’ efforts to ensure quality and accountability. However, several provisions drafted risk restricting access, undermining equity, and duplicating existing oversight.
I would like to start out by stating a powerful truth we hold close here at Gateway: communication is a human right. Language access is not a luxury, a perk, or a convenience; it is essential to learning, to healing, to justice, to participating fully in the world. Language access is a right that must include everyone, from those who use various sign language communication systems to those who rely on captions, and must be ensured across every zip code, system, and identity.
It’s a mistake to assume all interpreting service users are culturally Deaf or rely solely on ASL. In reality, many communities use diverse communication modes and language variations, many of which are neither standardized nor formally assessed. Everyone matters, and this bill must thoughtfully account for the full range of communication styles—both those that can be assessed through certifications and those that cannot—as well as the experiences of users and how service providers can best support them.
This is why Maryland’s proposed licensing law for sign language interpreters matters. It’s also why I believe, in its current form, it misses the mark.
A Law With Both Good Intentions and Serious Risks
Let’s give credit where it’s due. The people behind COMAR 14.41.01 are trying to ensure quality, accountability, and professionalism in the interpreting field. That goal is worth pursuing, but good intentions fall short if implementation builds barriers instead of bridges. As written, the new law imposes rigid requirements and complex structures that could limit interpreter availability, raise costs, and reduce consumer choice. While regulation is necessary, it must be grounded in reality. It must also reflect the lived experiences of those it aims to protect, and the practical constraints of the interpreting workforce.
When laws become inflexible, they don’t just regulate, they restrict. And in this case, they risk cutting people off from the very communication the law is supposed to protect.
Systems That Serve People, Not the Other Way Around
In every field (e.g., healthcare, education, legal services) communication access isn’t just helpful; it’s legally required. The proposed law adds layers of licensing, fees, specialty designations, and documentation that will stretch an already thin interpreter workforce.
Imagine needing emergency care in a hospital that can’t find an available interpreter because of licensing conflicts. Imagine being a DeafBlind student with no access to a ProTactile interpreter who is certified. Imagine being told that the interpreter who knows how to best match your communication needs can’t work with you anymore because of a paperwork technicality.
These are not hypotheticals; they are everyday realities for Maryland residents who rely on interpreting services. And they will become more common if this law isn’t rethought with people, not bureaucracy, at the center.
It’s Not Just About “Bad Interpreters”
Equity doesn’t mean creating the same pathway for everyone. It means designing systems that recognize different starting points, different needs, different ways of engaging.
Let’s be clear, this isn’t about calling out unskilled or unethical interpreters. Every field has a few, and they shouldn’t be providing communication access. But the deeper problem lies in the systems that allow it to happen. When an unqualified individual is placed in a role, we must examine who made that decision and why it was permitted.
Under the ADA and interpreting best practices, those unskilled or unethical interpreting services likely wouldn’t meet the standard of effective communication. If that’s the case, change is needed. I’ll dig into the difference between “qualified” and “certified” soon, but for now, it’s clear that accountability starts with those doing the hiring and determining who is qualified and not qualified to provide the service.
Skilled interpreters don’t all follow the same path. Many highly skilled interpreters, especially from earlier generations and rural areas, didn’t come through traditional certification routes. While today’s standard often includes a bachelor’s degree and RID certification, that hasn’t always been the case.
Plenty of qualified interpreters have developed advanced skills and deep community trust without those formal credentials. We can’t afford to overlook or lose these gems simply because their path looks different. Their value is proven where it matters most: in real-world communication.
In fact, Maryland doesn’t even have a university that offers a bachelor’s degree in interpreting—so their alternate pathways option will likely be heavily relied on. The other route, the Board for Evaluation of Interpreters (BEI), isn’t offered in the state either, with the closest testing site in Michigan. This highlights the need for practical, accessible pathways that reflect the realities on the ground. Add to that the ongoing growing concerns about RID’s reputation and their limited certification offerings, and it becomes clear that relying on RID as a cornerstone of this bill raises serious red flags.
For decades, interpreters learned on the ground through mentorship, community experience, workshops, and real-world practice. Many still do. These interpreters often use language modes that aren’t covered in formal tests but are trusted, effective, and deeply valued by the people they serve (various forms of signed English, Pro-Tactile, and even oral interpreting). Their work reminds us that skill and impact can’t always be measured by a certification alone.
A licensing system that only recognizes one source for credentials, one kind of training, or one kind of interpreting fails to capture the linguistic and cultural diversity that makes interpreting work very complex, meaningful and effective.
It’s time to redefine what qualified really means. It’s time we build a system that truly acknowledges there are many paths to being qualified. Interpreter education teaches this, and at Gateway Interpreting, thoughtful matching of interpreters to the people they serve is central to our approach.
The ADA has made this clear over the years: qualified doesn’t always mean certified, and certified doesn’t always mean qualified. It’s a powerful reminder that real effectiveness comes from the right fit, not just the right paperwork.
Language Belongs to the People Who Use It
One of the most troubling omissions in this law is the lack of consumer autonomy. Individuals who use interpreting services should continue to have the right to choose who facilitates language access best with them (including if it’s done in-person or virtually, which the bill includes), as well as interpreter(s) themselves, even if that interpreter doesn’t hold a specific state-issued license.
We have to be careful that “just get a licensed interpreter” doesn’t become the new version of “any warm body will do.” Holding a Maryland license doesn’t automatically mean an interpreter is qualified for work; and truly skilled professionals can be blocked from working if they’re not licensed. If the goal is real quality in interpreting services, we need to take a hard look at how interpreters are chosen and hired, not just whether they hold a license.
We need to rethink interpreter registration. We need a new approach to registering interpreters, one that doesn’t rely on flawed attempts at skill oversight. The focus should be on accountability and access, not rigid control over who is “qualified” based on incomplete or inconsistent measures. Let’s build a system that supports quality without shutting out those who serve our communities well.
This is especially important in light of the ongoing challenges surrounding RID, certifications, assessments, and interpreter education. The current system is far from settled, and relying on it as a foundation for oversight risks excluding skilled interpreters and limiting real access. The truth is, the field isn’t ready to rely solely on current assessments. And decisions about qualifications shouldn’t happen without input from the people who actually use interpreting services. Real language access means putting their needs and experiences at the center.
It’s a positive move for Maryland’s Office of Deaf and Hard of Hearing to take on oversight of sign language interpreter licensing and regulation. Still, they’re stepping into challenges that the Registry of Interpreters for the Deaf (RID) has struggled with for decades. Certifications have come and gone, specialties have been added and removed, and expectations around language use have shifted; sometimes leaving key communication modes, like signed English, and Pro-Tactile behind. Oversight is just the start; real change will require deeper, more adaptive approaches.
Effective communication is a right—not a moving target or merely a best practice—but a core principle of the Americans with Disabilities Act (ADA). While the interpreting field is still evolving, the ADA wisely puts the power in the hands of those using the service. It defines access through effective communication and calls for qualified interpreters, not just certified or state registered ones.
On that note, everyone should know that Certified ≠ Qualified. While certification is a useful tool, it doesn’t automatically mean someone is qualified. And being qualified doesn’t always require certification. At its core, current certification shows that a person passed a test on a specific day and kept up with the required maintenance. It’s one piece of the puzzle, not the whole picture. Real qualification comes from skill, experience, and the ability to meet the needs of those using the service. We need a pathway for qualified individuals, who may not be certified, to register with the state as professionals. In a field with limited assessments and shifting standards, who and what determines effectiveness matters. Language access should be defined by the people who use it and need it, not just the systems trying to regulate it.
When systems tell people who they must use, without asking who they deem qualified, they strip away dignity and agency. That’s not how access works. That’s not how equity works.
Let’s Get This Right, Together
Gateway Maryland has been part of this work for over 30 years. We’ve seen firsthand the difference that quality, culturally aligned interpreting makes in people’s lives. We support high standards. But we also support real-world flexibility, inclusion, and the empowerment of all, especially the ones often left out of the conversation.
We believe Maryland can create a licensing system that protects integrity and expands access. That honors credentials and lived experience. That enforces quality without shrinking the workforce or ignoring community needs.
It will take courage. It will take conversation. And it will take humility; the willingness to listen to interpreters, to consumers, and to those on the ground doing the work every day. This approach is preferable to imposing rigid governance and penalties on an industry still finding its footing.
Laws Should Reflect People, Not Just Policy
I hope the comments shared during the rules and regulations open comment period are truly valued and thoughtfully considered, and not treated as a procedural formality in favor of predetermined outcomes. Now is the time to pause, reflect, and make sure what’s being built isn’t just about policy but about people. Because in the end, the real test of any law isn’t how it reads on paper, but how it works in real life for those who rely on it most.
By Dave Coyne
If you want to connect to discuss this topic further, please reach out to me at dcoyne@gatewaymaryland.org to schedule a time to meet.
Meanwhile, if you have any questions or need additional information about the rules and regulations, contact ODHH:
📧 Tanea Brown — tanea.brown@maryland.gov
📧 Usherla DeBerry — usherla.deberry@maryland.gov
Additionally, we encourage you to share this announcement within your networks to ensure widespread participation. The public comment period will remain open until Monday, June 16, 2025, at 11:59 PM EST.
🗓️ Public Comment Deadline: Monday, June 16, 2025, at 11:59 PM EST
📄 Useful Links:
- Proposed Regulations: https://dsd.maryland.gov/MDRIssues/5210/Assembled.aspx
- (Use the “Control + F” function and search for “Subtitle 41” to locate the relevant section.)
- ODHH Public Comment Form: https://forms.gle/zvVnTqpZeyXCUXwM7
- AELR Committee Website: https://mgaleg.maryland.gov/mgawebsite/Committees/Details?cmte=aex
Even if you cannot make it to the Zoom session next Friday, we do ask for you to take a moment to participate in this important process. Your opinion truly matters.
Learn More About Gateway
Gateway connects people to their worlds and aids individuals in their ability to understand and to be understood. Gateway has grown into an organization that serves more than 4,000 children and adults every year, helping them communicate more effectively. With programming both on our Baltimore campus and through community-based programming, we provide education, access, and medical support to anyone who needs it.
We envision a society here everyone can understand and be understood and where everyone is treated with integrity, compassion, and equity.
