Deborah Bailey

RE: HB525 Dear Committee Members, As a former educator of Deaf and Hard of Hearing children and a strong advocate of New Hampshire's Deaf/Hard of Hearing/Deafblind community, I strongly oppose House Bill 525, which proposes transferring the specialized VR Program for the Deaf and Hard of Hearing and the oversight of the New Hampshire Interpreter Licensure Board (NHILB) to the Office of Professional Licensure and Certification (OPLC). As someone familiar with these critical services, I am deeply concerned about the implications this move could have on our community. Essential Services at Risk Since 1981, the Program for the Deaf and Hard of Hearing has been instrumental in providing services that are vital for our ability to communicate effectively and participate fully in society. Beth Keller, a Deaf ASL user and the State Coordinator for this program provides vital leadership in delivering Vocational Rehabilitation (VR) services specifically tailored to our community's needs. These services include: • Career Counseling and Guidance • Job Training • Resume Preparation and Interview Practice • Job Placement • Onsite Job Coaching • Help Obtaining Job Accommodations, including assistive communication devices • Workplace-Based Support for Co-Workers on how to communicate with people who are Deaf/Hard of Hearing/Deafblind as well as general disability education and awareness training • Transition services for students who are Deaf/Hard of Hearing/Deafblind • Advocacy for accessibility and legislative improvements • Collaboration with DHH organizations for comprehensive community support Also of critical concern is protecting the NHILB’s role in regulating and ensuring the quality of interpreter services through rigorous standards and investigations into professional misconduct. Moving these services to an office that lacks the specialized focus and understanding of the unique needs of our community risks diluting the quality and effectiveness of the support we receive. Key Concerns with HB525 1. Loss of Vocational Rehabilitation (VR) Services: The bill does not specify how crucial VR services listed above will be preserved. If these services are not explicitly protected, individuals who rely on them may face diluted services, disruptions or even a loss of access. 2. Undermining the NHILB’s Expertise: The NHILB is composed entirely of Deaf ASL users, interpreters, CODAs (Children of Deaf Adults), and CART (Communication Access Realtime Translation) users. This board plays a critical role in ensuring interpreter service quality through rigorous standards and oversight. Those with direct experience are uniquely qualified to uphold professional standards. Transferring oversight to OPLC risks replacing this specialized expertise with a generalized licensing approach that lacks the necessary cultural and linguistic competency. 3. Unfunded Mandate: HB525 provides no funding to support the transition of these services, despite OPLC indicating that at least two new staff positions would be needed (a board administrator and a grant writer). Without allocated funding, OPLC will either have to absorb these costs—straining existing resources—or the program will suffer from understaffing, delays, reduced service quality or no services. 4. Equity Concerns & Potential ADA and WIOA Violations: This bill singles out the Deaf/Hard of Hearing/Deafblind community for restructuring while leaving other disability services, such as those for individuals who are blind or developmentally disabled, intact. This could raise legal equity concerns under the Americans with Disabilities Act (ADA) and WIOA if services are disrupted or inadequately provided. 5. Unclear Use of Licensing Fees: The bill shifts control of licensing fees and administrative fines from NHILB to OPLC but provides no guarantee that these funds will be reinvested into DHHDB services. Without such assurances, there is a risk that these funds could be absorbed into OPLC’s broader administrative budget rather than benefiting the community they are intended to support. HB525 is an unfunded and poorly conceived proposal that jeopardizes services that many in the Deaf and Hard of Hearing community rely on. I urge you to vote against HB525. Thank you for your consideration. Sincerely, Deborah Bailey