Deaf and Hard of Hearing Exchange Participants Going Abroad

Table of Contents:

BACKGROUND INFORMATION

FUNDING SERVICES

FINDING & CONTRACTING INTERPRETERS or LOCATING OTHER ALTERNATIVES

BACKGROUND INFORMATION

Providing effective access services for international exchange participants who are Deaf or Hard of Hearing may mean considering several different types of services. Some Deaf or Hard of Hearing individuals communicate very effectively by using speech, their residual hearing, and personal amplification devices (hearing aids). Others require additional visual cues, such as speech-to-text services or sign language interpreters.

Knowing what service to provide in a specific setting will involve working closely with the individual to determine what will be most effective. Two individuals with a similar degree of hearing loss, as indicated on their audiograms, might not benefit from the same services. One may know American Sign Language (ASL) and use it for expressive and receptive communication, while the other may be more comfortable using speech and speech-to-text services such as CART, TypeWell, or C-Print.

Sign language is a visual-gestural language that is used as a primary means of communication by many individuals who are Deaf. Some individuals who describe themselves as Hard of Hearing may also use sign language, particularly in an educational setting, to more fully understand the message presented. Sign languages, such as American Sign Language, are unique and naturally developed languages with their own grammatical rules and syntax (see Linguistics of American Sign Language by Clayton Valli and Ceil Lucas, 1993, Gallaudet University Press). As with other languages, sign language is complex and uses not only hand shapes, but facial expressions and body movement significant to the language.

Just as Arabic, English, Russian and Spanish are unique to a culture, so is the sign language of a country. Even English-speaking countries often have different national sign languages. For example, American Sign Language differs from British Sign Language which differs from New Zealand Sign Language.

In some cases, a non-native sign language is imported to a country and local signs are added, and/or several regionally homegrown sign languages occur in one country due to absence of a nationally unified community of people who are Deaf and Hard of Hearing. More about the sign languages of different countries can be found in Gallaudet University library’s Sign Languages of the World.

How does the accommodation process for Deaf and Hard of Hearing exchange participants begin? This tipsheet addresses considerations and best practices in accommodating Deaf and Hard of Hearing individuals in mainstream international exchange programs, and advocacy steps that can be taken to remove potential barriers and improve the overall accommodation process.

FUNDING SERVICES

Preparations for hiring interpreters or other service providers for overseas study, volunteer or professional exchanges should begin early in the process. If you represent an exchange organization or university office, be proactive by including a reasonable accommodation line item in your program budget to cover expenses related to sign language interpreting or other communication services abroad for participants who are Deaf or Hard of Hearing. Learn more about budgeting for reasonable accommodation in the Budgeting for Inclusion tip sheet.

Paying for interpreters or speech-to-text providers for a study abroad student or international volunteer may not cost any more than it does in the United States. For example, sometimes foreign university class schedules make it more cost effective to pay for interpreters or service providers abroad than in U.S. classes. Costs can also be reduced by hiring skilled interpreter(s) for formal situations (i.e. orientations, meetings, and classes), and/or sharing the costs with other universities sending Deaf students on the same program. For informal situations, notetaker(s) and student interpreter(s) needing practicum experiences can be used or a technology that allows texting between two people.

For individuals, paying interpreter or speech-to-text provider costs out of pocket may be accomplished by seeking out disability-specific fellowships, scholarships, financial aid, and other sources of funding for overseas exchanges, and by fundraising. Learn more from the tip sheet 15 Ways to Raise Funds for Your Exchange Program or from the fundraising chapter in Survival Strategies for Going Abroad.

In some cases, several different sources of funding can be pooled together from vocational rehabilitation offices or community foundations, and/or costs shared and negotiated between the sending and receiving exchange organizations or universities. When choosing between exchange programs, Deaf and Hard of Hearing individuals may want to consider programs that are coordinated by more than one university, or with a third-party provider, since there will be more funding options for accommodations when it can be shared between more than one program sponsor.

Remember to budget for the service provider's or interpreter’s airfare, lodging, wages, ground transport and meals unless other arrangements have been made. You can save costs by setting a flat daily rate or stipend, negotiating free time as an incentive, utilizing frequent flyer points, and contacting disability organizations in the country to which one is traveling for assistance finding housing or a homestay for the interpreter(s) or speech-to-text provider(s).

Best Practices:

• Council on International Educational Exchange has pooled funds in their budget for participants with disabilities who require broader services or accommodations, and works jointly with the student’s home institution to share expenses to make coverage possible.
• University of Missouri disability services office requested bids from different freelance sign language interpreter agencies in their community to send two interpreters abroad and found that one agency underbid the other partly because it factored in the valuable overseas experience the opportunity afforded its interpreters. Also they did get a small amount of funding from vocational rehabilitation (VR) to help fund interpreter costs, and VR provided additional funds for the student's actual study abroad program costs.
• Northwestern University found that the speech-to-text services in the Czech Republic for a study abroad student was not going to be the quality the student needed. Instead of having to send a speech-to-text provider with the student to Prague, they contacted Alternative Communication Services to arrange remote C-Print services. The price was reasonable in comparison to sending someone abroad. The student just needed a computer with Internet connections, and they purchased a RevoLabs microphone with directional capabilities so the C-Print provider in Hawaii (to make the time differences easier) could hear the teacher and class discussions in Prague.

• The University of Wisconsin-Madison International Academic Programs (IAP) office works closely with their campus disability office to ensure that individuals with disabilities have access to study abroad opportunities. In recent years IAP has worked with students participating on IAP study abroad programs that have required 2-3 ASL interpreters. Both offices work together to evaluate each situation that arises and consider such factors as program type, location, program duration, to determine appropriate resources and relevant expenses. Depending on contributing factors, expenses are sought to be shared amongst  participating offices and organizations, like program providers, program consortium members, the campus disability office, and IAP.

• A college in New York assisted a Deaf student in getting necessary documentation to use some of her vocational rehabilitation funds towards sending ASL interpreters from the United States to interpret during her semester abroad at the Siena School for Liberal Arts in Italy. Additionally, the Siena School negotiates costs of the ASL interpreters for their Semester for ASL Users track (Spring) as a shared responsibility and offers, if interested, Continuing Education Units towards maintaining their interpreting certification.
  
• Cross-Cultural Solutions identified a person in Costa Rica who knew both ASL and Costa Rican sign language (LESCO) to assist a deaf volunteer with receiving orientation information and learning LESCO for her volunteer placement at a deaf school in Costa Rica.
• United States International Council on Disabilities researched local sign language interpreters for a Deaf staff person who traveled to do trainings in a few African countries. Since ASL influenced some of the local sign languages and she learned some of the additional local signs, it worked out for the budget they had. Read more on the blog Achieving Communication Access in Africa on a Shoestring Budget.
  
• Visit Arranging for Sign Language Interpretation Abroad: A Disability Service Provider Perspective to read about how the University of California, Santa Cruz, provided access for a Deaf student to study abroad in Scotland and the steps and decisions that made it happen.

Advocacy Action Steps:

1. Commit 1% from one of the following funding sources for disability-related accommodation expenses: Your overall international exchange programs or disability services budget; Your scholarship funds or student fees
   
2. Agree to provide at least the same amount of money towards sign language interpreter(s) or related services for a study abroad experience as would be provided if the student were to take the same number of credits on campus (cost-savings could come if more credits are offered in less time overseas).
3. Find a foundation to provide airfare as an incentive for the exchange program, school or university to cover other expenses related to providing sign language interpreter(s) or related service provider(s) abroad.
4. See arguments in Question 8 below and offered in a Post Secondary Education Network (PepNet) conference presentation and PepNet FAQ video for getting systemic commitment from a university or organization to make it an allowable cost.

FINDING & CONTRACTING INTERPRETERS or LOCATING OTHER ALTERNATIVES

Answers to frequently asked questions about finding sign language interpreters, the hiring and visa process, foreign language considerations, legal issues, and other service providers and communication technologies.

Questions Asked

1. Where do I find sign language interpreters in the United States? What about cued speech transliterators? 
2. What should I consider when hiring a sign language interpreter? Should I write a contract? What does a contract look like?
   
3. Does the sign language interpreter need to know a foreign language?
   
4. Can I find a sign language interpreter in the destination country?
   
5. Could I use assistive technology and remote interpreter(s) from the United States while abroad?
   
6. Are assistive technologies such as speech-to-text provision, assistive listening devices, and instant and text messaging alternatives to hiring an interpreter or for non-sign language users?
   
7. What works best for an international experience?
   
8. What are the rules and regulations regarding providing accommodations on an international exchange program?
   

Answer 1: Where do I find sign language interpreters in the United States? What about cued speech transliterators?

To find American Sign Language (ASL) interpreters in the United States, contact the Registry of Interpreters for the Deaf or put a message on a listserv such as an Interpreter Group site. You can also check with interpreter referral services, interpreter training programs, speech and hearing centers, exchange organizations that have sent sign language interpreters before, and Deaf schools and organizations.  

Some individuals use cued speech to communicate in daily life. A cued speech transliterator uses handshapes near the mouth to show a visual picture of a sound pattern. You can find cued speech transliterators through the National Cued Speech Association or through related organizations in the destination country. In the United States, cued speech transliterators are more available on the east coast.

It is important to check the interpreter’s certification, travel experience, amount of experience, and compatibility with the individual utilizing the interpreter’s services. You want to make sure that the interpreter and the Deaf or Hard of Hearing traveler are compatible (e.g. same type of preferences, early riser, not too timid). The exchange participant and interpreter could meet in person or communicate via videophone several times before going abroad to ensure that they are comfortable with each other’s communication style.

In most cases, you will need more than one interpreter unless other communication methods will be combined with interpreting. With only one interpreter, there are no backups for the interpreter if he/she becomes ill. Also, the long hours required on an exchange program could affect the interpreter’s performance and well-being, and negatively impact the exchange participants’s access to communication and information.

Advocacy:

Work with the Registry of Interpreters for the Deaf, National Cued Speech Association, and other referral agencies to include additional information in their databases about interpreters/transliterators who are traveling overseas, have lived overseas, want to go abroad, and/or have interpreted on programs abroad.

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Answer 2: What should I consider when hiring a sign language interpreter? Should I write a contract? What does a contract look like?

Interpreter(s) you hire will need to have all necessary paperwork in order (passport, visa, immunizations, insurance, etc.) prior to travel. The interpreter(s) may need only a tourist visa.  Check with the embassy of the destination country. If the interpreter(s) will go for more than six months, it is possible that the country will simply renew a 6-month tourist visa.

It is a good idea to sign a contract (e.g. Sample Contract) to be used with staff interpreter(s) providing more than interpreting services and another type of contract (e.g. Sample Contract) for study abroad programs. The contract should clearly list the duties of the interpreter(s), the hours and dates of service, the lump fee or salary, liability, what will be paid for and what will not, and any further rules or contingencies for termination or emergencies. When considering the hours of service for an overseas program, be sure to consider any activities outside of the classroom that are determined essential to the program. While Deaf and Hard of Hearing individuals can find independent ways of interacting with others during free time, an interpreter may be needed if there is a tour guide providing information during a bus trip or if a group leader needs to announce schedule changes or mediate misunderstandings between the student and his/her host family. If part of the cultural experience is interacting with a host family, that type of discourse needs to be considered when determining hours as well.

Before departure, it is helpful to provide the interpreter(s) with a basic itinerary of classes and events, share cultural information about the country and type of amenities that will be provided (e.g. housing, transportation, etc.), and discuss how stress situations and possible stereotyping will be handled. Depending on the nature of the program, you might also want to provide the interpreter(s) with expectations of their role and how involved they will or will not be in informal activities.

Advocacy:

Often the chance to go abroad creates a need to do things differently than in the United States. Associations representing sign language interpreters could advocate for stronger guidelines on compensation and working conditions for sign language interpreters on overseas programs, so there are not only increased opportunities, but adequate pay and enough breaks during programs as well.

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Answer 3: Does the sign language interpreter need to know a foreign language?

Remember, if you are going to a non-English speaking country, the sign language interpreter will also need to know the language of the destination country, unless programming is conducted in English. Even when programming is conducted in English, program or field trip leaders may have heavily accented English that requires the interpreter(s) to more frequently ask for clarification.
For education abroad programs that require a prior knowledge of a foreign language, such as direct enroll university programs where classes are taught in the foreign language, any service provider will also need to be evaluated to ensure that his/her foreign language skills are at an equivalent or higher level than those of the student.

Unfortunately, it is difficult to find out how many interpreters have foreign language skills. Databases of providers, such as the Registry of Interpreters for the Deaf, do not typically provide this information. Deaf Vision and National Network of Trilingual Interpreters list multilingual sign language interpreters in Spanish-English-ASL located in the United States. 

Even if someone with foreign language skills is found, there are other considerations such as:

• What is the ASL interpreter’s skill level in the foreign language? The following foreign language tests can be administered to ensure the interpreter has the level needed for the course: http://www.languagetesting.com/scale.htm.
• Does the interpreter have experience ASL interpreting from the foreign language? The interpreter may only be practiced at translating from English to ASL and not from the foreign language.
• How will program staff assess if the ASL interpreter is conveying the information accurately? Develop a regular system of check-ins with the participant to make sure he/she comprehends the information and that services are working successfully.

Technically, how the service will be provided also needs to be given some thought. For example, if the program involves a foreign language course where the student needs to learn grammar, the ASL interpreter will need strategies for conveying the foreign language through fingerspelling, oral interpretation and speech-to-text laptop software (see more in Answer 6) in order to accurately convey verb endings and sentence structure. The interpreter(s) should also have access to the textbook in order to prepare in advance of lectures.

Advocacy:

Organizations such as National Association of the Deaf could collaborate with other lobbying organizations such as American Council on the Teaching of Foreign Languages to find funding or initiate campaigns to further efforts to increase the number of ASL interpreters with foreign language training. Initiatives could include:

• Campaigns to encourage sign language interpreters to gain foreign language skills to improve access to foreign language courses for Deaf and Hard of Hearing students. This could include a commitment from post-secondary institutions to provide tuition-waivers or continuing education credits to interpreters who pursue foreign language study.
• Awareness-raising for Registry of Interpreters for the Deaf and similar provider databases regarding the importance of identifying interpreters with foreign language skills and prior experience with ASL interpreting in that language.
  

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Answer 4: Can I find a sign language interpreter in the destination country?

You may want to try looking for sign language interpreter(s) in the destination country to reduce costs or resolve foreign language issues. However, most sign language interpreters are trained only in the sign language of that country and do not know ASL. The European Forum for Sign Language Interpreters created a webpage for ASL interpreters living in Europe to post their information. Contacts are limited currently. Overseas Interpreting provides another forum through which study abroad students, business people and other English-speaking travelers can connect with ASL interpreters living in France, Italy, the Netherlands and the United Kingdom (although other countries can be arranged). An advantage of having a locally-based ASL interpreter is his/her connection to the local culture, including introducing the exchange participant to Deaf events and friends, which can help with immersion and transform the individual’s overseas experience. 

Another option is to check with Deaf and disability-related organizations in the destination country to learn of any ASL interpreters they may know in their countries. Find these by clicking on Mobility International USA’s Search for Disability Organizations, Gallaudet University’s World Deaf Information Resource Project, the World Association of Sign Language Interpreters, or by doing an Internet search.

If you are hiring an American who is living abroad, work requirements vary between countries, and there may be tax implications. To determine what arrangements are needed, talk with people in the international exchange field who have paid U.S. citizens abroad.

A better plan of action may involve sending an ASL interpreter in the early stages of the exchange while the individual learns the sign language of the country. You can then hire interpreter(s) from the country (if available) once the individual is familiar with the country’s sign language. 

The World Federation of the Deaf (WFD) has gathered many sign language dictionaries and you can e-mail WFD at wfd@kl-deaf.fi to learn how to obtain one. Deaf organizations in the host country, many of which are WFD members, may also be able to send dictionaries or DVDs. Through its Center for International Programs and Services, Gallaudet University has many international Deaf students that also can assist an exchange participant with learning a new sign language before he/she travels overseas. Some Deaf individuals may decide to go to the host country prior to the start of a study abroad program to take courses in the local sign language, interact with Deaf clubs or live with a Deaf host family. Living with a host family provides an excellent opportunity to develop foreign language skills while abroad, including skills in a foreign sign language not often offered as a course of study in the United States.

In general, access to sign language interpreters, especially those with interpreter certification training, varies significantly by country. WFD and the Swedish National Association of the Deaf "Deaf People and Human Rights" report shows the availability, or lack thereof, of qualified sign language interpreters by country. 

If hiring people in the host country is more cost-effective, another option for short-term programs is hiring a local sign language interpreter and someone locally who is Deaf and knows both ASL and their own sign language to relay interpret. With more Peace Corps volunteers working in Deaf communities overseas, and international Deaf individuals enrolling in Gallaudet University in the United States, the number of Deaf people who know ASL is growing. Note that relay interpreting may slow down group presentations as the speaker must pause to allow for the local Deaf person to receive the information from the local sign language interpreter, and then turn and interpret in ASL for the Deaf American. This strategy is often used for Deaf-Blind individuals who need close one-on-one or tactile interpreting too.

Advocacy:

1. Establish an ASL interpreter business/non-profit in regions of increased study abroad programs, similar to what Overseas Interpreting has done in Europe, so ASL interpreters who have an interest in living overseas could do so while also providing a needed service. 
2. Train overseas providers in ASL by having U.S. Deaf organizations or universities seek out international training grants.
3. Collaborate with international development organizations, institutional faculty exchanges, U.S. embassies abroad, and international Deaf organizations to increase the availability of sign language interpreters in more countries overall. 
4. Create an international friendship network between international and U.S. Deaf individuals to assist remotely with learning local sign languages in destination countries.

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Answer 5: Could I use assistive technology and remote interpreter(s) from the United States while abroad?

If an ASL interpreter cannot be located in the host country, or the Deaf individual isn’t able to become proficient in the local sign language, then video relay interpreting may provide a way to use U.S.-based ASL interpreter(s) while abroad. To learn more about video relays, which are often available 24 hours a day, visit this Wikipedia webpage. Some of the issues in using remote ASL interpreter(s) from the United States may involve having access abroad to a computer that has video phone capabilities that are compatible with a video relay agency. Another issue is access to high speed Internet and possibly telephone lines as some video relay agencies use both simultaneously.  Appropriate bandwidth (at least 425 kbps) should be reserved for the time of the relay, and the IP address should be ‘static’ for a better connection. Video relay interpreting for a class may be more costly than sending an ASL interpreter abroad as rates can reach as high as $150 to $350 an hour.

Outside the classroom, U.S. videophone services, including free video relay services, currently do not provide international service. However, contact your videophone provider to learn if this has changed. Deaf exchange participants can use computer calling services, such as Skype with webcams and other Internet videophones listed at the Escape Artist website for overseas living, or use instant text messaging when abroad to contact home. In more remote places, fax service may be the main option for communication. For communicating with other sign language users in the host country, exchange participants may be able to find mobile phones with video screens that can be purchased and used overseas (although these will not work upon return home). Also, in Sweden and the UK, public access videophones are already available in some places for those who communicate using sign language.

Advocacy:

Collaborate with remote service providers to research necessary connectivity requirements for different regions, and to establish communication agreements with foreign countries so videophone services can be available internationally.
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Answer 6: Are assistive technologies such as speech-to-text provision, assistive listening devices, and instant and text messaging alternatives to hiring an interpreter or for non-sign language users?

The use of the CART, Typewell, C-Print or similar speech-to-text provider(s) (real-time captioning/transcription) is a possible alternative to ASL interpreter(s) for some Deaf and Hard of Hearing individuals. Contact the Speech to Text Services Network or Post-Secondary Education Network for more information about different options. These assistive technologies are typically used in conjunction with a sign language interpreter if the individual knows ASL. 

Sign language users are the smallest group in the overall community of people with hearing loss. People who use a combination of hearing aids, assistive listening devices, lip reading and written communication will have their own adjustments to make in a foreign setting with new spoken accents, increased noise in buildings with less insulation or during field trips, or different writing systems. In some cases the overseas setting may be more conducive to communication, such as in quiet rural areas or when conversations are directed to, said more slowly, or willingly repeated to a foreigner who doesn’t speak the language regardless of hearing loss.

If the study abroad program is in another language, the speech-to-text provider(s) would need to develop a dictionary and shorthand codes in that foreign language and know the language well enough to type it word-for-word (for CART providers) or meaning-for-meaning (for C-Print and TypeWell). The providers should be assessed and evaluated accordingly (see Answer 3), perhaps in comparison with a recorded copy. More information is on our Foreign Language tipsheet.

Remote captioners/transcribers in the United States can be located through web searches, which can locate directories of individual real-time captioners. Intersteno is an association of real-time captioners in various countries worldwide, although many may be more experienced in court reporting than in providing services for Deaf or Hard of Hearing clients. Partners listed on the European Forum of Sign Language Interpreters may also have referrals for local speech-to-text providers. The Postsecondary Education Network-International is another potential resource as it works to improve and expand postsecondary education for Deaf and Hard of Hearing students around the world by sharing educational technology and conducting faculty development and training, particularly in developing countries. 

Use of remote captioning is possible if technology, but not personnel, is available overseas -- a different bridge, such as Jumbotran or Skype, may be needed to encode/decode audio and text that is being sent between the United States and overseas. Remote speech-to-text providers from the United States only need to hear what is happening in the class or on a field trip, and the Deaf or Hard of Hearing exchange participant needs to be able to receive the text back. Like remote video interpreting, this can be quite expensive per hour and requires the U.S. captioner to know the language being spoken abroad and be available at nontraditional hours due to time differences between countries. Companies, such as Alternative Communication Services, have made arrangements with providers they have in Hawaii to account for time differences with a client who needed remote services in Europe.

To get started, a laptop with access to the Internet, Internet connectivity, and a wireless microphone are needed. If the participant has a laptop with Internet access, he/she will need to load free software such as Skype, or a similar service, which provides phone service via the Internet. The speaker uses a microphone or if more than one person is speaking, then conference call equipment such as from Revo-MicLab, helps to be heard by the remote speech-to-text provider. The Deaf or Hard of Hearing individual goes to a website address to read the text, and connects to the speech-to-text provider via the Internet phone service, by clicking on the speech-to-text writer’s name to receive the remote text services.

Standard web-based instant messaging or web chat features also enable two-way or multi-way text messaging from the Internet. Equipment and consistent electrical and/or Internet connections must be available. Teachers can use technology like Interpretype or UbiDuo, a system which links two portable keyboards with built-in screens enabling face to face meetings or discussions with people who are Deaf or Hard of Hearing by typing messages. Interpretype has some additional features that can be purchased separately to translate words written in English into Spanish or French for the reader. They also have agreements with a foreign translation agency that can be called at any time to reach a foreign language interpreter.

Assistive listening devices, such as FM listening systems or infra-red broadcast systems, are often portable and allow program leaders or teachers to talk into a microphone or near a transmitter which is connected directly to the hearing aids or headphones of the Hard of Hearing or Deaf individual, or to a trained voice recognition software system on the individual’s laptop. However, this technology is not always reliable in other countries and voice recognition software needs many hours of voice training and correction of errors to become proficient by one user. Caption Mic™ is an example of this software, and has a Spanish version. Conditions at locations abroad will determine the reliability of using this equipment, including access to repairs, interference, and dust/heat.

Advocacy:

For those considering sending speech-to-text providers or using remote services from the United States, the ability to provide services in a foreign language can be a barrier. TypeWell providers use dictionaries that have been developed by linguists, so would need to find funding for linguists to create foreign language dictionaries with the appropriate shorthand codes developed, based on the frequent use of words in the foreign language. 

For C-Print and CART providers who develop and test their own dictionaries based on phonetics, working with referral agencies to develop a central repository for already created foreign language dictionaries to be shared between providers (albeit they could modify for their own shorthand) would be helpful.
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Answer 7: What works best for an international experience?

The most effective method of ensuring a good overseas experience for the Deaf or Hard of Hearing traveler is flexibility. Often, that entails using a combination of resources. Those resources may or may not include: ASL certified interpreters, local sign language interpreters, student ASL interpreters, lipreading the local language, notetaking, text and instant messaging, and utilizing speech-to-text providers, cued speech transliterators, assistive listening systems and remote video interpreting when available.

Students who are planning to study a foreign language abroad may also want to consider arranging supplementary instruction with oral components of a course, pronunciation, and/or homework that is presented in inaccessible formats (such as on CDs). Sometimes teachers may need to meet with Deaf or Hard of Hearing students during office hours to provide supplementary instruction and/or incorporate cooperative learning projects and writing activities into the course. Deaf and Hard of Hearing students may also benefit from tutoring services. More information can be found on our Foreign Languages tipsheet.

Training the overseas staff and faculty on appropriate etiquette and universal design techniques that enable effective communication with Deaf and Hard of Hearing individuals is also helpful. Some online tools to assist in this can be found at the Rochester Institute of Technology or Post-secondary Education Programs Network (PEPNet).

Advocacy:

Attend many related conference workshops to ask the panelists for their views and opinions, to generate support for addressing this issue, and to brainstorm with others about how we can achieve this goal -- accessible study abroad programs for Deaf and Hard of Hearing exchange participants.
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Answer 8: What are the rules and regulations regarding providing accommodations on an international exchange program?

The free publication, "Rights and Responsibilities: A Guide to National and International Disability-Related Laws for International Exchange Organizations and Participants," published by Mobility International USA, provides information on civil rights laws and case studies that have addressed the question of if the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act extend overseas. This publication can be downloaded for free on the NCDE website.

Many organizations and institutions choose considerations beyond set rules and regulations when deciding to provide accommodations on international exchange programs. This proactive process often is based on values of equal opportunity – just as they do not leave behind sexual harassment protections, behavior/conduct codes and non-discrimination practices when sending participants abroad, equal opportunities for Deaf and Hard of Hearing exchange participants should follow suit.

Administrators concerned with retention rates or time to graduation of diverse and excelling students often see the value of supporting study abroad as incentive for students with and without disabilities to continue on their path towards graduation. Studies at several universities have found that students who study abroad tend to graduate earlier than other students.

Also, some institutions or organizations may not see previous study abroad legal decisions as particular to their situations or choose not to risk negative exposure or the cost of potential complaints from students by denying accommodations to Deaf and Hard of Hearing study abroad students.

Institutions with internationalization efforts or global-focused mission statements, or private college, universities or third party providers with more resources, may also choose to for those reasons to support accommodations abroad for study abroad students. 

Advocacy:

One way for Deaf and Hard of Hearing participants to receive costly accommodations is to refer to the right to equal access and opportunity as stipulated by the ADA or Section 504 of the Rehabilitation Act. This has been done in the case of study abroad as noted in the publication mentioned above; however, in an opinion letter, the U.S. Department of Education concluded that these laws do not reach across borders, with the exception of Title I of the ADA which Congress amended to expressly provide for extraterritorial application of the ADA in employment cases. No similar amendments were made to Titles II and III, which led some to conclude Congress intended those Titles to be only applicable on U.S. soil.

This extraterritoriality determination could be challenged directly in another court case related to study abroad. The goal would be to clarify if extraterritoriality should be a consideration or not in study abroad, or to get a ruling about legal requirements to provide accommodations on study abroad programs sponsored by U.S. institutions (as opposed to programs conducted by third party providers).

Another approach would be to lobby for Congress to state that Section 504 and/or other Titles of the ADA also were intended to apply overseas – as long as they are not in conflict with existing laws in another country. This would likely take a cross-disability and extended effort.

A just as challenging, although valuable, approach would be to work with Deaf advocacy groups abroad to improve laws in their countries regarding the provision of accommodations for Deaf and Hard of Hearing people and to make those accommodations available and applicable to international visitors as well.

For example, the Equality Act 2010 in the United Kingdom (UK), which covers several protected groups and consolidates the previous UK Disabilities Discrimination Act, specifically states that all students in higher education, including those from overseas, are covered by legal entitlement to fair access and academic support while studying in the UK. However, the source of funding is not clear, as local Deaf and Hard of Hearing students get grant funds through their Student Loan Companies in their hometown in the UK and not from the university they attend, as is the case in the United States. International students to the UK are usually ineligible for the Disabled Student Allowances as there are residency and immigration status requirements. Clarifying where the funding for accommodations comes from will help to guide the implementation and enforcement of laws in other countries. 

American schools or universities must take some proactive steps to encourage their overseas program partners and organizations to provide physical and program modifications, auxiliary aids, and other accommodations. This would apply most if a sign language interpreter in the destination country can be used because the Deaf individual knows the sign language of that country (i.e. a British university would not be expected to bring an ASL interpreter to England for a U.S. study abroad student).

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Thank you for all the people from various universities, PepNet, and others who reviewed this tipsheet and provided feedback and information. Although efforts have been made to ensure accuracy, MIUSA/NCDE cannot be held liable for inaccuracy, misinterpretation or complaints arising from these listings. Mention of an organization, company, service or resource should not be construed as an endorsement by MIUSA/NCDE. Please advise NCDE of any inaccuracies you may find.