Educational Interpreter for Deaf Students: EIPA Standards, How to Request One, and What to Do When Schools Say No

A student who relies on sign language may need a qualified interpreter to access instruction. Yet schools sometimes assign interpreters whose qualifications fall below state requirements, give them non-interpreting duties, or claim they simply can't find one. These practices can leave a student without effective communication access and may violate state requirements or professional standards.

EIPA Standards: What "Qualified" Actually Means

The Educational Interpreter Performance Assessment (EIPA) is a diagnostic scale from 1.0 to 5.0 developed by Boys Town National Research Hospital. A score of 1.0 means barely functional; 5.0 means advanced professional fluency.

State minimum requirements vary, but the trend is clear — the bar is rising:

• California: RID certification or equivalent, or a score of at least 4.0 on an approved assessment such as the EIPA
• Washington: EIPA 4.0 plus a passing EIPA written test, or national RID certification plus a passing EIPA written test
• Pennsylvania: EIPA 3.5 or qualification under the state's sign-language interpreter registration law, plus 20 hours of annual staff development related to interpreting
• South Carolina: national certification or EIPA 3.5 beginning in the 2026–2027 school year; the EIPA minimum rises to 3.7 in 2030–2031 and 4.0 in 2034–2035
• Oregon: EIPA 3.5 or RID NIC, CI, or CT certification, plus the required degree or EIPA written test
• North Carolina: EIPA 3.3 qualifies an interpreter as Educational Interpreter I; the interpreter must reach 3.5 within three years to advance to Educational Interpreter II

If your state hasn't set a minimum, you can request an EIPA score of at least 3.5 as a benchmark. A score below 3.5 may still meet some states' requirements, so check your state's standard. Ask the school for the interpreter's current EIPA score or RID certification in writing.

What an Educational Interpreter Should and Shouldn't Do

An interpreter's role is communication facilitation — period. They convey communication between spoken English and the student's language or communication mode in real time. A student who uses Cued Speech may need a qualified Cued Speech transliterator. Interpreters are not:

• Teachers or tutors
• Classroom aides
• Disciplinarians
• Note-takers
• Paper graders

Schools that assign interpreters to perform these duties during instructional time are pulling them away from their primary function and denying the student equal communication access. If this is happening, raise it at the next IEP meeting and document it in writing.

CART as an Alternative or Supplement

Communication Access Realtime Translation (CART) provides verbatim text of everything spoken in the classroom, displayed on a laptop or tablet screen. It's the right fit for deaf or hard of hearing students who rely on print literacy rather than sign language — and it's an option worth knowing about even for signing students who may benefit from text reinforcement.

CART providers are typically Certified Realtime Captioners through the NCRA. Remote CART has expanded access significantly — a captioner doesn't need to be physically present in the classroom to provide the service.

Under ADA Title II, schools must give "primary consideration" to the specific auxiliary aid the individual with a disability requests. If your child needs CART rather than an interpreter — or CART in addition to an interpreter — the school may use another equally effective aid; if the requested aid would fundamentally alter the program or impose an undue burden, the school must take another action that provides effective communication to the maximum extent possible.

How to Request an Interpreter or CART Services

Put the request in writing to the IEP team, specifying:

• The type of communication access needed (ASL interpreter, Cued Speech transliterator, CART)
• The required qualification level (minimum EIPA score or RID certification)
• Coverage for all environments: classroom, lunch, recess, assemblies, field trips, after-school activities
• A plan for substitute coverage when the primary interpreter is absent

Cite both IDEA (the special factors provision at 34 CFR §300.324(a)(2)(iv)) and ADA Title II (28 CFR §35.160) in your request. The combination creates a strong legal foundation.

When Schools Claim They Can't Find an Interpreter

"There's an interpreter shortage" is a real problem — and it doesn't exempt the district from providing effective communication. Ask the school to consider coverage options such as:

• Contract with an interpreting agency
• Seek remote interpreting services (Video Remote Interpreting as a temporary measure, though it has limitations in classroom settings)
• Provide CART as an interim accommodation while searching for an interpreter
• Contact the state school for the deaf for referrals

The district remains responsible for providing the communication access required by the student's plan and applicable law. A staffing shortage alone does not establish liability. The Supreme Court's A.J.T. v. Osseo Area Schools decision (2025) rejected a heightened bad-faith-or-gross-misjudgment standard for education-related ADA and Section 504 claims; compensatory damages generally require intentional discrimination, often shown by deliberate indifference.

Document every day your child goes without services. File a state administrative complaint with a specific timeline of the access denial.

The Deaf & Hard of Hearing IEP & Communication Access Toolkit includes interpreter qualification checklists, CART request templates, and the pushback scripts you need when a school board claims communication access is optional.