National Associates Committee

Dear members of the NCARB,
I am the happiest person by the new resolution because now it is going to be very difficult that many interns will not manipulate the list of activities and time of campletion, "GREAT". It will improve a better relationship between mentor-supervisor vs candidate.
I would like if NCARB consider more options for Architects who came from another country and definetely it would be an improvement if there are different stages to prepare them before start to apply for a job in USA.

Sincerely yours,

Jose Leonidas Mejia
architect SCA 1989
Associate Member AIACT
Volunteer at the New Canaan Historical Society
International Delegate of the Society of Columbian Architects.
203-9668254 Office
203-9375679 Home

Generally speaking, a 6 month requirement to turn in IDP units isn't a bad idea. It will motivate many procrastinators to finish IDP in a more reasonable amount of time. Alas, there are many other issues at work here that the 6 month rule does not take into account. The main issue is the responsibility of the intern to acquire IDP units and for him/her to press their employer for this experience. NCARB needs to understand that the one thing that makes IDP currently unsuccessful is the burdened of the intern being solely responsible for his/her education. The 6 month rule, again, makes the intern responsible for their education. It is not unlike a college student creating their own pedagogy and curriculum to teach themselves architecture. NCARB needs to communicate with the profession and academia to find a more successful method of acquiring professional training (i.e. internship). Only when NCARB begins out reaching and listening instead of dictating model law will the internship become a more successful means of professional development.

Increasing restrictions on IDP + ARE conspire to keep people out of the practice of architecture.

The future is bleak when this profession restricts entry. Smart kids will go elsewhere.

The IDP process is already painful enough. Is NCARB planning on beefing up their staff to handle this? Based on my experience, and that of some colleagues, they already have their hands full. What good does it do if the turn around time increases to four months instead of two. I would prefer them concentrating on streamlining the process as opposed to adding headache.

The first half of the six month rule, that of requiring submissions every six months, is great, and probably will help the procrastinators among us. The second half, however, of having credits disappear, seems counter-productive. Additional experience would only seem to be helpful, both to the individual's knowledge base in taking the tests, and in the development of the individual as an architect. I wouldn't propose rewards for taking a long time to get through the IDP, but there shouldn't be any penalties either. Any way you slice it, getting through the IDP and getting licensed is an arduous process. Let's concentrate on encouraging, rather than discouraging, individuals through this process.

This strikes me as a terrible idea, and not just because I'm a recalcitrant procrastinator (though, I admit that), but also because I am an unfailing supporter of allowing emerging professionals in non-traditional-firm jobs as many ways as possible to work towards earning IDP credit as they gain experience.

IDP already disallows credit for work experience under half-time, which has the unfortunate anti-family or possibly outright sexist effect of discounting the part-time efforts of new parents or others who choose to work flexibly. IDP also already disallows credit for less-than-6-month positions, meaning that emerging professionals are discouraged from seeking a diverse set of short-term work experiences in their early career to identify the best work environment for them. This new proposed requirement would stifle the career progress of individuals who move into architecture from another related field where they have already gained some experience in project or office management. It would also place an unfair burden on interns in situations where they do not have complete control over when supervisors find time to mentor or sign off on paperwork.

More restrictive processes only build resentment of the program and prevent a real, meaningful discourse about the actual diversity of ways that professionals gain an understanding of a field.

While this may be well intentioned, I think it goes much too far in proposing a big stick to solve a vague problem. Even given some legitimate concerns, this seems punitive and does not leave much wiggle room for life circumstances. If the goal is bi-annual reporting, why not start with a one year or eighteen month expiration clock? How will you handle the many interns who do their documentation promptly, but then spend months long distance trying to get their previous employer to complete their small task? What obligation does the firm and mentor have to make sure this works for the intern? What professional penalty does the firm or mentor suffer if it doesn't work, as delaying licensure of the intern is a significant penalty to them? I approve of the general goal of getting regular reporting, but it seems there should be carrots as well as sticks. Perhaps fees could be lower for interns who submit at least two reports every calendar year?

I can already foresee potential problems with this rule change. Currently in order to be eligible to recieve credit for work experience a candidate must be employed by a firm for at least six months. But the new rule will require a candidate to report their work experience at a MAXIMUM of six months. Do they expect a candidate to have their forms dated within this 24 hour period or else the candidate will not recieve credit? IDP is already a laughable system that in itself makes no real contribution to architectural traning; let's hope that NCARB isn't going to make it worse.

This would be a distaster for overseas architects like me who had previous experience in the US but who didn't realise they wanted to be registered here until years later. All experience, validly gained, should be allowed to be included. If the US toughens their restrictions, all that will happen is that other countries will follow suit and restrict the experience US architects can count when submitting for registration in other countries. A (probably unexpectedly) lose-lose situation.

I am a Broadly Educated Architect. As it stands, IDP, ESSA and NCARB are extremely hide-bound entities mired in red tape. Isn't it enough that these programs are so byzantine that they discourage participation except under duress? These entities, in an effort to be regulatory for all markets, have become monopolies of the highest order. The difficulties they mandate for any individual with "nonstandard" history is enough - having personal experience expire is absolutely counter to the concept of broad experience.

My vote is NO on 6 MONTHS. I completed IDP and helped others fill in paperwork. It is a DECENT GUIDELINE for mentorship, and helped me gain experince in areas I would not have otherwise. HOWEVER, the rules set by NCARB are confusing, the fees exasperating, and timeframe for turn around long. Compared to other professions, like doctors and lawyers, who use a honor systems for continued education, we're using a highly regulated system for low quality training. I'd like to have more time talking about projects with my interns and making the world better, than filling out training reports and helping them understand the process of NCARB. Member boards have clear, fast processes, why doesn't the big cheif of boards also?

This proposal is not only disappointing but is outright irresponsible!

What is the purpose of the IDP program? It is a means to document and track working experience in specific categories based on a measure of time. Should a professional’s time and experience expire? This profession, which is rooted in apprenticeship, historically and currently values time and experience above all other measures of performance. This proposal devalues that experience and further devalues the profession.

This proposal is also highly discriminatory against women. As a woman, I am highly offended by the additional penalty this proposal will apply to our careers by temporarily leaving or choosing a part time schedule to start a family during this same period of time. We are already knowingly forgoing growth and advancement in both position and pay by making this decision. It is unacceptable to include a loss of earned experience as well!

This proposal will also impact others who may have an unintended life crisis, an accident, illness and/or job lay off that are not a matter of personal choice. This also does not take into consideration the firms that do not offer the flexibility or support to provide an intern with the “ideal” experience within the “ideal” time. Many firms are less than ideal, and the intern must be flexible to meet the needs of the firm first. It is unrealistic to not acknowledge the role and influence of the employing firm.

Providing a provision to prevent procrastination or encourage motivation is akin to legislating common sense, a futile endeavor. If there is to be a penalty, it should be placed upon the employing firm. These are the professionals are actually responsible for and provide the greatest influence for mentoring, training and motivation.

If such a provision is passed, I would hope that we then apply the same standard to the senior and principal architects who would also be subject to losing their time, experience, earnings, and license too.

As an IDP Mentor and former IDP participant, this sort of limitation for reporting training activities is ludicrous at best. The NCARB has proven itself extremely inefficient and poorly managed already, even before imposing arbitrary deadlines.

The running joke amongst most Architects attempting to obtain an NCARB Record is not IF a problem will occur, but when and how many problems will be encountered. NCARB commonly misplaces files, records, payments, etc. even to the point of requiring multiple submissions for the same required documentation.

For NCARB to now presume they can apply a limitation on when training activities can be reported is laughable in light of their incompetence as an organization. I can definitely see many people becoming so frustrated by the arbitrary rules, lost information, mismanagement and other problems that they simply give up the process and leave the Architectural field. We definitely don't need another reason for a mass exodus from this profession. It is already hard enough to find qualified staff.

I suggest that NCARB instead work to clean up their act, creating an organized and efficient organization. This would help the process much more than applying deadlines onto overworked and distracted intern architects who need help not hindrance. Better yet, just fire everybody at NCARB and start over from scratch.

Seems like this is another attempt for this organization to become relevant. If NCARB wants to become a meaningful part of an architect's education, it should invest time and money in relating to the existing professional community and the mentoring process. Increasing the burden on the apprentice only diverts attention from current disconnect between registered architects and the process of becoming an architect. The current process is so rigid and inflexible it is dismissed as "an expensive game" or "just jumping through hoops" by those who are now mentors. Until mentors can embrace the process with confidence, NCARB will continue to be ignored and disrespected by registered architects and those struggling to beome one.

I think NCARB and the AIA need to ask this question,

If the IDP process needs another stick, could there be something wrong with the process?

Quite frankly, this proposal enrages me.

IDP is already a monopolistic racket, and to add another hurdle to licensure in an already bloated bureaucratic process is too much. This will certainly have the effect of reducing the number of candidates participating in IDP. I know from colleagues that the barrier blocking them getting into the process is that it's unclear, cumbersome, full of paperwork and EXPENSIVE. What is the incentive to getting licensed if one works at a large firm? Paying yearly fees? We certainly don't get the community recognition and correlating compensation that being a "licensed professional" deserves. Shame on NCARB for contributing to the demise of accessibility to this profession.

This proposal from NCARB is complicated. I imagine it is in an attempt to improve internship, assuming the outlined Training Areas can improve the breadth of experience an emerging professional seeks out.

I find it upsetting that NCARB is sneaking this onto the June agenda without soliciting comments from the architecture-public at-large.

The limit on paperwork submission turns the profession's back on those who have worked for years in architecture (don't tell me there aren't people in your office who do the work of architects, but aren't architects), and finally decide it's time to be professionally licensed. And these points about foreign professionals, and women who may struggle to balance their lives, must be considered. I don't think the profession would agree we want to turn our backs on those who take a different path into the profession.

NCARB already seems taxed to process IDP and send documents to the states in a timely manner. I do not see how multiplying the amount of information they get on any given day will in any way improve the process.
I am firmly against this unnecessary new rule.

I think this is another undesireable roadblock to liscensure and is an overly Bureaucratic Solution in search of a problem. Instead of requiring reporting every 6months or you LOOSE credit for work experience, Why not reduce the Cost of Testing of each ARE Segment by 5% or some percent if Interns submit paperwork each 6 months.

I really don't understand the rational of requiring a min. number of hours per week to obtain IDP credit, lesser hours don't devalue the experience gained and many people have individual circumstances which may dictate shorter work hours.

I say let market forces and local laws dictate professional licensure. Like the bar exam, students coming out of BArch or March programs should be immediately eligible for the ARE. The exam should be administered by a consortium of developers, contractors and each state's planning and building code depts. IDP, NCARB, and AIA can all disappear today and nobody will miss them except for its officers.

The scores of interns who do not enroll in IDP immediately and think they can back log their time from prior firms will be the only ones hurt by this new ruling. The "I worked there 5 years ago, therefore I'm entitled to training units" attitude will be over. Often interns waste more time trying to back log work from firms that have gone out of business because they think they can get away with filing all their hours at once. It equates to trying to finish a project the week before its due without working on it for the months ahead of time. You know it's due eventually, why not work on it as you go instead of cramming at the end?

Yet another incredibly stupid idea from NCARB.

The focus seems to be on more red tape and creating a byzantine bureaucracy than in assuring the IDP process actually helps train future architects.

NCARB is already over taxed dealing with the complexities of it's current system. To think that the addition of another level of complexity will work better simply defies common sense.

NCARB can't even send me a monograph I ordered two months ago even after apologizing for the delay a month ago. It's still not here. What makes anyone think they can handle the additional burden imposed by the proposed process?

I think NCARB should get it's own act together before imposing additional restrictions on Interns. I think the staff at both NCARB and AIA have their heads in the sand and don't care a whit about interns as evidenced by the weekly emails I receive from AIA where politics is the major focus and NCARB's seeming unwillingness to improve it's own internal system. Rarely is there even a mention of what is best for interns education let alone making any progress to help them gain licensensure. NCARB can't process items sent to them now in a timely or reliable fashion. How about if we impose a penalty on NCARB for not properly or in a timely fashion processing what is sent to them? The entire system is archaic and unnecessarily cumbersome. From the intern's perspective the system is set up to keep new people to the profession in low paying grunt jobs as long as possible and the profession could care less how many people who achieve a degree in Architecture never receive a license.

A little background, NCARB is made up of registered architects, see below pulled from NCARB’s webpage.
NCARB Members
NCARB members are the architectural registration boards of the 50 states, the District of Columbia, and three U.S. territories (Guam, Puerto Rico, and the Virgin Islands). Each registration board has state-appointed public and professional members as well as an administrator.

The IDP Committee of NCARB comprises of registered practicing architects from state boards and intern(s). This committee proposes changes to the IDP process, which the Board of Directors, also comprised of registered architects many from state boards and who practice, vote on.
So in short, the 6 month rule was derived from registered practicing architects that serve or have affiliations with their state board of architects. Therefore, they are mainly concerned about the Health, Safety, and Welfare of the public and the means of which to be registered. IDP is a state edict for registration in many states. In the end, the process of registration has to stand up in a court of law.

So when one thinks that NCARB’s rules and regulations are irrelevant and are detached from the status quo; remember that it is our colleagues that are practicing like us that are setting these policies.

The proposal doesn't support the basis of IDP.

IDP was initially established to help young architects (interns - this word is derogatory) gain a broader exposure to the profession through a variety of practice based experiences not typically found in formal education. The time period in which this experience occurs can and will change from person to person. There is no such thing as a three year "finish line" as everyone's experience is different and rate of learning is different. Therefore, why penalize young architects for submitting information when they are not ready to move to the next step, the ARE?

On top of this, NCARB can NOT keep up with the paperwork as it is. Several years ago when I went through IDP, it took months to hear back from NCARB on receipt of the information alone, and then many more to actually receive approval. Through various colleagues, I've been told it's even worse now. Well before additional submittal requirements are established, NCARB should re-evaluate their internal process and potentially staffing to learn how the review process can be expidited.

I find it hard enough to believe that NCARB thinks that this perfect formula spits out well trained architects. Now, it is even more of a stretch to think that requiring "young architects" to submit additional paperwork will actually improve their professional practice experiences. The two, paperwork and professional experience are just not related.

If NCARB wants to correct the system, then it needs to help architectural firms find better ways to develop the IDP program within their practice. This is how young architects will benefit from the program... through the young architect's actual experiences, not through additional paperwork with additional deadlines.

I’m currently trying to go through the NCARB/IDP process. NCARB took over 2 years to log-in the training reports, transcripts and other information they wanted to be submitted. After over 2 years they “decided” in an apparently random manner, what information to count and what to not issue credit for. If the interns spend countless hours and money to go through IDP and will have even more restrictions in getting IDP done, then NCARB should have to step up to the plate as well and process IDP information in a timely manner, after all, interns PAY for the service…

It seems that the interns will get the short end of the deal here, as NCARB officials are not able to handle the load of applicants, schools don’t train their students on IDP at all, and small firms don’t have the time or manpower to monitor and supervise the IDP process. It all looks fair and do-able on paper, but the reality of the process gave me a very different experience.

I read all the other comments and agree 100% with most of them. NCARB needs to be accountable for their actions, especially if they want to hold interns to such high, almost unachievable standards. The process needs to change to be reality oriented and fair. This change will not come from within NCARB, it needs to come from the AIA.

Ahhh bureaucracy at its finest. This is a definate textbook example of the top of the hierarchy dicating what is best for the bottom of the hierarchy. This proposal makes it seem like NCARB has realized that it is not the efficient machine that it thinks it is and in an attempt to correct the problem they are penalizing the end user. People have pointed out that NCARB is composed of peers in our profession. I personally would like to see how frequently those on the head committee actually practice Architecture.

Apparently they forgot that one grows through experience gathering and not point gathering. You want to get as many points as possible play basketball. You want to grow into a better Architect get out and work for various Architecture Firms. A points system has no place in the design profession.

This proposal is simply appalling. If I understand correctly that only full time work lasting at least 6 months would count, then this rule would only further reduce interns to slave status.

An intern who has worked for several months under horrible conditions would be required to stick it out until the 6-month mark, then kiss up to the boss so he'll sign the forms. An employer could penalize an intern he did not like by firing him/her at 5 1/2 months so the time would not count. Or he could simply refuse to sign the work verification in the required time frame. Interns would be punished by NCARB for the slack behavior of employers who fail to complete their part of the reporting task.

Women interns who want to take a hiatus or work part time to start a family can simply forget it, because now NCARB is in the family planning business, making the decisions for women. Somebody please tell NCARB that we already had a women's movement in this country, which kicked into high gear 40 YEARS AGO. Interns of any gender who must leave a job prior to the 6 month mark, perhaps due to a family emergency, or simply a spouse's job transfer, will doubtless be offered the option of groveling to NCARB to explain their situation and beg forbearance.

The term "slavery" is not an exaggeration in these situations. Though we would all like to think that such situations would not happen, you can bet they would indeed. In some form, they already do, only now NCARB wants to exacerbate them and blame/punish the victim.

So many qualified people would abandon the pursuit of licensure, that employers would suffer from difficulties finding staff. As more people forego licensure, yet continue to do the work of architects (with a firm colleague providing the stamp), the public will get the impression that a license has no meaning at all. Reducing the number of architects in this manner will not increase our pay. It will only further erode our already paltry influence on society.

Though I found the IDP process cumbersome, as have seemingly all interns before and after me, I did not have such a vehement disagreement with NCARB's tactics as I have since I read about this proposed rule. The AIA has a DUTY TO THE PROFESSION to take a position against this, and to ACTIVELY OPPOSE IT.

IDP revisions are necessary and the biggest problem with life as an intern is that you must work for a firm to get there and in a competitive market place, economic forcing works against the IDP task distribution and forces specialized tasking. In general competitive terms the firms are more invested in fewer licensed architects to compete against and want fewer threats in the market not more.

The 6 month rule will pretty much require a 6 month minimum employment contract between intern and the firm and the contract must further require that the firm serve the employees IDP interest in the tasks assigned. The firm in competition with others will be unlikely to sign such a contract. Such contracts will abrogate work for hire legislation in most of the work for hire states.

Catherine Barfield AIA has accurately described the flaws of the 6 month rule and I have added a few concerns of my own.

The proposed 6-month rule for reporting IDP credits may seem like a good idea, but it is really a patronizing way of adding burdens to already overburdened architects and interns. Do we really need the added stress? While fostering more active engagement of mentors and supervisors, and helping interns discipline themselves to turn in IDP reports on a regular basis is a commendable goal, legislating it is probably not the best way to do so. Recommending it and making resources available to simplify the process may not be sufficient in every instance, but at least it treats the mentors, supervisors and interns like adults, allowing them the choice and flexibility to report on their own time schedules and, yes, even the opportunity to fail. In fact, legislating would simply add more stress to the over-busy, over-burdened architects and interns. It would probably result in more interns failing to report their hours before the deadline, rather than fewer. Leave us the dignity to be in control of our own reporting and help relieve us of burdens rather than adding to them.

How about requiring NCARB to grant full credit for intern's work not approved/reviewed within 6 months time? Why should the burden be placed with the intern when firms and mentors are not to be held accountable?