The 6-Month Rule

The National Council of Architectural Registration Boards (NCARB) recently voted at its annual conference to adopt Resolution 2008-7, more commonly referred to as the “6-month rule.” The resolution mandates that interns report their Intern Development Program (IDP) training units at least every six months. Any training that is not reported within six months expires in accordance with a “rolling clock.” The resolution is effective July 1, 2009, for new NCARB record holders, and July 1, 2010, or later for current record holders. It’s obvious that this resolution may significantly impact anyone currently pursuing or planning to pursue professional licensure as an architect for the first time and who is a participant in the IDP process.

What was NCARB’s motivation for introducing the resolution? The principal goal of the 6-month rule is to ensure that interns report their experience in a timely manner, as opposed to allowing individuals to attempt compiling a work history that may be many years old and difficult to substantiate. The intent is to make the reporting process more rigorous and systematized, to encourage more frequent reviews with supervisors and mentors, and ultimately to better prepare our future architects. On the other hand, the 6-month rule is controversial and has been widely debated by many stakeholders.

Prior to the NCARB vote on the resolution, AIA National President Marshall Purnell sent two letters to the NCARB member boards regarding AIA opposition to it. The key concerns had to do with the following:

• Besides the intern, several people (the NCARB administrator, the employer, and the mentor) must review, sign, and submit forms, and can lose or misplace paperwork, or be late when responding. However, it is the intern who loses credits for processes left undone.
• NCARB is developing a new electronic reporting system to facilitate the time-sensitive reporting. The AIA is concerned that the new electronic system may not be fully functional or immediately equipped to handle the reporting in an efficient and timely manner. This may lead to further delays in reporting, which could result in unforeseen consequences for interns. The AIA did acknowledge that there will be an increase in regular training unit submissions once a fully operational electronic reporting system is in place and expects that the use of this technology will virtually eliminate late reporting of IDP training units.

In response to the AIA input, the actual enforcement of the 6-month reporting period will be tied to the full and successful implementation of the electronic reporting system, the dates listed above notwithstanding.

For many, the biggest stumbling block posed by the resolution as it was originally presented is that it was perceived as discriminatory, particularly against younger women. This is because the 6-month rule effectively imposes a penalty upon those who choose to temporarily leave the profession or take on a part-time work schedule to start a family while in the middle of their internships. In response to this concern, NCARB has extended the 6-month reporting period for parents adopting or having a child during the preceding 6-month cycle by an additional six months. This extension also applies to circumstances that likewise could preclude timely reporting, such as a serious medical condition or active military service. However, the resolution appears to make no allowance for a failure to report required training units beyond the 6 + 6 time limit. It’s not difficult to imagine a parent making the personal choice to extend a recess from a professional career for more than a year in order to direct his or her energies towards raising a family. Should this individual effectively be punished for this decision?

Ironically, NCARB has been criticized for its frequent inability to review and respond to IDP submissions or inquiries promptly. Opponents of the resolution have argued that NCARB needs to get its own house in order first before mandating deadlines like the 6-month rule.

While the common perception may be that NCARB is monolithic, mired in bureaucracy, and indifferent to the real needs of interns, it is important to remember that it comprises all of the member registration boards in the US. The decision to implement the 6-month rule was made collectively and not imposed by fiat by a faceless, third-party entity. Each delegation at the NCARB annual meeting (including Oregon’s) carefully weighed the issue before voting for or against the resolution.

It will be interesting to see how successful the new online reporting system is, and to gauge whether the more structured reporting process imposed by the 6-month rule achieves NCARB’s desired goal of better preparing interns to be fully fledged architects. It will also be interesting to see if the shortcomings of the resolution are so significant that the member boards will be tasked with amending the reporting requirements again after the 6-month rule is fully implemented.

Click here to find the final resolution language as adopted by the NCARB member boards.