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Licensing Boards: Entities That Govern the Design Professions Part 2 – Qualifications of Perspective Licensees and Licensing Exams

  

This is the second in a four-part series on this blog addressing licensing boards governing the design professions, comprised of: (a) Part 1 – Introduction to Licensing Boards and Revisions of Laws and Regulations; (b) Part 2 – Qualifications of Perspective Licensees and Licensing Exams; (c) Part 3 – Issuance of Licenses and Registrations; and (d) Part 4 - Enforcement. 

This series of articles describes the basic functions of licensing boards governing the design professions and how their operations affect personnel engaged in architecture, engineering, and other design professions in the United States. In this series of articles, laws, rules, and regulations are referenced as either “laws and regulations” or “statutory requirements”. 

Three basic actions are necessary for an individual to become a licensed design professional: (1) completing accredited education in the subject design profession, (2) obtaining appropriate experience in the practice of the design profession, and (3) passing exams required for licensure. Each of these is discussed below. In addition, applicants must be, “of good character” and furnish references from other design professionals licensed in that jurisdiction.

Education

Education must be obtained in the appropriate field from an institution of higher learning with appropriate accreditation. For example, education in architecture must be completed at an institution accredited by the National Architectural Accrediting Board (NAAB), and engineering education must be obtained from an institution accredited by the Engineering Accreditation Commission of ABET (EAC/ABET). ABET was originally the Accreditation Board for Engineering and Technology, but its name was changed to simply “ABET” in 2005. Applicants for licensure must submit to the licensing board evidence of their successful completion of education, typically including a transcript from the accredited college or university. 

Engineering Qualifications and Exams

Engineering licensure requires the applicant to pass two, separate licensing exams: the “Fundamentals of Engineering” (FE) exam (sometimes known as the “Engineer in Training” or EIT exam) and the “Principles and Practice of Engineering” (PE) exam. Both exams are prepared and administered through the National Council of Examiners for Engineering and Surveying (NCEES).

The FE/EIT exam requires six hours, of which the exam proper occupies 5 hours, 20 minutes. Alternative versions of the FE/EIT exam are available for seven different, broad engineering disciplines: chemical, civil, electrical and computer, environmental, industrial and systems, mechanical, and “other disciplines”. An examinant needs to take and pass only one of these alternative exams. To be eligible for the FE/EIT exam, a person must be either in their senior year of undergraduate education in an EAC/ABET-accredited program, or have obtained either a bachelor of science or master’s degree from an EAC/ABET-accredited program.

In contrast, separate PE exams are available in 16 different engineering disciplines: Agricultural and Biological, Architectural, Chemical, Civil, Control Systems, Electrical and Computer, Environmental, Fire Protection, Industrial and Systems, Mechanical, Metallurgical and Materials, Mining and Mineral Processing, Naval Architecture and Marine, Nuclear, Petroleum, and Structural. An applicant needs to pass only one of these as part of the process of becoming a licensed professional engineer. The duration of the PE exam is typically about eight hours (plus one hour for an orientation tutorial and one 50-minute break), although the duration may be longer for certain types of engineering. For example, at the time of this writing, the PE exam for structural engineering was 10.5 hours, plus one hour for orientation plus a break.

To be eligible for the PE exam, an applicant must have demonstrated to the satisfaction of the licensing board one of the following: (1) a “specific record of four years of progressive engineering experience after a qualifying [bachelor of science] degree is conferred” (source: Section 130.10.2.a.3 of NCEES's Model Law (revised September 2021); bracketed text not present in the original); (2) three years of appropriate engineering experience after a qualifying master’s degree in engineering is conferred; or (3) two years of appropriate engineering experience after a qualifying doctorate in engineering is conferred. Laws and regulations in some jurisdictions may include other, more specific requirements, and may allow an individual to qualify for the licensing exams without an engineering bachelor of science degree from an EAC/ABET accredited college or university when a specific, greater extent of appropriate experience is documented and accepted by the licensing board.

Architecture Qualifications and Exams

To become a registered architect, an applicant must pass the Architect Registration Examination (ARE) administered by the National Council of Architecture Registration Boards (NCARB). Section R301.3.2 of NCARB’s Model Laws and Regulations (2022) requires, “2) To qualify for the Approved Examination, an Applicant shall present satisfactory evidence to the Board of one of the following: a. An architecture degree from an Approved Educational Program; or b. Active enrollment in a NCARB-accepted Integrated Path to Architectural Licensure (IPAL) option within an Approved Educational Program.” At the time of this writing, NCARB’s current exam is ARE 5.0, which includes six “divisions,” as indicated in Table 1, together with the exam duration for each.

Table 1: ARE 5.0 Divisions

Division

ARE 5.0 Maximum Duration

NCARB AXP Experience Required for Licensure

Practice Management

2 hours, 40 minutes

160 hours

Project Management

3 hours

360 hours

Programming & Analysis

3 hours

260 hours

Project Planning & Design

4 hours, 5 minutes

1,080 hours

Project Development & Documentation

4 hours, 5 minutes

1,520 hours

Construction & Evaluation

3 hours

360 hours

TOTALS

19 hours, 50 minutes

3,740 hours

Each Division of the ARE is a separate exam that may be taken in any order desired by the applicant, upon the licensing board’s acceptance of the individual’s application to take the exam. The various divisional exams need not be taken on consecutive days, although some licensing boards may establish that the exams all be taken within a stipulated period, such as five years. While NCARB presents no experience requirement for eligibility to take the exams, beyond graduating from an approved educational program, most state licensing boards’ regulations establish a mandatory experience requirement as a precondition for examination. The experience requirement varies by jurisdiction. For example, New York requires four years of relevant, documented architecture experience prior to taking the ARE; Pennsylvania requires three years; and both Massachusetts and Nebraska require completion of NCARB’s Architectural Experience Program (AXP) as indicated in Table 1, above.

Section R301.2 of NCARB’s Model Laws and Regulations (2022) includes the following requirements for experience necessary for licensure: “An Applicant shall successfully complete the Approved Experience Program to obtain an initial License. An Approved Experience Program means the Architectural Experience Program (AXP) administered by NCARB.” At the time of this writing, NCARB’s AXP requires documentation of not less than the minimum experience indicated in Table 1, above.

State architecture boards may establish additional or alternative experience requirements, often as a precondition for examination. For example, Section 7304 of the New York State Education Law, governing the practice of architecture, requires documentation of not less than four years of appropriate, relevant architecture experience, together with a bachelor’s degree in architecture from an accredited college or university, as a prerequisite for licensure. Section 7304 of the New York State Education Law further allows (bracketed text is not present in the original and is included here for clarity): 

“In lieu of [bachelor’s] degree and experience [four years] requirements specified in subparagraphs (2) and (3) of subdivision one of this section, twelve years of practical experience in architectural work of a grade and character satisfactory to the board may be accepted by the department, provided that each complete year of college study satisfactory to the department may at the discretion of the board be accepted in lieu of two years of experience but not to exceed nine years toward the required total of twelve years.”

Common Elements for Qualifications and Exams

Regardless of whether one is applying to take the Architect Registration Examination or the “Principles and Practice of Engineering” (PE) exam, documenting compliance with experience requirements can be challenging and time-consuming. While working to accrue the necessary experience, applicants should keep appropriate records, including copies of timesheets, when available from their employer. Summaries of the applicant’s experience must be written on the licensing board’s application forms in sufficient detail to convince the licensing board that the experience is appropriate. The applicant must obtain from their supervisor, project manager, or other person supervising their work an endorsement that the applicant’s summary of claimed experience is correct. It may be advisable to retain in the applicant’s own file sufficient documentation to substantiate the experience claimed on the application submitted to the licensing board.

Experience summaries submitted to the licensing board should be focused on the types of experience necessary for the purpose. For example, an engineer’s application to take the PE exam should typically document proper engineering experience. Including other types of experience, no matter how apparently desirable they may seem to the applicant, such as performing construction observation, land surveying, or architecture (of whatever minor nature), has potential to result in the licensing board deeming such experience inapplicable and perhaps delaying the applicant’s ability to take the PE exam. Similarly, applicants for licensure as an architect must document not less than the minimum required experience established by their associated architecture licensing board. Including other types of experience, especially experience that does not properly constitute the statutory definition of architecture, for the associated division (for jurisdictions requiring compliance with NCARB’s AXP), has potential for the architecture licensing board to deem such experience as non-compliant relative to licensure eligibility.

It may be unwise to prepare and submit an application for examination or licensure documenting only the minimum experience necessary. Licensing boards may deem certain, claimed experience as insufficient. Thus, if the applicable experience requirement is four years, it may be advisable to document 4.5 or even 5 years of experience with an initial application.

Licensing exams are developed and administered by NCARB and NCEES, rather than the associated licensing board. Although the licensing board is responsible for determining an applicant’s eligibility to take the associated exam, formal application for the exam is typically through NCEES or NCARB, as applicable. Exam fees are typically payable to NCARB or NCEES.

The architecture and engineering exams are each administered at third-party, commercial test centers. NCARB and NCEES each use a different test administrator, although each has hundreds of locations across the United States and, perhaps, in other nations, as well. The exams are closed-book, although a digital, searchable reference guide is available to all examinants for each exam. Because they are administered at third-party test centers, the ARE, FE/EIT, and PE exams may be taken on a date and time of the examinant’s selection. In the past, the exams were administered only on a very limited number of days per year at very few locations in each state, whereas the current approach is much more convenient for examinants.

This article does not attempt to present complete, detailed information on the licensing exams and qualification requirements for any design profession. Readers considering applying for licensure and taking the exams should refer to official sources, including, as applicable, NCEES, NCARB, the applicable state licensing board website, and the website of the third-party exam administrator. 

Conclusions

Licensing boards have the authority to establish suitable requirements for licensure and evaluate the qualifications of applicants. While requirements for licensure for architects and engineers vary somewhat, they include multiple, lengthy licensing exams and requirements for specific, progressive types of appropriate experience. Successfully documenting compliance with qualifications requirements can be challenging and time-consuming. Although the licensing board serves as the gatekeeper for who can be admitted for examination and licensure, NCEES and NCARB develop the applicable licensing exams and separately retain independent entities to administer the licensing exams. Prospective applicants for licensure should carefully read, understand, and comply with board requirements for licensure.

Future installments in this series will include: Part 3 – Issuance of Licenses and Registrations; and Part 4 - Enforcement.

Acknowledgments: The author gratefully acknowledges the assistance of the following, who kindly reviewed and commented on drafts of this article: Jerry Cavaluzzi, Esq, of Westchester County, NY, who is Chief Risk Officer and General Counsel for Kennedy/Jenks Consultants, Inc.; and James K. Lowe, Jr., Esq., P.E. (VA, emeritus), who has more than 45 years’ experience in the A/E industry. In addition, Deborah Seiner, RA, of Foit-Albert Associates in Buffalo, NY and Steve VanDyke, RA of Nault Architects in Worcester, MA, also provided advice useful in the preparation of this article. The author is solely responsible for the content of this article. 

Original text Copyright 2024 by Kevin O’Beirne
The content of this blog post is by the author alone and should not be attributed to any other individual or entity.
The author of this blog post is not an attorney and nothing in this blog post constitutes legal advice. Readers in need of legal advice should consult with a qualified, experienced attorney.

Kevin O’Beirne, PE, FCSI, CCS, CCCA is a professional engineer licensed in NY and PA with over 35 years of experience designing and constructing water and wastewater infrastructure for public and private clients. He is the engineering specifications manager for a global engineering and architecture design firm.  He has been a member of various CSI national committees and is the certification chair of CSI’s Buffalo-Western New York Chapter.  He is an ACEC voting delegate in the Engineers Joint Contract Documents Committee (EJCDC) and lives and works in the Buffalo, NY, area. Kevin O’Beirne’s LinkedIn page.  

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