The Case Against “Master’s-or-Equivalent” Licensure Requirements

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The Case Against “Master’s-or-Equivalent” Licensure Requirements Thank you for the opportunity to discuss the need to maintain the current education standards for engineering licensure. The basis for licensure is protection of the health, safety and welfare of the general public. INSERT NAME AND DATE HERE

Current Requirements for Licensure Graduation from four-year engineering program accredited by Engineering Accreditation Commission (EAC) of ABET Successful completion of the NCEES Fundamentals of Engineering (FE) exam Completion of four years of progressive engineering experience Successful completion of the NCEES Principles & Practice (PE) exam I represent engineering societies with over 300,000 members and <number> in the state of <state name> who are in favor of maintaining the current requirements for engineering licensure. NCEES is the National Council of Examiners for Engineering and Surveying, which is the national organization that oversees the engineering licensing process. NCEES is the organization whose Model Law was changed to call for a Master’s Degree or Equivalent as the educational requirement.

To MOE or Not MOE MOE = BS+30 = “Raise the Bar” No compelling evidence MOE opposed by vast majority of eminent engineering societies This presentation will show that no evidence has been presented that earning a master’s degree or adding thirty credit hours will have a positive impact on the public’s health, safety and welfare.

Confusion Too many terms MOE = BS+30 = “Raise the Bar” No compelling evidence MOE opposed by vast majority of eminent engineering societies Some of the terms you will hear on this issue are: FPD – first professional degree (the Baccalaureate) BS+30 – The original proposal from ASCE and NSPE to require 30 additional semester credit hours, passing the FE (Fundamentals of Engineering), and experience before sitting for the PE (Principles & Practice) MOE – (Master’s or equivalent) – is the current term being used because it is perceived as a more saleable description for BS+30 

Confusion Professional Practice, Prestige, and Licensure MOE = BS+30 = “Raise the Bar” No compelling evidence MOE opposed by vast majority of eminent engineering societies Other terms are: BOK - Body of Knowledge – a conceptual framework for the FPD curriculum that seeks to map-out what person in the “Professional Practice of Engineering” should know. “Raise the Bar” an NSPE/ASCE effort that pushes the BOK as the desired domain of an FPD engineering education and used to justify inclusion and adoption of MOE by PE Boards

NCEES Model Law A guide (i.e., not mandatory) for states to adopt It includes a provision to require an MS (or its equivalent [≈ 30 add’l semester credit hours]) to sit for the PE exam, beginning in 2020 Many licensing jurisdictions use the NCEES Model Law as a guide for enabling legislation on engineering licensing. Due to the federated nature of licensing jurisdictions, some states may adopt MOE and others may not, causing disparities and hindering licensee mobility. If our state adopts MOE and surrounding states do not, we are likely to lose engineers to our neighbors. This will potentially reduce the number of individuals entering the field as fully qualified professionals and stunting <state name’s> technological growth and competitiveness. The quality and equivalency of non-university-based courses, the “or equivalent” part of “Master’s or Equivalent” will be a major concern. It will be challenging to resolve the bandwidth and depth of requirements and outcomes assessment between university and Continuing Education Unit-Professional Development Hour based courses when the two approaches are bundled into one competency algorithm. Many early career engineers receive extensive in-house training from their employers, which may not count toward their “or equivalent” credits.

Professional Practice v. Professional Engineer Technical, legal, managerial, & social concepts within an engineer’s training & experience Professional Engineer A legal designation Defined by: Knowledge Experience Ethical base Terms are confused in NCEES/NSPE/ASCE justification of MOE or BS+30 Professional Practice – a state where technical, legal, managerial, and social concepts are within an engineer’s training and experience implies being a PE is synonymous with professional practice, but--- The PE is a legal designation

State Regulations The mission of licensure boards is to protect the health, safety, & welfare of the general public Typical definitions are: The Vermont Board of Engineering is a five member Board created by the Legislature whose members are appointed by the Governor to administer the laws for this profession in the State of Vermont. The Board's mission is public protection.” “The mission of the Oregon State Board of Examiners for Engineering and Land Surveying is to regulate the practices of engineering… in the State as they relate to the welfare of the public in safeguarding life, health and property.” "In order to safeguard life, health and property, and to promote the public welfare, the practice of engineering and land surveying are declared to be subject to regulation in the public interest.“ (Oklahoma) And similar language in North Dakota, Pennsylvania, Mississippi, North Carolina, et al.

State Regulations Elevating the status or perception of the profession Defining the scope of the profession or professionalism Contributions to economic development Ensuring the supply of PEs in a state What the state regulations do not say…. … To elevate the status or public perception of engineering and registered professional engineers … To define the scope of the engineering profession and professionalism … To regulate the specific content of college/university engineering degree programs … To contribute to economic development … To provide economic/competitive advantage to engineers registered in the state. … To assure sufficient supply/demand balance of the number of registered engineers in the state.  These are not within the mission of the engineering licensing boards, but are arguments used to support “Raise the Bar” and MOE.

Degree program accreditation Two NCEES-validated exams Four years of supervised experience Public safety is assured by a mature and adaptable system of knowledge and experience that limits risk.  We have effective degree program accreditation by criteria and outcomes assessment governed by the engineering societies representing the profession. A program can earn accreditation of up to six years. To earn a license one must earn a degree from a four-year engineering program accredited by Engineering Accreditation Commission (EAC) of ABET; pass two, major, field-validated examinations; and build an experience and ethical base in four years of early practice through supervised and responsible charge of projects. NCEES has been and must continue have sufficient capability, currency, and validity to continue to do its part in assuring engineering competence. Knowledge, together with experience and an ethical base developed in responsible charge of projects that is sufficient to assure minimal risk to the public, which are the current requirements, are sufficient now and into the foreseeable future. There is no evidence to the contrary.

Continuing Education Body of codes and standards In addition to the one-time, front-end assessments described in the previous slide, the NCEES Model Law requires annual continuing education to maintain one’s license. Continuing education is an essential career-long need for engineers and significant learning is necessary for engineers of all disciplines beyond the studies that qualified them for the First Professional Degree. There is also an extensive body of legally empowered engineering codes and standards -- created, validated, and evolved by the engineering community, and applicable to the entire bandwidth of industry/commercial sectors, consumer product and public infrastructure domains.

Engineering Societies Supporting ABET AAEE ACerS ACSM AIAA AIChE AIHA ANS ASABE ASCE ASEE ASHRAE ASME ASSE BMES CSAB IEEE IIE INCOSE ISA MRS NCEES NSPE SAE Int’l SFPE SME SME-AIME SNAME SPE SPIE TMS WEPAN On the larger scale, these Societies … in federated organization, annually deploy over a thousand engineers, that continuously undertake the evolution, assessment and assurance of entry-level engineer standards of learning at a national (and increasingly international) level …. across all sectors of engineering endeavor. Our societies will continue to review the body of knowledge required for entry-level engineers, not from the standpoint of professional registration, but from the standpoint of the global technical competitiveness of graduating engineers.

What problem does MOE solve? Front-loaded specialized education shows no specific benefit to public safety ABET accreditation values outcomes above numbers Does MOE address increased public safety as much as continuing education to keep abreast of technology? The ABET EAC General Criteria reinforces the fact that Master’s programs are designed to add technical specialization not the practical education and experience implied by PE requirements. Front-end loaded education as proposed in MOE becomes considerably out of date well before mid-career. Most graduate schools require a 3.0 grade point average for admission. If we say that a master’s degree is a requirement for professional practice, we are telling many of our students that they are not qualified for a license. How many actions have been taken by your State Board in the past 10 years against engineers for technical incompetency at a cost to public safety and welfare? If any actions were taken, would 30 additional university credit-hours have pre-empted those incidents? It is, therefore, irrational to expect that the specific front-end loading a 40-year engineering career with 30 additional credit-hours of university coursework would make a discernible difference in increasing public safety -- either immediately in the field or at any time in the future. Even after decades of rapid technological change, no data from licensing boards has been presented showing a degradation of public safety over time due to increased competence failures of practicing PE’s. The Society of Naval Architects and Marine Engineers, for example, has reported no early career incompetence among their disciplines identified by state boards. The accreditation of engineering programs has successfully moved from the so-called credit hour “bean counting” to outcomes based assessment as well as assessment of Program Educational Objectives, which are target accomplishments of students three to five years after graduation. Success on the Fundamentals of Engineering Exam and Principles and Practice Exam are commonly used indicators.

What problem does MOE solve? Doesn’t address already-licensed PEs A deterrent to study (e.g., costs, time) and to employers (i.e., more $ to hire engineers) What problem does MOE solve? If it’s intended to address the public health and welfare over a long term engineering career, it’s ineffective and we ask virtually nothing of the current generation of 450,000 (est) PEs Our organizations support education to the level required to achieve a person’s career goals and continuing education to maintain that expertise, but MOE: Makes engineering look even more daunting as a career choice Works against government and industry efforts to enlist students in STEM careers Adds cost of tuition, time off, books, commuting, and student loans to achieve PE-ready status Adds overhead costs to engineering firms to bring BS hires to the MOE level and/or to hire MS level staff

“Reduced Hours” Issue Basic math & science counted in 150 units Superior computation capabilities ASCE and NSPE point to a decline in the number of credit hours needed to earn a bachelor’s degree in engineering over the years. Average credit hours for the FPD in 2010 were 128 – a decrease in average credits of 1.5 from 1998. Many of the 150 credits so common a few decades ago were for basic math and science that are now part of the high school curricula. The outcomes based assessment of modern FPD programs have resulted in better, more focused coursework and computational capabilities are significantly superior to those available decades ago. Computers have replaced slide rules. Additional specialized coursework at the beginning of an engineering career may not be as important as continuing education to keep abreast of technology So the claims being made about the reduced hours are as backward as the flaws in the clock on this slide.

Professional Status of Engineers 150 Hour Requirement for CPA’s Public perception of engineers No boost in professional status resulted from the implementation of the 150-hour requirement for Certified Public Accountants. States that implemented this saw a significant decrease in the number of accounting students and of CPA’s. Increasing prestige for engineers by requiring MOE for the PE does nothing to enhance public safety, but does increase the cost of becoming a professional engineer. “Raising the Bar” is a slogan used by MOE proponents. It is not a goal. Enhancing the status of engineers is neither the mission of the state, nor is it systematically achievable with MOE, nor is it even on the list of important challenges we must surmount as engineers. The status of engineers has its marketplace, but it is a matter outside the state’s public health, safety and welfare interest.

Other options? Career-long professional development requirements Begin continuing education immediately after B.S. degree? Continuing education is an essential career-long need for engineers, and significant learning is necessary for engineers of all disciplines beyond the studies that qualified them for the First Professional Degree (FPD). These principles are already incorporated in the present system as most states require professional development credits to maintain licensure. We are in favor of having engineers getting used to continuing education on an annual basis. We would endorse a proposal to have, say 60 professional development hours required between the time of passing the FE and the PE exams. The Model Law requirement of 30 semester credit hours, which translates to approximately 450 professional development hours, to be accomplished in four years is not feasible. Technical competency is a career-long moving target. In the engineering practice arenas governed by licensing boards, if there is evidence -- or even a body of compelling indications -- that evolving deployment of technologies is compromising the licensed engineer’s competency and ability to practice safely, then the Board should consider: On the front end, insist and support the NCEES in producing more contemporary, relevant, and practice-validated examinations, and For the Engineering Interns and Licensed Professional Engineers now practicing and maintaining registration the field: Strengthening the validity and effectiveness of The Engineering Intern Experience – (eg. more years; more rigorous testimony of the supervising, responsible –charge engineer) Implementing a more safety-strategic and extensive standard of annual, career-long continuing education requirements. This provides current technology studies that, by definition, will become obsolete in relatively short order – all on the front end.

The consensus of these engineering organizations which make up the Licensing That Works team is there is no compelling evidence for the MOE requirement. Some believe that the academic community favors MOE as a way to force students to take more classes. However, the Engineering Deans Council of the American Society for Engineering Education sees the problems with implementing MOE and has taken a position against it. Knowledge - attested by attainment of accredited BS engineering degree plus passing two NCEES validated examinations, plus required career-long continuing education, together with an Experience and Ethical Base - developed in supervised and responsible charge of projects, are sufficient and sufficiently adaptable to assure minimally acceptable risk to the public, now and into the future. We have been presented with no systemic evidence to the contrary.

www.LicensingThatWorks.org Resources Endorsements FAQs You can find additional information at the Licensing That Works website. The LTW Societies listed earlier will continue our assessment and advocacy of effective, rational, relevant and durable systemic approaches to assuring the public health, safety, and welfare through engineering education, engineering codes and standards, and professional registration. We hope that NCEES would rescind its Model Law. Until this happens, we will oppose the acceptance of MOE jurisdiction-by-jurisdiction if it comes before individual legislatures and/or licensing boards. We welcome your support and participation in our efforts. In summary, engineers are already held in high esteem in national polls compared with attorneys, physicians and other professionals. There is no need for additional prestige, nor gain in prestige, from an increase in educational requirements for PE’s. Again, the public’s health, safety, and welfare -- not status -- is our job

I would be pleased to answer any questions that you have.