The “Six-Month Rule”

In June, the National Council of Architectural Registration Boards’ (NCARB) Member Boards passed a rule requiring interns to submit their training units in reporting periods of no longer than six months. The “Six-Month Rule,” as it has been nicknamed, will go into effect on 1 July 2009 for interns who begin an NCARB Record on or after that date and 1 July 2010 for all interns regardless of application date. All training unit reports must be submitted electronically and within two months of completion of each reporting period.

Things Supervisors and Interns Should Know

  • The “Six-Month Rule” is designed to improve both the accuracy of reporting and the overall IDP experience. The IDP Guidelines have long recommended that interns submit reports to NCARB every four months. Under the new rule, interns will be required to report training units earned in intervals of no more than six months. However, they can submit reports more often if they wish.
  • Regular reporting will provide an opportunity for interns and supervisors to review progress made over reporting periods and develop a plan for acquiring training in the remaining areas. This benefit should help prevent interns from being surprised by falling short of required training units as they near the end of their internship. Supervisors will also be more familiar with the work documented and therefore would be more likely to approve training reports.
  • Implementation of the “Six-Month Rule” is dependent on an online reporting system. The electronic Employment Verification Reporting system (e-EVR) will be available by the end of December, but the “Six-Month Rule” will not go into effect until at least six months after the online reporting system is launched. Should the new system not be fully tested and operational by 31 December 2008, each implementation date will be pushed back and will go into effect six months after the system is operational.
  • Once interns have submitted their training units by entering them into their Record online, those units are protected while any loose ends are tied up. Interns will not be affected by any delay caused by their supervisor or NCARB. However, submitted training units can be lost if they are deemed invalid by their supervisor, or if they are not earned in accordance with the rules of IDP.
  • The “Six-Month Rule” allows parents of newborn infants or newly adopted children to receive a six-month extension of the reporting deadline upon proper application. Extensions for active military service and serious medical conditions are also available.

All of the provisions of the “Six-Month Rule” are designed to make every internship experience more constructive and valuable. The rule will greatly improve the accuracy of reporting, which should help reduce the amount of time it takes interns to complete the IDP.

NCARB’s Committee on the IDP has compiled the following examples of the basic methodology of the “Six-Month Rule.”

Example 1:
An intern taking maximum advantage of the reporting and filing periods would have through August 30 to report Training Units that were earned during the six month period starting January 1 and ending June 30. While the reporting period is a maximum of six months, the filing period could be any time on or after June 30 through August 30.

Example 2:
Same example as above, but there is an incidental problem with the report or supplementary information is required and it takes additional time for NCARB and the intern to resolve. The intern may still count the time between January 1 and June 30 once the problem is resolved and accepted by NCARB.

Example 3:
An intern reporting Training Units earned between January 15 and April 14 must report these Training Units by June 14, two months after the end of the period being reported. If, for some reason, an intern missed his or her intended filing date of June 14, because only four months of Training Units were being reported, the intern could extend the reporting period and not lose any credits. It is anticipated that the online reporting form will advise the intern at the time he or she is filing the report that the filing date is more than two months after the end of the reporting period and, if such is the case, also advise that either a longer period must be reported (but never more than six months) or a later beginning date to the reporting period must be entered. So, if the intern missed the intended filing date of June 14 and actually filed on July 1, he or she could file on July 1 for the reporting period beginning on January 15 and ending on May 1.

Example 4:
If an intern attempts to file a Training Unit report on October 3 for a period covering January 15 through July 14, the report will not be accepted. The intern must recalculate and resubmit the report. In this example, February 4 is the earliest possible start date for a Training Unit report submitted on October 3 and any units accumulated from January 15 through February 3 would be lost. If February 4 was used as the start date, then the reporting period would end on August 3, six months later, and the intern could file his or her report on October 3.

Example 5:
An intern has become a new parent or adopted a child on January 15. Before taking a leave of absence on January 1, the intern had completed six months of work (July 1 – December 31). Whereas the intern would normally be expected to file the Training Unit report by February 28, following a documented and approved request the intern would be given until August 31 to file this report.

Example 6:
An intern has been called to active military duty on January 15. Before this event, the intern had worked until December 31, having completed six months of work (July 1 – December 31) that could be reported for Training Unit credit. Whereas the intern would normally be expected to submit the Training Unit report by February 28, following a documented and approved request, the intern would be given a reasonable extension for filing this report following the intern’s end of active military duty.

Example 7:
Similar to Example 6, an intern who has experienced a serious medical condition could, with appropriate and approved documentation from a licensed medical doctor overseeing the intern’s care, be allowed a reasonable extension of the two-month filing period.

Introducing e-EVR

Interns will soon be able to enter their Intern Development Program (IDP) training units online with the electronic Experience Verification Reporting system (e-EVR). Even though the e-EVR and the “Six-Month Rule” will work in tandem beginning 1 July 2009, they are two separate NCARB initiatives. The e-EVR will become the standard way for Record holders to submit Experience Verification Reports before the “Six-Month Rule” goes into effect.

The e-EVR is part of NCARB’s Business Process Reengineering (BPR) Plan to improve customer service. Now one-third of the way through the three-year plan, the Council has already taken numerous steps to reduce processing time, including implementing the online application in August 2007, the online request for early eligibility in October 2007, and online renewal in August 2008.

The e-EVR launch date will be announced on www.ncarb.org as well as through mail and e-mail communications. Interns should begin using the e-EVR as soon it is launched, as it offers many benefits over the paper employment verification form, which will be quickly phased out.

Benefits of e-EVR

  • Interns can enter their training units over any timeframe (weekly, bi-weekly, monthly, quarterly, or every six months). Units may be saved as work-in-progress and submitted for their supervisor’s review at a later date.
  • e-EVR will prevent some common errors, reducing the possibility of rejection during the evaluation process.
  • Once interns submit an online report, their supervisor is automatically notified via e-mail that a training unit report is available for review and approval.
  • Interns can check their IDP progress at any time by logging on to “My NCARB Record.” They will be able to see which training units have been completed, which are pending supervisor approval, and which training areas still require additional documentation.
  • The IDP progress report enables interns to identify training area deficiencies sooner so they can work with their supervisor and mentor to develop a plan to gain exposure to these areas.
  • The system includes a message center that allows interns to track NCARB communications about their reports.