AICAD POSITION PAPER ON INTERIOR DESIGN LEGISLATION
Underlying Principles AICAD's approach to interior design certification stems from a commitment to the benefits of open and flexible access to the field for all interior designers. We believe:
The "body of knowledge" needed to practice in a field exists independently; no one owns it.
There are a variety of ways to acquire that knowledge. Degree programs are an efficient, but not the sole, means to acquire knowledge. We need multiple pathways into creative fields due to their varied and dynamic natures. Many people can acquire the necessary skills through extended work experience or through shorter degree programs combined with other education. Many others have started in one area and evolved into competent practitioners in another. Society does not benefit by a narrowing of access to creative fields. Competence is best judged on he basis of the work produced rather than credentials alone. Credentials are a result of, but they are not substitutes for, competence. Competence can and often does exist in the absence of a credential. Our mission as educators is to help produce the best educated designers we can. We do this in a variety of ways at a variety of institutions. We do not feel that politics, PR, or perceptions of the field should influence how we teach, nor what we legislate. Position Statement AICAD's position on legislation relating to the certification of designers is: 1.) Accreditation: We fully support laws that include NASAD, CIDA, NAAB, and any other USDE or CHEA accrediting agency. We oppose any legislation which limits access to only those who have graduated from a CIDA accredited program, as an unreasonable and unnecessary restriction whose need and validity is unproven. Discussion - NASAD's standards are nearly identical to CIDA's standards. There is no evidence - not even any research on the subject - showing that CIDA graduates are any better designers than others, or that NASAD graduates are any worse. Far too many programs are not accredited by CIDA to allow a monopoly to be granted, absent proof of deficiencies in NASAD. To do so eliminates too many productive programs and qualified students, or else forces schools to obtain accreditation they do not want or need. There is no proof that CIDA accreditation is a criterion so critical to success that it warrants the exclusion of all other accreditation agencies. And if the exams are truly effective at certifying future designers' competence, then the criteria needed to sit the exams should not be unreasonably restrictive. It's quite possible for people can pass these exams without a CIDA education. Many do so right now. While CIDA is effective at what it does, it isn't the only effective U.S. accreditation agency.
2 2.) Education: We fully support laws that allow for a variety of education programs and backgrounds, combined with appropriate work experience: 4 or 5 year programs plus 2 years of work; 3 year programs plus 3 years work; 2 year programs plus 4 years work; and less than two years of education combined with 8 years of work experience. We oppose CIDA's policy of accrediting only 4-year programs, and NCIDQ's new policy (January, 2009) to permit only three-year graduates to take the exam, as unnecessary and inappropriate curtailing of access. And we oppose legislation which incorporates or permits these limitations. Discussion - Many programs of less than 4 year's length can provide a concentrated education in interior design sufficient to pass a qualifying exam and become an effective designer. Many students get general art or design degrees and then complete AAS degrees later. Many others have extensive work experience that can prepare them adequately for the exams and further practice. Again, if the exams are truly effective at certifying future designers, then access to the exams should not be so restricted. Many people currently pass these exams with 2 year degrees. A one-size-fits-all education requirement runs counter to the varied ways people develop creative skills and disqualified a large number of potential future designers. And some of he nation's best designers currently practicing have little or no direct interior design education. Professionalism and experience are developed via many different pathways. We should allow that to continue. 3.) Work Experience: We support laws that allow 6 years of education and work experience combined, that allow access for those (few) people with no formal interior design education but with 8 years work experience, and that do not restrict whom the work experience can be supervised by. We oppose the IDEP program policy and the new NCIDQ exam policy (January, 2008), which limit work supervision to only those who have passed the NCIDQ exam or are state certified. And we oppose legislation which incorporates or permits these limitations. This is a particularly serious limitation for designers and students in the 28 states that currently have no certification process. Discussion - Currently, typical interior design laws require a 6 year work and education combination, and a few require no formal education. This should be the standard, unless we are to unreasonably limit access to the field for some qualified people. There are so many different ways for people to become competent enough to sit for the exams that limitations are inappropriate. The IDEP and the new NCIDQ work policies (no "workonly" access and narrowed supervision of work) are unreasonable, and in some states coercive, restrictions for which there is little or no supporting proof of "public good." 4.) Testing: We support laws that allow a choice of qualifying exams. We oppose laws that grant NCIDQ a monopoly on testing, unless NCIDQ maintains an open access policy on education and work experience. Discussion - As with accreditation, education and work experience, the restrictions in the testing arena are similarly unnecessary and unfairly restrictive. NCIDQ policies bar many students from taking its test, when there is no objective research proving they are
3 incompetent designers, fail the tests in large numbers, or pose a threat to the public. 5.) Title vs. Practice Laws: We support open, voluntary title laws ("certified interior designer" or similar). We oppose all practice acts and all laws using the title "interior designer" only. Discussion - Practice acts are an unreasonable limitation of the field. They require all designers to obtain a full state license, even if they will never undertake jobs that require permits or that present any obvious risk to the public. In many jurisdictions and for many jobs, plumbers, electricians and contractors can pull the required permits. Only five jurisdictions have seen the need for practice acts. Furthermore, analysis by the legislative analysts in at least two states recently recommended sunsetting their Interior design title laws due to lack of need or public risk. These states determined that contract laws, consumer protection laws, building codes, and the permitting and inspection processes provided ample protection of the public's health and safety. In addition, to write a title law that applies to "interior designers" only is tantamount to writing a straight practice act. It is extremely difficult to practice interior design if you can't call yourself an interior designer. Thus purportedly voluntary title acts become virtually mandatory. 6.) "Indirect" Legislation: We support open, public dialogue about interior design legislation, and flexibility with regard to work and education. We oppose the de facto legislation that occurs when groups or associations change their policies without the knowledge or consent of the state legislators. Twenty-four states, plus DC and PR, have enacted interior design laws. These laws specify the education and work experience required before one may apply for state certification or licensure. Some of these states have quite open and flexible laws on the books, with very few limitations on length of education or work. However, when a law requires passage of the NCIDQ exam (as virtually all of them do) or limits access primarily to CIDA graduates (as some do), and NCIDQ or CIDA subsequently tighten or narrow their policies, the effect is to amend the state law without formal action by the legislature. These states are thus prevented from having a full, frank, and public review of the effects of the NCIDQ or CIDA policy changes.
Association of Independent Colleges of Art & Design 3957 22nd Street San Francisco, CA 94114 415-642-8595 www.aicad.org William O. Barrett, Executive Director director@aicad.org Policy adopted October, 2004