June 2024

In Fall of 2022, the member organizations of the Interorganizational Council on Regulation (ICOR) began a multi-year effort to develop guidance on how to  better regulate overlapping practice between the professions of architecture, engineering, interior design, landscape architecture, and surveying.

Referred to by a variety of names—incidental practice, overlapping practice, scope of practice—this concept has posed challenges for both licensing boards to regulate and for practitioners to navigate. To protect the public, licensing boards are responsible for ensuring only competent individuals are practicing in each of these professions. However, boards handle issues of overlapping practice differently, each jurisdiction with their own rules and policies about what is acceptable and unacceptable overlap, which can cause consternation and confusion.

The primary objective of the ICOR Practice Overlap Task Force is to develop clear and uniform guidelines and definitions for competent overlap of practice that can be adopted as the recommended definitions in model law and policy guidance issued by the ICOR organizations for regulatory boards. Through research, surveys and subject matter input, the Task Force identified over a hundred areas of practice that could potentially involve practice overlap. By conducting research and taking a broad view of almost a hundred discrete design topic areas, ICOR seeks to identify clear areas of the design process where overlap is appropriate because professionals are competent to practice in that area and a delineation of where there is distinction between appropriate scopes of practice.

This initial research – conducted by a steering committee made of licensed professionals, member board executives/administrators, and public members (supported by staff and consultants) – resulted in the topic areas being categorized into three groups:

1. No overlap / no health, safety, and welfare impact: In some cases, no overlap was identified between professions. In others, the content area is either not related to protecting the health, safety, and welfare of the public or is related to an area of practice that is not regulated by licensing boards. (e.g., civil (roads, bridges, canals); geotechnical; business practices).
2. Acceptable Overlap: While overlap was identified, the content area constitutes an area of practice within the professionals’ scope of practice or where practitioners collaborate within appropriate licensing boundaries. These were not determined to be areas of concern for overlapping practice that would result in disciplinary action by a licensing board. (e.g., construction plans/administration; project planning; physical analysis).
3. Practice Boundaries: These areas were determined to include acceptable overlap as well as scope distinctions between the various design professions (e.g., building performance; environmental systems; fire protection)

Additional examination and discussion of the topic areas with practice boundaries are being explored by the sub-committees made up of dozens of expert volunteers who practice architecture, interior design, engineering, landscape architecture, and land surveying. Together these groups represent diverse perspectives across regions of the United States and Canada, practice domains, and small and large firms.

The Task Force will complete its analysis of these topic areas – with the ultimate goal of delineating acceptable overlap and recommended areas of scope distinction for in a ICOR guidance document intended to be adopted by reference in each the ICOR member organizations’ model laws and regulations. During 2024, the respective memberships of the ICOR organizations will have multiple opportunities to learn more about the Task Force’s approach and initial recommendations, as well as provide feedback on ICOR outreach efforts including presentations at each organization’s Annual Business Meeting, informational webinars, and regular updates on the ICOR website.

By 2025, ICOR hopes to finalize this work and submit official resolutions to each organization for approval that would update national/international models. Updating the model laws of each of the design profession’s regulatory associations would provide — for the very first time —  shared, consistent approach to an issue that has longed vexed design professionals and the regulatory community charged with ensuring public health, safety, and welfare, 

ICOR will continue to provide regular updates and seek feedback from licensing boards and external partners as this initiative progresses.

ABOUT ICOR

The Interorganizational Council on Regulation (ICOR) is made up of the Council of Interior Design Qualification (CIDQ), Council of Landscape Architectural Registration Boards (CLARB), National Council of Architectural Registration Boards (NCARB) and National Council of Examiners for Engineering and Surveying (NCEES). The organizations within ICOR collaborate on issues of shared interest including member board support, best practices in regulation and advocating on behalf of the public protection role our member licensing boards play. ICOR also works together to harmonize policies, processes, and procedures between professions to reduce friction and create administrative efficiencies for the many boards shared by the ICOR associations. ​