Testimony of Michael A. Clark, General Manager National Institute for Certification in Engineering Technologies (Division of the National Society of Professional Engineers) Alexandria, Virginia Before the Subcommittee on Benefits Committee on Veterans’ Affairs U.S. House of Representatives Veterans’ Employment: Credentialing (Licensure, Certification, Accreditation, and Apprenticeship) Requirements
Mr. Chairman and Distinguished
Committee Members, I wish to thank you for the opportunity
to speak before you today. As
a private citizen, I truly appreciate the leadership demonstrated by
Chairman Quinn, Ranking Minority Member Filner, and the other members
of this Subcommittee to solve a major problem facing our service men
and women as they transition from military careers to private careers
– the lack of good communication and understanding between
government and private industry about the training and testing
provided by the military and how it relates to private sector
professions, which then leads to unnecessary duplication of efforts
and a delay in getting our service men and women into good jobs as
they leave the military. I
also appreciate your sponsorship and support of conferences which will
allow government and private industry to come together as partners to
sort out possible solutions to this problem, work through several
pilot projects to see if the proposed solutions will work, and to
ultimately develop true consensus standards that can guide us into the
future for the benefit of all stakeholders. The National Institute for
Certification in Engineering Technologies (NICET) has been providing
testing and certification services for engineering technicians and
engineering technologists since 1961.
In that time, we have certified over 100,000 individuals in
more that 40 specialty areas of engineering technology, many of which
are identical for military and private sector personnel.
We operate with a full-time staff of 16 and an annual budget of
just over 2 million dollars, all of which is generated from the sale
of tests and the collection of recertification fees.
Most of our customers are employed by private industry, and
most of them are small businesses.
We do have contracts and/or agreements with several state
agencies to provide testing and certification services for their
personnel, but we do not currently have any contracts or grants from
the federal government. We
have worked with DANTES in the past to provide NICET examinations to
active-duty service men and women at military bases, but few military
personnel have taken advantage of this opportunity to-date, most
probably because we have not done an effective job of communicating
the advantages and benefits of NICET certification to the military. Throughout most of our history, NICET has promoted our certifications as a means for personal satisfaction, or as a marketing tool for career advancement or employment opportunities. Within the past ten years or more, however, we have witnessed an increased use of government regulation, either through legislation or through administrative rule making, to establish minimum competency requirements for persons performing a variety of jobs. Thus, NICET certification, like many other private sector certifications, is becoming a requirement to work. Most government regulations are prepared with honorable intentions. But as you know, there are no universal standards within the government for preparing this type of regulation, or for evaluating credentialing providers and their programs. Consequently, much of the regulation that we have seen to-date is either so vague that it allows almost anyone to qualify – thereby being worse than no regulation – or it is so specific that it eliminates any fair competition, and often unreasonably restricts the ability of the provider to offer better or more economical services. As an example, we all to frequently
encounter regulations that call for an individual to simply “possess
a NICET certification.” Which
NICET certification? And at what level of competency?
It would be infinitely better to have an individual who is
installing a fire alarm system possess a NICET certification in Fire
Alarm Systems at a Level III (with advanced knowledge of fire alarm
systems and at least 5 years of qualifying experience) than to get an
individual who possesses a Level I certification in Highway
Construction (an entry-level trainee inspector). At the other end of the spectrum, we also see regulations
that call for an “XYZ technician certified by ABC organization at
Grade II by use of written and performance examinations.”
Certainly this eliminates, or greatly reduces, fair competition
from other providers that may offer an equivalent or superior program
– often unintentionally – but it also restricts the ability of ABC
organization to offer new and better methods to assess candidate
knowledge and ability, such as computer simulation testing.
What we often find when we discuss these regulations with the
specifying agencies is that there is a genuine interest in providing
fair and reasonable requirements, but there is a true lack of
understanding about the various credentials available and about the
entire credentialing process. As a result of this inconsistency in
regulations, NICET has become active with several national and
international organizations over the past few years in an effort to
help establish minimum competency standards for the certification of
persons. I have
personally become active with the American Society of Testing and
Materials’ (ASTM) Committee on Conformity Assessment in chairing a
task group charged with developing an ASTM standard on this subject.
At the same time, I am serving as the representative of the
American National Standards Institute (ANSI) on a task group that is
preparing a similar standard for the Organization for International
Standardization’s (ISO) Conformity Assessment Council (CASCO).
I have gathered input on both of these efforts from my peers
through connections established by our membership in industry
organizations such as the National Organization for Competency
Assurance (NOCA) and the Council on Licensure, Examination and
Regulation (CLEAR). NICET has been a member of NOCA for many years because of the excellent education seminars and conferences that they offer throughout the year and the opportunities to network with our peers and other experts in our profession. However, until just last year, NOCA was not involved in any legislative or government activities. Therefore, when Mr. Steven Halsey formed the Coalition for Professional Certification (CPC) in early 1997, NICET became one of the founding members. We have developed the CPC to be a partner with government in the establishment of fair and reasonable standards for the certification of persons that everyone can accept. And although the CPC does not have a large membership base, we do have a fairly representative cross-section of the certification industry – from engineering technicians and technologists to crane operators, and from orthotists and prosthetists to lactation consultants. The CPC is also committed to the
establishment of minimum certification standards – but not the
“gold standards” being offered by NOCA and their accreditation
council, NCCA. And had we
been properly informed about NOCA’s legislative agenda over the past
year, we certainly would not have approved any push for adoption of
the NCCA standards as the federal standard. We are not opposed to
having a “gold standard” for our industry, and in fact, several of
the CPC members are NCCA-accredited and several others, including
NICET, are implementing expensive, and often painfully slow, process
changes just to achieve NCCA accreditation.
However, we understand that many reputable organizations with
good certification programs cannot afford to make some of the changes
necessary to achieve NCCA accreditation, nor can they afford to pay
the high annual fees to maintain NCCA accreditation.
Therefore another standard that identifies the essential,
minimum requirements for certifying persons needs to be established
within the federal government. CPC has established such a standard,
and with the support of this Subcommittee, this standard has been
adopted within the new GI Bill legislation.
We will be eternally grateful to this Subcommittee for their
efforts in getting this new legislation passed, as will be the
thousands of veterans who can now use these funds to help pay for the
private sector training and certification that they now need to work
in private industry. However,
I urge you to not stop here – we need to find ways for the military
to utilize private sector programs for active-duty personnel, and to
help transitioning personnel communicate their qualifications to
private industry such that efforts are not duplicated and monies are
not spent needlessly. Again, I wish to thank you for the opportunity to speak before you today. If you have any questions of me, I will be happy to respond to the best of my ability. And if I can be of further assistance to this Subcommittee in the future, I stand ready to help. Back to Witness List |