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This essay is written on behalf of a growing number of planning education providers who are being harmed by the American Institute of Certified Planners' Certification Maintenance (CM) program.
We consider the CM program to be predatory, confiscatory, unfair and inequitable. In this essay, we address each allegation. We offer an alternative that has proven to be non-predatory, non-confiscatory, fair, and equitable – and which facilitates the expansion of in-depth professional education opportunities.
We agree that planners should be current with planning knowledge. But the CM program undermines this goal. The CM program unfairly increases costs to non-AICP members, reduces the number of in-depth courses available for AICP members to take for credit, and leads to an overall dumbing-down of professional education opportunities for planners.
As background, the CM program was approved by the AICP Commission on April 13, 2007. Here's how it works.
The CM program was designed substantially without input from the very organizations that provide the largest share of high-quality, in-depth professional planning education courses nationally. What we have seen from APA/AICP is a pattern of behaviors indicating they have little apparent desire to engage constructively with those organizations.
Moreover, there is a clear conflict of interest because the people who are responsible for increasing the revenue of APA/AICP through the CM program are also making decisions about their "competitors." Many of those competitors are non-profit, university-based outreach education programs.
The CM program prices many in-depth courses and their providers out of existence in favor of APA/AICP's own courses and, especially, short conference sessions. Since conferences are a major source of revenue for APA the effect of this scheme is predatory.
Here's the problem. Most planning education providers are self-supporting and operate literally hand-to-mouth from course revenues. Because planners are not as wealthy as lawyers or doctors, we have to keep our costs down which makes our margins thin. We rely on net revenue to pay some bills and develop new courses.
While the $50 per credit fee is negligible when applied to a short APA conference session attracting hundreds, it is significant when applied to a 2-day, 14-hour in-depth course. That cost would be $700 and is onerous especially when enrollments are capped (to assure quality) and where most participants are mostly not AICP members anyway. We can't raise fees to cover CM costs because they are already as high as planners, citizens, and nonprofits can afford. We can't cut costs to pay the fees because that would reduce quality.
Technically, we can choose not to certify courses. Practically, we have no choice. A growing number of organizations will send their staff, including non-AICP members, only to CM-approved programs. This is a recipe for predation.
For instance, the Planning Academy at Virginia Tech is canceling many of its planning education courses because it cannot afford to pay the CM fees, but without CM approval some organizations won't support staff to attend them. The Planning Academy may shut down as a consequence. This is a predatory outcome of the CM program.
Who benefits by shutting down providers? APA/AICP. Attendance at national and state conferences will surely increase because AICP members can log the CM credits they need by sitting in on conference sessions. Those sessions tend to be passive listening sessions, not the high-quality, in-depth professional education experiences one would expect the CM program to encourage.
Bottom line: If a pricing scheme by a regulator curtails or even shuts down competitors with the result that its own operations are expanded common sense would suggest that predation occurs.
The CM program confiscates net revenues of providers. Consider the following examples.
Rutgers' Bloustein Online Continuing Education Program and The Leading Institute calculates it would have to pay roughly $28,000 annually to have all of its courses certified by APA/AICP. The fee to certify one class -- $700 -- represents around 27% of the operating costs of a typical BOCEP class. Clearly, the CM program will reduce many of Rutgers' offerings and could threaten its survival.
The Planning Academy at Virginia Tech runs short courses with capped enrollments that operate on tight margins. The CM fees, however, absorb about one- to two-thirds of the net revenue of courses and actually increase the odds that courses will lose money.
To reach planners, commissioners and citizens, Ohio State offers its courses for a price as low possible. Yet, for its continuing education program in planning and its certificate program, CM fees would run $14,000 annually, a figure equal to its entire net revenue from last year.
Planetizen estimated that it would cost $9,600 a year if all of its online courses were in the CM program. (That's almost three times as much as the American Institute of Architects would charge.)
In effect, APA/AICP pockets much of the hard-earned net revenue generated by university educational outreach providers who incur all the costs to create and deliver courses and take all the financial risks. As a "tax" that can approach (or exceed) 100% of the net revenue, CM fees are nothing less than confiscatory.
The CM program is unfair in how it operates. For one thing, its staff not only approves our courses but their own as well. This raises the appearance of -- and perhaps the temptation for -- conflict of interest.
The CM program may also "churn" fees, which is an unfair practice. For example, the Michigan chapter of the APA created a CM-approved 5-hour DVD of conference sessions to assist members in distant parts of the state. Although they paid CM fees to certify the DVD content initially, they have learned they must pay another $1,000 annually to make the DVDs available four times a year. This is called churning as it costs APA/AICP nothing to reapprove the same material.
We have been told by an APA official that because of staff, legal, overhead and other costs, it is possible that the CM program could lose money. If so, APA/AICP has two solutions: raise CM fees even more or use dues and other own-source revenue to cover losses. Both give APA/AICP an unfair advantage over providers.
The first solution is unfair because providers can't afford the current pricing scheme anyway. APA/AICP points out that it pays the same fees to its CM program as we do, but this is like a landlord paying herself rent on the house she owns. In fact, APA/AICP has every incentive to inflate financial losses and cover them through higher CM fees; doing so further cements APA/AICP's predation of the professional planning education market unfairly.
In the second respect, unlike APA/AICP, self-sufficient providers like us have no alternative sources of revenue to cover losses. APA/AICP has an unfair resource advantage.
The CM program is unfairly hard on planning schools that want to offer graduate courses for CM credit. Ohio State learned, for example, that the fee for a 3-credit hour graduate course would be $2,250 ($50 per hour times 45 contact hours) which is unworkable. Despite months of delay waiting for resolution from APA/AICP, Ohio State has received none. In the meantime, universities are not offering graduate courses for CM credit. This is unfair to those planners who seek graduate credit to help meet CM requirements.
Finally, the pricing scheme is unfair when considering APA/AICP's likely costs. It does not take much more time to process a 2-credit conference session than it takes to process an in-depth 14-credit course. The 2-credit conference session costs $100 in CM fees but the in-depth 14-credit course costs $700. So, the in-depth course heavily subsidizes the conference session.
AICP officials argue that the CM program will increase registration and the new revenue will cover higher costs. But they won't guarantee this. More problematic is that this reasoning does not work for courses that are capped to assure quality. It also does not work for courses that are offered for free or for registration fees set to cover just costs such as printing and catering -- unless of course we increase registration fees to cover CM costs which means everyone pays for AICP members' benefit unfairly.
We worry lastly about the equity implications of the CM scheme. After all, while the costs are incurred by everyone the benefits are enjoyed only by AICP members.
Consider that the CM program may violate the spirit if not the letter of AICP's own Code of Ethics:
1. f) We shall seek social justice by working to expand choice and opportunity for all persons, recognizing a special responsibility to plan for the needs of the disadvantaged and to promote racial and economic integration.
Consider also that AICP members average $5,000+ more income than non-AICP members, according to APA. So, while the CM program helps AICP members earn more money, the cost of their income benefits are borne by lower-earning non-AICP members. And we're supposed to be a profession advancing equity?
In review, the current CM program will:
A Proven Alternative
For years, the American Institute of Architects (AIA) has run a model continuing education program. It charges annual fees ranging from $650 to professional nonprofit organizations – such as university outreach programs like ours -- to $3,300 for private-sector providers, such as Planetizen.
Let's do the math for university outreach providers. For 200 credits offered annually, APA/AICP would charge $10,000 a year. AIA would charge only $650.
AIA's approach stimulates the provision of literally thousands of high-quality, in-depth professional education resources for its members. In contrast, the CM pricing scheme stifles planning education. Providers are already reducing the number of high-quality, in-depth courses. Some are shutting down their planning education operations and more are sure to follow.
The providers of professional continuing education support the goals of Certification Maintenance; we just want a program that is non-predatory, non-confiscatory, fair, and equitable. We propose that the AICP Commission adopt the following policies.
Arthur C. Nelson Ph.D., FAICP
Director, Metropolitan Institute
Editor, /Housing Policy Debate
Professor of Urban Affairs and Planning
Virginia Polytechnic Institute and State University
Leonardo Vázquez, M.Pl, M.P.A., AICP, PP
Director, Professional Development Institute
Edward J. Bloustein School of Planning and Public Policy
Jennifer Evans-Cowley, PhD, AICP
Associate Professor and Planning Education at a Distance Program Director
City and Regional Planning
Austin E. Knowlton School of Architecture
The Ohio State University
Graham Billingsley, President of AICP, and Monica Groh, Manager of Professional Development and AICP for the American Planning Association, have issued formal responses to this op-ed. Read AICP Responses to 'AICP's Continuing Education Program Needs To Be Fixed'.