Item template OpenInEditor attribute.

I have an item template where I want OpenInEditor=true when the item is added explicitly by the user via the Add New Item dialog. But, I want OpenInEditor=false when the item is added programmatically via ProjectItems.AddFromTemplate.  The core issue is that our designers add files and we don't want the focus to change away from the designer when we programmatically add those project items.

Thanks in advance.

Kirk Fertitta