Comment #1Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: 2Comment Intent: Not an ObjectionComment Type: EditorialComment: Section 904.4.2.4 – Quality assurance reviews of providers by RESNET staff in 2013 found that only requiring the Quality Assurance Designee only have to conduct field reviews on raters is too long. The sentence needs to be corrected. It does not make sense.
Section 904.4.2.4 – Quality assurance reviews of providers by RESNET staff in 2013 found that only requiring the Quality Assurance Designee only have to conduct field reviews on raters is too long.
The sentence needs to be corrected. It does not make sense.
Comment #2Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: 904.4.2.4Comment Intent: ObjectionComment Type: GeneralComment: Increasing the field review requirement to quarterly will only increase the costs to the rater and subsequently to the customer without any evidence that the quality of the rating process will be improved. The proposed change to quarterly field reviews only serve to penalize low volume energy auditors by increasing field audit rates (and costs) to a rate significantly higher than 1% currently required. I currently pay travel and expenses in addition to a per house fee for my field reviews. Scheduling field reviews throughout the course of a year is inefficient and costly. My field reviewer travels 60 miles (on average one way). Scheduling the audits for a single day maximizes his and my time away from the business of rating homes. This helps control costs and reduces unneccessary travel for both the field reviewer and the energy rater. The problem with meeting the current annual review period is that it is done in real time, the year the ratings take place. A rater doing 99 homes a year would be required to increase the number of field reviewed projects from 1 annually to 4 quarterly. Their review rate would increase 400% as would their costs. This is an unreasonable and unneeded burden. Last year I waited until late in the year because I didn't knw if I would cross into the 200+ ratings and I didn't want to rate 3 homes if I only needed to rate 2 since you no longer allow carry over to the following year. A practical way to eliminate a log jam at the end of the year would be to complete the required number of field audits the year after the total number has been established. So a rater completing 201 energy audits in 2013 would be required to complete 3 field reviews in calendar year 2014. If change is needed practical, cost-effective change should be enacted. Trying to maintain "real time" reviews in a given calendar year is the real problem. Consider teh nergy savings and sustainability in changing the field review process to be completed the year after. The 1% goal integrity is still maintained, the time crunch is eliminated and the cost to the rater and the industry does not increase. Proposed Change: 904.4.2.4 Each QA Provider shall conduct onsite QA field reviews throughout the year at a rate based on shall be conducted on an ongoing basis as appropriate the volume of ratings being certified by the Provider in the previous year. The Provider shall conduct onsite field reviews no less frequently than quarterly. Each year the Provider shall complete a minimum of 1% onsite field reviews based on the number of ratings certified the previous quarter. For example , if a Provider certified 201 ratings in a given quarter the previous calendar year, that Provider shall perform no fewer than 3 onsite field reviews the following quarter year.
Increasing the field review requirement to quarterly will only increase the costs to the rater and subsequently to the customer without any evidence that the quality of the rating process will be improved. The proposed change to quarterly field reviews only serve to penalize low volume energy auditors by increasing field audit rates (and costs) to a rate significantly higher than 1% currently required.
I currently pay travel and expenses in addition to a per house fee for my field reviews. Scheduling field reviews throughout the course of a year is inefficient and costly. My field reviewer travels 60 miles (on average one way). Scheduling the audits for a single day maximizes his and my time away from the business of rating homes. This helps control costs and reduces unneccessary travel for both the field reviewer and the energy rater.
The problem with meeting the current annual review period is that it is done in real time, the year the ratings take place. A rater doing 99 homes a year would be required to increase the number of field reviewed projects from 1 annually to 4 quarterly. Their review rate would increase 400% as would their costs. This is an unreasonable and unneeded burden.
Last year I waited until late in the year because I didn't knw if I would cross into the 200+ ratings and I didn't want to rate 3 homes if I only needed to rate 2 since you no longer allow carry over to the following year.
A practical way to eliminate a log jam at the end of the year would be to complete the required number of field audits the year after the total number has been established. So a rater completing 201 energy audits in 2013 would be required to complete 3 field reviews in calendar year 2014.
If change is needed practical, cost-effective change should be enacted. Trying to maintain "real time" reviews in a given calendar year is the real problem. Consider teh nergy savings and sustainability in changing the field review process to be completed the year after. The 1% goal integrity is still maintained, the time crunch is eliminated and the cost to the rater and the industry does not increase.
904.4.2.4 Each QA Provider shall conduct onsite QA field reviews throughout the year at a rate based on shall be conducted on an ongoing basis as appropriate the volume of ratings being certified by the Provider in the previous year. The Provider shall conduct onsite field reviews no less frequently than quarterly. Each year the Provider shall complete a minimum of 1% onsite field reviews based on the number of ratings certified the previous quarter. For example , if a Provider certified 201 ratings in a given quarter the previous calendar year, that Provider shall perform no fewer than 3 onsite field reviews the following quarter year.
Comment #3Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: 1Paragraph / Figure / Table / Note: 904.4.2.4Comment Intent: ObjectionComment Type: GeneralComment: While we understand the desire of RESNET to provide guidance to Providers and QADs, the timing and planning of field reviews is a matter of good business practice, and should be left up to the Provider to manage. There is no current requirement to wait until the end of the year. This proposed amendment not only changes the timing of onsite field review, but it also changes the number of required field reviews, which is beyond the scope of the stated Justification. There is a very large difference between 1% annual and 1% quarterly review for low-volume raters, especially those who certify less than 100 ratings per year (1 versus 4 required field reviews). The additional cost to these raters is not included in the current contracts between Providers and Raters, nor is it included in contracts between Raters and builders. This will present a significant barrier to entry for new Raters. If the intent is to change the RESNET Standard to require 1% quarterly field review, that should be stated explicitly and should be justified. Proposed Change: 904.4.2.4 Each QA Provider shall conduct onsite QA field reviews throughout the year at a rate based on shall be conducted on an ongoing basis as appropriate the volume of ratings being certified by the Provider. The Provider shall conduct onsite field reviews no less frequently than during each calendar year at a rate of no less than 1% of total ratings certified during that calendar year, including all ratings within sample sets. RESNET encourages Providers to conduct field reviews throughout the year, at regular intervals, in order to maintain a steady work flow and to identify and correct any quality issues. quarterly. Each quarter the Provider shall complete a minimum of 1% onsite field reviews based on the number of ratings certified the previous quarter. For example, if a Provider certified 201 ratings in a given quarter, that Provider shall perform no fewer than 3 onsite field reviews the following quarter. Completed, and at a minimum annually.
While we understand the desire of RESNET to provide guidance to Providers and QADs, the timing and planning of field reviews is a matter of good business practice, and should be left up to the Provider to manage. There is no current requirement to wait until the end of the year. This proposed amendment not only changes the timing of onsite field review, but it also changes the number of required field reviews, which is beyond the scope of the stated Justification. There is a very large difference between 1% annual and 1% quarterly review for low-volume raters, especially those who certify less than 100 ratings per year (1 versus 4 required field reviews). The additional cost to these raters is not included in the current contracts between Providers and Raters, nor is it included in contracts between Raters and builders. This will present a significant barrier to entry for new Raters.
If the intent is to change the RESNET Standard to require 1% quarterly field review, that should be stated explicitly and should be justified.
904.4.2.4 Each QA Provider shall conduct onsite QA field reviews throughout the year at
a rate based on shall be conducted on an ongoing basis as appropriate the volume of ratings being certified by the Provider. The Provider shall conduct onsite field reviews no less frequently than during each calendar year at a rate of no less than 1% of total ratings certified during that calendar year, including all ratings within sample sets. RESNET encourages Providers to conduct field reviews throughout the year, at regular intervals, in order to maintain a steady work flow and to identify and correct any quality issues. quarterly. Each quarter the Provider shall complete a minimum of 1% onsite field reviews based on the number of ratings certified the previous quarter. For example, if a Provider certified 201 ratings in a given quarter, that Provider shall perform no fewer than 3 onsite field reviews the following quarter. Completed, and at a minimum annually.
Comment #4Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: Chapter 9Paragraph / Figure / Table / Note: 904.4.2.4Comment Intent: Not an ObjectionComment Type: GeneralComment: Section 904.4.2.4 I am 100% for more QA involvement. The trouble we run in to, is affording the trip to no where South Dakota. In the past years we lost two more raters that where on the midwest loop to share expenses with. If quarterly would be necessary we will need to raise the budget to $8,000 from current of $2,000. The need for quarterly could be set up though; 1) using a generic testing home in the town where the national meeting is going for raters over 300 miles from provider. (First Quarter) 2) we are lucky enough to use Energy Logic which has a yearly meeting/ training, this could also be used as a generic testing home. (good for another quarter). 3) using technology, being able to skype, google + or facetime to remotely go though a home/unit with rater. The rater would be responsible to be at location of QA project and walk QA Designee around location using camera device live.
Section 904.4.2.4
I am 100% for more QA involvement.
The trouble we run in to, is affording the trip to no where South Dakota. In the past years we lost two more raters that where on the midwest loop to share expenses with. If quarterly would be necessary we will need to raise the budget to $8,000 from current of $2,000. The need for quarterly could be set up though;
1) using a generic testing home in the town where the national meeting is going for raters over 300 miles from provider. (First Quarter)
2) we are lucky enough to use Energy Logic which has a yearly meeting/ training, this could also be used as a generic testing home. (good for another quarter).
3) using technology, being able to skype, google + or facetime to remotely go though a home/unit with rater. The rater would be responsible to be at location of QA project and walk QA Designee around location using camera device live.
Comment #5Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: 2Paragraph / Figure / Table / Note: 904.4.2.4Comment Intent: ObjectionComment Type: TechnicalComment: As many have already noted, the proposed change to quarterly field reviews would put an undue burden on low volume raters. In addition, when we are talking about low volume rater in remote areas such as Hawaii, which has NO PROVIDERS in the State, the travel costs multiply exponentially. With so few raters out here to even share costs with (already a potential conflict due to competing raters for limited business), it is already difficult enough to meet the current annual requirement. Clarity is therefore needed for extremely low volume raters. If we only conduct 1 rating each quarter, then do we need 1 field review the following quarter? If that scenario follows for each quarter, and no further work ensues, then we will have conducted 100% field QA for the year. In other words, by requiring quarterly field reviews, RESNET is effectively raising the minimum of 1% field QA all the way up to 100% field reviews for anyone conducting just 4 ratings per year. As it now stands, if I conduct 4 ratings in a year, then one field QA is required. Finally, with the recent developments in remote video technology, it seems that RESNET should be looking into utilizing such tools for field QA. I propose coming up with a way to comply with the “on-site” portion of the QA reviews using remote video technology. While it would certainly require some time to develop the rules and regulations governing the process, I believe the broader goal of “efficiency” is ultimately strengthened by virtually eliminating the carbon footprint incurred by all those extra flights and road trips for field QA. Proposed Change: 904.4.2.4 Each QA Provider shall conduct onsite QA field reviews throughout the year at a rate based on shall be conducted on an ongoing basis as appropriate the volume of ratings being certified by the Provider. The Provider shall conduct onsite field reviews no less frequently than quarterly Each quarter the Provider shall complete a minimum of 1% onsite field reviews based on the number of ratings certified the previous quarter. For example, if a Provider certified 201 ratings in a given quarter, that Provider shall perform no fewer than 3 onsite field reviews the following quarter. Completed, and at a minimum annually. Low volume rater exception: Any rater whose annual volume is less than 100 ratings, shall be required to have at least one field review conducted by their provider during the year.
As many have already noted, the proposed change to quarterly field reviews would put an undue burden on low volume raters. In addition, when we are talking about low volume rater in remote areas such as Hawaii, which has NO PROVIDERS in the State, the travel costs multiply exponentially. With so few raters out here to even share costs with (already a potential conflict due to competing raters for limited business), it is already difficult enough to meet the current annual requirement.
Clarity is therefore needed for extremely low volume raters. If we only conduct 1 rating each quarter, then do we need 1 field review the following quarter? If that scenario follows for each quarter, and no further work ensues, then we will have conducted 100% field QA for the year. In other words, by requiring quarterly field reviews, RESNET is effectively raising the minimum of 1% field QA all the way up to 100% field reviews for anyone conducting just 4 ratings per year. As it now stands, if I conduct 4 ratings in a year, then one field QA is required.
Finally, with the recent developments in remote video technology, it seems that RESNET should be looking into utilizing such tools for field QA. I propose coming up with a way to comply with the “on-site” portion of the QA reviews using remote video technology. While it would certainly require some time to develop the rules and regulations governing the process, I believe the broader goal of “efficiency” is ultimately strengthened by virtually eliminating the carbon footprint incurred by all those extra flights and road trips for field QA.
904.4.2.4 Each QA Provider shall conduct onsite QA field reviews throughout the year at a rate based on shall be conducted on an ongoing basis as appropriate the volume of ratings being certified by the Provider. The Provider shall conduct onsite field reviews no less frequently than quarterly Each quarter the Provider shall complete a minimum of 1% onsite field reviews based on the number of ratings certified the previous quarter. For example, if a Provider certified 201 ratings in a given quarter, that Provider shall perform no fewer than 3 onsite field reviews the following quarter. Completed, and at a minimum annually.
Low volume rater exception: Any rater whose annual volume is less than 100 ratings, shall be required to have at least one field review conducted by their provider during the year.
Comment #6Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: 1Paragraph / Figure / Table / Note: 904.4.2.4Comment Intent: ObjectionComment Type: GeneralComment: Requiring field reviews to be conducted on a quaterly basis has the potential to significantly raise the cost of of RESNET compliance for raters. My QAD is not locally based and charges for travel as part of their QA process. By conducting annual field reviews, they can get everything accomplished in just one trip. If they have to complete a quarterly review, you are potentially quadrupling the cost of this process. This seems like an unfair administrative burden that will not produce any real benefits in the quality of the rating process. Perhaps it would be more productive to place Providers who fail to meet the deadlines for their annual review process on probation. During their probationary period they would be required to conduct quartely reviews. This will meet your goal of orderly compliance with field reviews and will punish bad actors without the unintended effect of raising the cost of compliance for everyone. This would also alert raters to the fact that their Provider is not meeting RESNET standards and would allow raters to potential choose a Provider that is in good standing. Thank you for your consideration. Proposed Change: 904.4.2.4 Each QA Provider shall conduct onsite QA field reviews throughout the year at a rate based on shall be conducted on an ongoing basis as appropriate the volume of ratings being certified by the Provider. The Provider shall conduct onsite field reviews no less frequently than quarterly. Each quarter the Provider shall complete a minimum of 1% onsite field reviews based on the number of ratings certified the previous quarter. For example, if a Provider certified 201 ratings in a given quarter, that Provider shall perform no fewer than 3 onsite field reviews the following quarter. Completed, and at a minimum annually.
Requiring field reviews to be conducted on a quaterly basis has the potential to significantly raise the cost of of RESNET compliance for raters. My QAD is not locally based and charges for travel as part of their QA process. By conducting annual field reviews, they can get everything accomplished in just one trip. If they have to complete a quarterly review, you are potentially quadrupling the cost of this process. This seems like an unfair administrative burden that will not produce any real benefits in the quality of the rating process.
Perhaps it would be more productive to place Providers who fail to meet the deadlines for their annual review process on probation. During their probationary period they would be required to conduct quartely reviews. This will meet your goal of orderly compliance with field reviews and will punish bad actors without the unintended effect of raising the cost of compliance for everyone. This would also alert raters to the fact that their Provider is not meeting RESNET standards and would allow raters to potential choose a Provider that is in good standing.
Thank you for your consideration.
904.4.2.4 Each QA Provider shall conduct onsite QA field reviews throughout the year at a rate based on shall be conducted on an ongoing basis as appropriate the volume of ratings being certified by the Provider. The Provider shall conduct onsite field reviews no less frequently than quarterly. Each quarter the Provider shall complete a minimum of 1% onsite field reviews based on the number of ratings certified the previous quarter. For example, if a Provider certified 201 ratings in a given quarter, that Provider shall perform no fewer than 3 onsite field reviews the following quarter. Completed, and at a minimum annually.
Comment #7Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: 9-4Paragraph / Figure / Table / Note: Section 904.4.2.4Comment Intent: ObjectionComment Type: EditorialComment: Our view is that Quarterly should be optional, Yearly is required. Quarterly will impose excessive Travel Charges to Remote Raters, intruding on their business profits, and there their efforts to promote the RESNET HERS Index and EEP Programs. RATERusa Your notice showed Section 904.4.2.4 Our view is that this discussion pertains to Section 904.4.2.3 Proposed Change: Our view is that Quarterly should be optional, Yearly is required. Quarterly will impose excessive Travel Charges to Remote Raters, intruding on their business profits, and there their efforts to promote the RESNET HERS Index and EEP Programs. RATERusa Your notice showed Section 904.4.2.4 Our view is that this discussion pertains to Section 904.4.2.3
Our view is that Quarterly should be optional, Yearly is required.
Quarterly will impose excessive Travel Charges to Remote Raters, intruding on their business profits, and there their efforts to promote the RESNET HERS Index and EEP Programs.
RATERusa
Your notice showed Section 904.4.2.4
Our view is that this discussion pertains to Section 904.4.2.3
Comment #8Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: 1Paragraph / Figure / Table / Note: 904.4.2.4Comment Intent: ObjectionComment Type: TechnicalComment: Provider shall conduct onsite field reviews no less frequently than quarterly. I believe this should be "twice a year". Each quarter.... Should be "every 6 months"... Justification.... Low and mid volume raters will be faced with significant costs for QA if having to do each quarter. Also 904.4.2.4 states 1% onsite field reviews ..based..on the previous quarter. F First this should be based on a cumulative basis for the year-not based on last quarters quantity of ratings. Example- rater does 5 ratings first quarter-1 onsite QA done. Then he does 4 more the next quarter-another 1 onsite QA visit. If this were cumulative then the one for the first quarter (I propose every 6 months) should count for the second month (less than 10 ratings....) The standards would be overly burdensome on the low to mid volume rater. Proposed Change: 904.4.2.4 Each QA Provider shall conduct onsite field reviews throughout the year at a rate based on the volume of ratings being certified by the Provider. The Provider shall conduct onsite field reviews no less frequently than quarterly (insert -twice a year). Each quarter (insert- 6 months) the Provider shall complete a minimum of 1% (insert-cumulative) onsite field reviews based on the number of ratings certified the previous quarter (insert cumulative amount starting with Jan. 1). For example, if a Provider certified 201 ratings in a given quarter (insert- 6 months) that Provider shall perform no fewer than 3 onsite field reviews the following quarter (insert 6 months). Insert- The QAD shall have the option of performing a full years worth of QA on one visit if it can be achieved-up to a max of 5 onsite QA.
Provider shall conduct onsite field reviews no less frequently than quarterly.
I believe this should be "twice a year".
Each quarter....
Should be "every 6 months"...
Justification....
Low and mid volume raters will be faced with significant costs for QA if having to do each quarter. Also 904.4.2.4 states 1% onsite field reviews ..based..on the previous quarter. F
First this should be based on a cumulative basis for the year-not based on last quarters quantity of ratings. Example- rater does 5 ratings first quarter-1 onsite QA done. Then he does 4 more the next quarter-another 1 onsite QA visit. If this were cumulative then the one for the first quarter (I propose every 6 months) should count for the second month (less than 10 ratings....) The standards would be overly burdensome on the low to mid volume rater.
904.4.2.4 Each QA Provider shall conduct onsite field reviews throughout the year at a rate based on the volume of ratings being certified by the Provider. The Provider shall conduct onsite field reviews no less frequently than quarterly (insert -twice a year). Each quarter (insert- 6 months) the Provider shall complete a minimum of 1% (insert-cumulative) onsite field reviews based on the number of ratings certified the previous quarter (insert cumulative amount starting with Jan. 1). For example, if a Provider certified 201 ratings in a given quarter (insert- 6 months) that Provider shall perform no fewer than 3 onsite field reviews the following quarter (insert 6 months).
Insert- The QAD shall have the option of performing a full years worth of QA on one visit if it can be achieved-up to a max of 5 onsite QA.
Comment #9Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: 2Paragraph / Figure / Table / Note: 904.5.2.2Comment Intent: ObjectionComment Type: TechnicalComment: within 5 business days is too quick-be realistic. replace with 30 business days. Proposed Change: 904.5.2.2. within 5 30 business days.....
within 5 business days is too quick-be realistic.
replace with 30 business days.
904.5.2.2.
within 5 30 business days.....
Comment #10Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: 3Paragraph / Figure / Table / Note: 912.2.1.2.6Comment Intent: ObjectionComment Type: EditorialComment: A QA Provider that attempts to schedule QA but does not have the raters cooperation will not be found to be at fault. The Provider will elect to place the rater on probation or suspension and therefore not be accountable for the lack of QA on a rater. Proposed Change: 912.2.1.2.6 Willful failure Purposefully disregarding the requirement to complete field or file QA.
A QA Provider that attempts to schedule QA but does not have the raters cooperation will not be found to be at fault. The Provider will elect to place the rater on probation or suspension and therefore not be accountable for the lack of QA on a rater.
912.2.1.2.6 Willful failure Purposefully disregarding the requirement to complete field or file QA.
Comment #11Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: 1Comment Intent: Not an ObjectionComment Type: EditorialComment: Documented for Clarification. The proposal to amend 904.4.2.4 is really referencing 904.4.2.3. The proposal to amend 904.4.2.9 is really referencing 904.4.2.8. The proposal referencing 904.5.2.2 is referencing the second 904.5.2.2 in the standards (the first 904.5.2.2 should really be numbered 904.5.1.2). Proposed Change: 904.4.2.43 904.4.2.98
Documented for Clarification.
The proposal to amend 904.4.2.4 is really referencing 904.4.2.3. The proposal to amend 904.4.2.9 is really referencing 904.4.2.8. The proposal referencing 904.5.2.2 is referencing the second 904.5.2.2 in the standards (the first 904.5.2.2 should really be numbered 904.5.1.2).
904.4.2.43
904.4.2.98
Comment #12Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: 1Comment Intent: ObjectionComment Type: GeneralComment: The extremely burdensome issues this proposal for required quarterly field review places on independent and low-volume raters has been very well written by others in this forum, so I will not reiterate, however, I do want to state that I agree with those comments. The need for this requirement was documented with, "Too many providers find themselves in trouble when they wait until the end of the year to conduct their reviews." This is an issue best dealt with on a one-on-one basis with the offending parties rather than a wholesale change to standards. Work directly and constructively with the Providers who are finding themselves in trouble. Perhaps they need some guidance and training? There are valid reasons to wait to perform the field review. We all know that a minimum of one field review is going to be required, so it makes sense to get started as early as possible. However, this may not be feasible when the rater is remote. The QAD may wish to wait until closer to the end of the year to understand exactly how many ratings the rater is going to complete and therefore how many field reviews must be conducted. If there are several remote raters in the same general area, the QAD may wish to wait until closer to the end of the year to group field reviews for the area so the costs can be split up between the raters involved, saving them some money. Sometimes it is just not possible to get back in the property that was rated to perform the field review and the choice then is to either wait for the next property or go to jail for breaking and entering. Sometimes the rater does not have the funds available to pay for a field review. The Provider's policies and procedures should include details regarding how the lack of field review will impact the rater and would then be covered under 904.5.1.3 for the Provider and QAD if they do not follow their own procedures. Field reviews are extremely important, but they are also both a time, cost and logistics burden and need to be managed at the Provider level, not by a wholesale change to standards resulting in unintended consequences. I am also suggesting that if you want to clarify the rate for field review, you need a more clear clarification, see below. Thank you for your consideration. Sharla Riead, QAD, Accurate Rater Network Proposed Change: Retain 904.4.2.3 (in the amendment as 904.4.2.4) as it is currently written. 904.4.2.98 If a QA Designee is required to complete onsite field reviews QA inspections on at least two (2) homes for a given Rater (i.e. the Rater performed more than 100 ratings within the calendar year) , the QA Designee may use one centralized – proctored rating QA event, and only one, for review of the Rater in lieu of an independent confirmation of the rating for the home as required for the balance of homes evaluated for the onsite inspection process.
The extremely burdensome issues this proposal for required quarterly field review places on independent and low-volume raters has been very well written by others in this forum, so I will not reiterate, however, I do want to state that I agree with those comments.
The need for this requirement was documented with, "Too many providers find themselves in trouble when they wait until the end of the year to conduct their reviews." This is an issue best dealt with on a one-on-one basis with the offending parties rather than a wholesale change to standards. Work directly and constructively with the Providers who are finding themselves in trouble. Perhaps they need some guidance and training?
There are valid reasons to wait to perform the field review. We all know that a minimum of one field review is going to be required, so it makes sense to get started as early as possible. However, this may not be feasible when the rater is remote. The QAD may wish to wait until closer to the end of the year to understand exactly how many ratings the rater is going to complete and therefore how many field reviews must be conducted. If there are several remote raters in the same general area, the QAD may wish to wait until closer to the end of the year to group field reviews for the area so the costs can be split up between the raters involved, saving them some money. Sometimes it is just not possible to get back in the property that was rated to perform the field review and the choice then is to either wait for the next property or go to jail for breaking and entering. Sometimes the rater does not have the funds available to pay for a field review. The Provider's policies and procedures should include details regarding how the lack of field review will impact the rater and would then be covered under 904.5.1.3 for the Provider and QAD if they do not follow their own procedures. Field reviews are extremely important, but they are also both a time, cost and logistics burden and need to be managed at the Provider level, not by a wholesale change to standards resulting in unintended consequences.
I am also suggesting that if you want to clarify the rate for field review, you need a more clear clarification, see below.
Sharla Riead, QAD, Accurate Rater Network
Retain 904.4.2.3 (in the amendment as 904.4.2.4) as it is currently written.
904.4.2.98 If a QA Designee is required to complete onsite field reviews QA inspections on at least two (2) homes for a given Rater (i.e. the Rater performed more than 100 ratings within the calendar year) , the QA Designee may use one centralized – proctored rating QA event, and only one, for review of the Rater in lieu of an independent confirmation of the rating for the home as required for the balance of homes evaluated for the onsite inspection process.
Comment #13Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: 904.4.2.4Comment Intent: ObjectionComment Type: GeneralComment: I don't believe that any requirement to require quarterly field monitoring is unnecessary and begins to make quality assurance difficult and frustrating. The line must be drawn somewhere so that the standards don't go far beyond the original intent of meeting the 1% annual review. Whether I complete it at the beginning of the year or end of the year is irrelevant if I am performing my due diligence. Currently, I can take care of some local field QA during the first part of the year, hit long-distance raters during the late-spring, summer, early fall, and then tie up the loose ends during the late fall. This has worked adequately in completing review on 100% of our raters for some consecutive years now and the field would become so complicated that many providers / QADs would find it easier just to go back to being raters and allowing some other entity to be under the gun for probation due to the no-exceptions policy that RESNET has with Quality Assurance review of providers. Proposed Change: My recommendation is to make no change to the existing requirement of annual field monitoring at the minimum rate of 1% and continue the current policy of quarterly file reviews.
I don't believe that any requirement to require quarterly field monitoring is unnecessary and begins to make quality assurance difficult and frustrating.
The line must be drawn somewhere so that the standards don't go far beyond the original intent of meeting the 1% annual review.
Whether I complete it at the beginning of the year or end of the year is irrelevant if I am performing my due diligence.
Currently, I can take care of some local field QA during the first part of the year, hit long-distance raters during the late-spring, summer, early fall, and then tie up the loose ends during the late fall.
This has worked adequately in completing review on 100% of our raters for some consecutive years now and the field would become so complicated that many providers / QADs would find it easier just to go back to being raters and allowing some other entity to be under the gun for probation due to the no-exceptions policy that RESNET has with Quality Assurance review of providers.
My recommendation is to make no change to the existing requirement of annual field monitoring at the minimum rate of 1% and continue the current policy of quarterly file reviews.
Comment #14Amendment: Proposed Amendment of Chapter 9 to Revise Certain QA RequirementsPage Number: 1Paragraph / Figure / Table / Note: 904.4.2.4Comment Intent: ObjectionComment Type: GeneralComment: Section 904.4.2.4 “Each quarter the Provider shall complete a minimum of 1% onsite field reviews based on the numbers of ratings certified the previous quarter” This sentence needs clarified, since this could be interpreted to mean either total quarterly ratings a) per rater or b) total ratings for all raters. This is confusing, because we usually interpret “1% QA” to be per rater. If option a), this will more than double the amount of 1% QA required; increasing the amount of 1% QA required does not meet the intention of this proposed amendment. Therefore, we object the proposed amendment. If option b), this requirement will not be an effective solution for reasons below. Therefore, we object the proposed amendment. Here is an example using our single family numbers from 2013, using 3 different scenarios: 1) AS IS 1%: 28 QA trips total required for 2013 2) If 1%/rater/quarter: 65 QA trips total for 2013 3) If 1%/total ratings/quarter: 5 QA trips, there are still 23 QA trips left to do at the end of the year Additionally, while we agree it is not best pracitce to wait until the end of the year to complete annual field QA requirements, RESNET should not be creating business management requirements for Providers for the reasons below: There is currently no method of enforcing this requirement. Providers are not currently required have a quarterly tracking system and there is no consistent method of reporting QA results to RESNET. The most helpful improvement to the QA management system would be to provide an annual QA reporting template, QA results report template, etc. before any other changes to the standards are made. This would improve the efficiency and effectiveness of the field QA process for Providers, QAD's, Raters, and RESNET. Proposed Effective Date: If the intent of this change is to increase the amount of annual field QA, then the effective date would need to allow enough time for providers, QAD's, and raters to accommodate this change (more than 30 days). This change would need to take effect at the beginning of the calendar year, at the earliest.
Section 904.4.2.4 “Each quarter the Provider shall complete a minimum of 1% onsite field reviews based on the numbers of ratings certified the previous quarter”
This sentence needs clarified, since this could be interpreted to mean either total quarterly ratings a) per rater or b) total ratings for all raters. This is confusing, because we usually interpret “1% QA” to be per rater.
If option a), this will more than double the amount of 1% QA required; increasing the amount of 1% QA required does not meet the intention of this proposed amendment. Therefore, we object the proposed amendment.
If option b), this requirement will not be an effective solution for reasons below. Therefore, we object the proposed amendment.
Here is an example using our single family numbers from 2013, using 3 different scenarios:
1) AS IS 1%: 28 QA trips total required for 2013 2) If 1%/rater/quarter: 65 QA trips total for 2013 3) If 1%/total ratings/quarter: 5 QA trips, there are still 23 QA trips left to do at the end of the year
Additionally, while we agree it is not best pracitce to wait until the end of the year to complete annual field QA requirements, RESNET should not be creating business management requirements for Providers for the reasons below:
Proposed Effective Date:
If the intent of this change is to increase the amount of annual field QA, then the effective date would need to allow enough time for providers, QAD's, and raters to accommodate this change (more than 30 days). This change would need to take effect at the beginning of the calendar year, at the earliest.
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