Comment #1Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Comment Intent: ObjectionComment Type: GeneralComment: As a truly third party provider that does not compete with raters and only is involved as a provider/QA work, I object to the proposal that the provider roles are being split and another entity is brought into the mix. We already have builders leave the program because of cost factors. With the most recent changes to the program we have seen a significant drop in builder participation already. The additional cost would ultimately be shifted to the builder on a per rating increase. With the new codes going into effect later this year and being more stringent than EnergyStar I can not see why builders would stay in the program and absorb the higher cost associated with this. Response: Reject No propose change suggested. RESNET board has already directed that the standard be modified.
As a truly third party provider that does not compete with raters and only is involved as a provider/QA work, I object to the proposal that the provider roles are being split and another entity is brought into the mix. We already have builders leave the program because of cost factors. With the most recent changes to the program we have seen a significant drop in builder participation already. The additional cost would ultimately be shifted to the builder on a per rating increase.
With the new codes going into effect later this year and being more stringent than EnergyStar I can not see why builders would stay in the program and absorb the higher cost associated with this.
Reject
No propose change suggested. RESNET board has already directed that the standard be modified.
Comment #2Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Comment Intent: ObjectionComment Type: GeneralComment: As a truly third party provider that does not compete with raters and only is involved as a provider/QA work, I object to the proposal that the provider roles are being split and another entity is brought into the mix. We already have builders leave the program because of cost factors. With the most recent changes to the program we have seen a significant drop in builder participation already. The additional cost would ultimately be shifted to the builder on a per rating increase. With the new codes going into effect later this year and being more stringent than EnergyStar I can not see why builders would stay in the program and absorb the higher cost associated with this. Response: Reject No propose change suggested. RESNET board has already directed that the standard be modified.
Comment #3Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1Comment Intent: ObjectionComment Type: GeneralComment: I am concerned about the proposed requirment that agents not be raters as well. Right now, I'm sure that the vast majority (100% in smaller population areas) of QADs are raters first, QADs second as far as a business/income model. There is no way to make a living being only a QAD/agent in many areas (I can't imagine anyone dropping their rating business and becoming an agent...too much of a risk with out knowing potential income). The only way around this is to have agents that cover large areas which means I as rater will have to pay for travel expenses which can be rather hefty. For new raters or low volume raters, this will be a cost they can not cover. Until RESNET has perfected the virtual field review, I recommend letting agents be raters as well (I guess I don't see the confict of interest anywhere anyway. As long as raters aren't doing reviews on their own ratings...). Proposed Change: 103.2 Third-party Rating Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider whose employees are not allowed to conduct any portion of the work for a HERS rating but and who may receive fees for performing quality assurance work as outlined in these Standards, quality assurance oversight, certification and other Quality Assurance Provider related duties if they have no financial interest in the rating of the homes the are providing Quality Assurance on. Response: Accept Accept in principle. Revised section 905.2.2.3 to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
I am concerned about the proposed requirment that agents not be raters as well. Right now, I'm sure that the vast majority (100% in smaller population areas) of QADs are raters first, QADs second as far as a business/income model. There is no way to make a living being only a QAD/agent in many areas (I can't imagine anyone dropping their rating business and becoming an agent...too much of a risk with out knowing potential income). The only way around this is to have agents that cover large areas which means I as rater will have to pay for travel expenses which can be rather hefty. For new raters or low volume raters, this will be a cost they can not cover. Until RESNET has perfected the virtual field review, I recommend letting agents be raters as well (I guess I don't see the confict of interest anywhere anyway. As long as raters aren't doing reviews on their own ratings...).
103.2 Third-party Rating Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider whose employees are not allowed to conduct any portion of the work for a HERS rating but and who may receive fees for performing quality assurance work as outlined in these Standards, quality assurance oversight, certification and other Quality Assurance Provider related duties if they have no financial interest in the rating of the homes the are providing Quality Assurance on.
Accept
Accept in principle. Revised section 905.2.2.3 to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
Comment #4Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: omissionComment Intent: ObjectionComment Type: GeneralComment: In the Recommendations of RESNET Quality Improvement Task to the RESNET Board on Enhanced Quality Assurance the task force made the recommendation that, "There will be a transparent process for RESNET’s cost for implementation Quality Assurance and credentialing. RESNET will report to the accredited Providers the cost of its carrying out the requirements of quality assurance oversight." See #6 in the last section "Quality Assurance oversight" http://www.resnet.us/professional/about/Quality_Improvement_Taskforce_Recommendations_to_the_RESNET_Board_-10-20-14.pdf Proposed Change: I propose RESNET inlcude language in this standard that addresses this task force recomendation like it does the other recomendations. Response: Accept Accept in principle. This item will be addressed but language will not be included in the RESNET Standards.
In the Recommendations of RESNET Quality Improvement Task to the RESNET Board on Enhanced Quality Assurance the task force made the recommendation that,
"There will be a transparent process for RESNET’s cost for implementation Quality Assurance and credentialing. RESNET will report to the accredited Providers the cost of its carrying out the requirements of quality assurance oversight."
See #6 in the last section "Quality Assurance oversight"
http://www.resnet.us/professional/about/Quality_Improvement_Taskforce_Recommendations_to_the_RESNET_Board_-10-20-14.pdf
I propose RESNET inlcude language in this standard that addresses this task force recomendation like it does the other recomendations.
Accept in principle. This item will be addressed but language will not be included in the RESNET Standards.
Comment #5Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 103.11Comment Intent: ObjectionComment Type: GeneralComment: i have been in the insulation and energy conservation business for over 40 years and was instrumental in the creation of the first MEC in the State of Ohio in 1994. We are Energy Star, BPI, RESNET and HERS qualified amongst others. We perform 8 scopes of work for residential builders. There never has, or would, be an instance when it would be in our best interest to provide scoring or testing information to a builder that was'nt completely accurate or true. I would request that a review of any organization that has performed testing for builders for as many years as we have,for quality assurance and accuracy, and that be the criteria for their acceptance regardless of their affiliations in the construction industry. To limit those that have helped for years to promote RESNET/HERS and attain the status it enjoys, with the construction industry and consumers, is patently unfair and quite frankly sounds like cronyism and turf protection, in my opinion. Response: Reject Contradict RESNET board policy that Quality Agents act as agents of RESNET.
i have been in the insulation and energy conservation business for over 40 years and was instrumental in the creation of the first MEC in the State of Ohio in 1994. We are Energy Star, BPI, RESNET and HERS qualified amongst others. We perform 8 scopes of work for residential builders. There never has, or would, be an instance when it would be in our best interest to provide scoring or testing information to a builder that was'nt completely accurate or true. I would request that a review of any organization that has performed testing for builders for as many years as we have,for quality assurance and accuracy, and that be the criteria for their acceptance regardless of their affiliations in the construction industry. To limit those that have helped for years to promote RESNET/HERS and attain the status it enjoys, with the construction industry and consumers, is patently unfair and quite frankly sounds like cronyism and turf protection, in my opinion.
Contradict RESNET board policy that Quality Agents act as agents of RESNET.
Comment #6Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-6Comment Intent: ObjectionComment Type: EditorialComment: 904.3.3.1.1.1 change 500 to 300, so more Raters qualify. Proposed Change: • 904.3.3.1.1.1 Home Energy Raters who conduct over 500 300 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the field QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated. Response: Reject Entire section will be deleted
904.3.3.1.1.1 change 500 to 300, so more Raters qualify.
• 904.3.3.1.1.1 Home Energy Raters who conduct over 500 300 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the field QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated.
Entire section will be deleted
Comment #7Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Comment Intent: ObjectionComment Type: EditorialComment: 904.3.3.1. Allow pre-drywall QA Field Reviews to account for more of the total number of QA Field reviews. More QA is needed at pre-drywall to ensure the home has QA throughout every phase of construction. By allowing up to 50% pre-dryall field QA to count towards the total number of required field QA, every home that QA is performed on can have full QA. Proposed Change: • 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10% but not more than 10% 50%, of the total number of QA Field reviews (rounded up). Response: Reject 50% is too stringent of a requirement for the standard
904.3.3.1. Allow pre-drywall QA Field Reviews to account for more of the total number of QA Field reviews. More QA is needed at pre-drywall to ensure the home has QA throughout every phase of construction. By allowing up to 50% pre-dryall field QA to count towards the total number of required field QA, every home that QA is performed on can have full QA.
• 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10% but not more than 10% 50%, of the total number of QA Field reviews (rounded up).
50% is too stringent of a requirement for the standard
Comment #8Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: entire documentComment Intent: ObjectionComment Type: EditorialComment: To the Committee: Please review the entire document for consistency in terms of terminology and verb tense. Please also consider structuring sections so that their content parallels other, similar sections. In general, please review for grammatical errors and ambiguous phrases. If at all possible, please review with an eye toward consolidating subsections. A document that frequently uses five or more levels of subsections is difficult to follow and, therefore, difficult to both implement and enforce. Let's create a Standard that we can all use to "enhance the national consistency of HERS Index scores." Response: Reject No specific proposed change suggested. Staff will review document for grammatical errors and consistency.
To the Committee:
Please review the entire document for consistency in terms of terminology and verb tense. Please also consider structuring sections so that their content parallels other, similar sections. In general, please review for grammatical errors and ambiguous phrases.
If at all possible, please review with an eye toward consolidating subsections. A document that frequently uses five or more levels of subsections is difficult to follow and, therefore, difficult to both implement and enforce. Let's create a Standard that we can all use to "enhance the national consistency of HERS Index scores."
No specific proposed change suggested. Staff will review document for grammatical errors and consistency.
Comment #9Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-29Comment Intent: ObjectionComment Type: GeneralComment: The committee should have the same time constraints as the Raters/Providers. The Committee should deal with these issues in a timely manner defined by the standards. Proposed Change: 908.2.2 Committee Responsibilities. The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider’s accreditation has been suspended or revoked within 30 business days. Response: Accept
The committee should have the same time constraints as the Raters/Providers. The Committee should deal with these issues in a timely manner defined by the standards.
908.2.2 Committee Responsibilities. The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider’s accreditation has been suspended or revoked within 30 business days.
Comment #10Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 1 0 3 . 4 . 9 .2.2Comment Intent: ObjectionComment Type: GeneralComment: I am concerned with the changes made in this section. Does this mean that any subcontractor or entity who is a certified HERS rater who worked on the house in any way even if not the GC, those who used to just disclose involvement in the form, is now no longer able to provide a rating on the home? Two concerns with this: 1.) In rural areas that may not have a close-by 3rd party HERS rating company, this can make it less likely for homes in these areas to get rated at all. Homebuyers and builders do not pursue HERS ratings if doing so is not cost effective and is not convenient. Independent raters or companies who only do ratings also tend to be very rare in rural areas, simply due to lack of adequate business, getting one to come to you from a nearest city will be costly and not convenient for either party. Subcontracting companies are also more rare in rural areas, but trades that are impacted by energy efficiency such as insulation, HVAC, window sales, etc, who had previuosly been allowed to Rate homes with proper disclosure--have more reason to have some presence in rural areas: those that have an interest in seeing the more widespread use of HERS ratings to help distinguish energy efficient homes in their marketplace currently have the ability, with discolusre, to get that training themselves and thus help bring HERS to their builder or homeowner clients by acting themselves. There may not be a big enough market for a business that does only HERS ratings as a third party in rural areas, but, a successful business could be built by offering multiple services. The prevalence HERS index is already largely concentrated in urban areas and is not adequately present in rural areas. Business models that work in areas with a higher populartion no not necessarily work in rural areas. Dissallowing this too narrowly limits innovation in business models that could bring the HERS index into the mainstream in these more rural areas. 2.) I am an example of a different business model that uses the HERS index: I a certified HERS rater who works for a panelized home manufacturing company, and am actively involved in helping our clients design their home. We aren't GCs or home builders, but we do provide one large component of the project: a structural shell kit and a design for the home, and ship this product to clients all over the country to be assembled by an on-site GC, and hopefully, rated by an on-site HERS Rater. In this role I do not do any confirmed ratings, but I do projected ratings for the purposes of helping the client make the most energy efficient decisions during the design phase, and for the purposes of helping the clients prepare the appraisal form 820 document with as much information as possible to be able to successfully get construciton loans that account for the higher value of the home's energy efficinecy. Many o fmy clients are building in rural areas wehre finding an on-site, third-party HERS rater to do this for them is difficult. Using the energy modeling in the design process is a very powerful tool for getting houses that are ultimately the most energy efficient, and often those most directly involved in the design process are builders or architects, who have financial stake in the project but also work with the client directly to make decisions about how they build their house. I would submit that projected ratings done in this manner are valuable tools to make homes energy efficient while still maintaining high quality assurance by virtue of falling under the usual quality assurance standards and guidelines when later finished as confirmed ratings. Proposed Change: 103.4.9.2.2 Companies(including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct confirmed ratings on any homes or buildings for which any of the above designations apply. Response: Accept Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
I am concerned with the changes made in this section. Does this mean that any subcontractor or entity who is a certified HERS rater who worked on the house in any way even if not the GC, those who used to just disclose involvement in the form, is now no longer able to provide a rating on the home?
Two concerns with this:
1.) In rural areas that may not have a close-by 3rd party HERS rating company, this can make it less likely for homes in these areas to get rated at all. Homebuyers and builders do not pursue HERS ratings if doing so is not cost effective and is not convenient. Independent raters or companies who only do ratings also tend to be very rare in rural areas, simply due to lack of adequate business, getting one to come to you from a nearest city will be costly and not convenient for either party. Subcontracting companies are also more rare in rural areas, but trades that are impacted by energy efficiency such as insulation, HVAC, window sales, etc, who had previuosly been allowed to Rate homes with proper disclosure--have more reason to have some presence in rural areas: those that have an interest in seeing the more widespread use of HERS ratings to help distinguish energy efficient homes in their marketplace currently have the ability, with discolusre, to get that training themselves and thus help bring HERS to their builder or homeowner clients by acting themselves. There may not be a big enough market for a business that does only HERS ratings as a third party in rural areas, but, a successful business could be built by offering multiple services. The prevalence HERS index is already largely concentrated in urban areas and is not adequately present in rural areas. Business models that work in areas with a higher populartion no not necessarily work in rural areas. Dissallowing this too narrowly limits innovation in business models that could bring the HERS index into the mainstream in these more rural areas.
2.) I am an example of a different business model that uses the HERS index: I a certified HERS rater who works for a panelized home manufacturing company, and am actively involved in helping our clients design their home. We aren't GCs or home builders, but we do provide one large component of the project: a structural shell kit and a design for the home, and ship this product to clients all over the country to be assembled by an on-site GC, and hopefully, rated by an on-site HERS Rater. In this role I do not do any confirmed ratings, but I do projected ratings for the purposes of helping the client make the most energy efficient decisions during the design phase, and for the purposes of helping the clients prepare the appraisal form 820 document with as much information as possible to be able to successfully get construciton loans that account for the higher value of the home's energy efficinecy. Many o fmy clients are building in rural areas wehre finding an on-site, third-party HERS rater to do this for them is difficult. Using the energy modeling in the design process is a very powerful tool for getting houses that are ultimately the most energy efficient, and often those most directly involved in the design process are builders or architects, who have financial stake in the project but also work with the client directly to make decisions about how they build their house. I would submit that projected ratings done in this manner are valuable tools to make homes energy efficient while still maintaining high quality assurance by virtue of falling under the usual quality assurance standards and guidelines when later finished as confirmed ratings.
103.4.9.2.2 Companies(including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct confirmed ratings on any homes or buildings for which any of the above designations apply.
Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
Comment #11Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-1 and 1-4Paragraph / Figure / Table / Note: 102 and 103Comment Intent: Not an ObjectionComment Type: EditorialComment: I propose to reverse sections 102 and 103 so that Accredation Criteria preceeds Renewal Process. Proposed Change: 103 102 PROVIDER ACCREDITATION AND RENEWAL PROCESS ... 102 103 ACCREDITATION CRITERIA FOR HOME ENERGY RATING QUALITY ASSURANCE PROVIDERS Response: Accept
I propose to reverse sections 102 and 103 so that Accredation Criteria preceeds Renewal Process.
103 102 PROVIDER ACCREDITATION AND RENEWAL PROCESS
...
102 103 ACCREDITATION CRITERIA FOR HOME ENERGY RATING QUALITY ASSURANCE PROVIDERS
Comment #12Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1Paragraph / Figure / Table / Note: 102.1Comment Intent: Not an ObjectionComment Type: GeneralComment: In regards to the statement, "...will post the registry on its website." Which website? The 'professional' or 'public' website? I'd like to see this spelled out in the standard, specifically because consumers might like to access the list, rather than have a search function that may or may not work because of issues with the RESNET National Registry. Proposed Change: 102.1 National Registry of Accredited Providers RESNET shall maintain a national registry of organizations accredited as Providers in each Provider accreditation category and will post the registry on the public RESNET website. The registry for each Provider accreditation shall serve as the current and definitive list of RESNET accredited Providers. The definitive list of Rating Quality Assurance Providers shall be maintained within the National RESNET Registry. Response: Reject Unnecessary distinction “public” and “professional” website are available to all
In regards to the statement, "...will post the registry on its website." Which website? The 'professional' or 'public' website? I'd like to see this spelled out in the standard, specifically because consumers might like to access the list, rather than have a search function that may or may not work because of issues with the RESNET National Registry.
102.1 National Registry of Accredited Providers RESNET shall maintain a national registry of organizations accredited as Providers in each Provider accreditation category and will post the registry on the public RESNET website. The registry for each Provider accreditation shall serve as the current and definitive list of RESNET accredited Providers. The definitive list of Rating Quality Assurance Providers shall be maintained within the National RESNET Registry.
Unnecessary distinction “public” and “professional” website are available to all
Comment #13Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-2Paragraph / Figure / Table / Note: 102.1Comment Intent: Not an ObjectionComment Type: EditorialComment: Section 102.1 repeats itself and this causes confusion. The last sentence is not required. Proposed Change: RESNET shall maintain a national registry of organizations accredited as Providers in each Provider accreditation category and will post the registry on its web site. The registry for each Provider accreditation shall serve as the current and definitive list of RESNET accredited Providers. The definitive list of Rating Quality Assurance Providers shall be maintained within the National RESNET Registry. Response: Accept
Section 102.1 repeats itself and this causes confusion. The last sentence is not required.
RESNET shall maintain a national registry of organizations accredited as Providers in each Provider accreditation category and will post the registry on its web site. The registry for each Provider accreditation shall serve as the current and definitive list of RESNET accredited Providers. The definitive list of Rating Quality Assurance Providers shall be maintained within the National RESNET Registry.
Comment #14Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-1Paragraph / Figure / Table / Note: 102.1Comment Intent: Not an ObjectionComment Type: EditorialComment: Terminology needs to remain consistent throughout the RESNET Standards in order to communicate clearly with all stakeholders. Terms that are defined in Appendix B, the Glossary, need to be used throughout the Standards so that everybody is on the same page. When the terms in the Standard do not align with the Glossary, there is no point to providing a Glossary. In addition to consistency, brevity is a critical attribute of clear technical writing. Please refrain from restating the same sentiment more than once in the same provision, and work to consolidate provisions so that they do not restate each other. Particular to this provision, the use of the term "web site" is vague and should be accompanied by more specific language: which website? Also, please note the correct spelling is "website." Proposed Change: 102.1 National Registry of Accredited Providers RESNET shall maintain a definitive Nnational Rregistry of organizations accredited as Providers in each Provider accreditation category and shallwill post the Rregistry on its consumer and professional web sites. The Rregistry for each Provider accreditationshall serve as the current and definitive list of RESNET accredited Providers. The definitive list of Rating Quality Assurance Providers shall be maintained within the National RESNET Registry. Response: Reject Unnecessary distinction “public” and “professional” website are available to all
Terminology needs to remain consistent throughout the RESNET Standards in order to communicate clearly with all stakeholders. Terms that are defined in Appendix B, the Glossary, need to be used throughout the Standards so that everybody is on the same page. When the terms in the Standard do not align with the Glossary, there is no point to providing a Glossary.
In addition to consistency, brevity is a critical attribute of clear technical writing. Please refrain from restating the same sentiment more than once in the same provision, and work to consolidate provisions so that they do not restate each other.
Particular to this provision, the use of the term "web site" is vague and should be accompanied by more specific language: which website? Also, please note the correct spelling is "website."
102.1 National Registry of Accredited Providers RESNET shall maintain a definitive Nnational Rregistry of organizations accredited as Providers in each Provider accreditation category and shallwill post the Rregistry on its consumer and professional web sites. The Rregistry for each Provider accreditationshall serve as the current and definitive list of RESNET accredited Providers. The definitive list of Rating Quality Assurance Providers shall be maintained within the National RESNET Registry.
Comment #15Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 2Paragraph / Figure / Table / Note: 102.2.1Comment Intent: Not an ObjectionComment Type: EditorialComment: The sentence structure for this proposed standard needs work: 102.2.1 An entity seeking accreditation must file with RESNET an application for the specific Provider category for which they seek accreditation. Proposed Change: 102.2.1 An entity seeking accreditation must file an application with RESNET for the specific Provider category for which they seek accreditation. Response: Accept Accept in principle. This will be considered when staff conducts editorial review of standards.
The sentence structure for this proposed standard needs work:
102.2.1 An entity seeking accreditation must file with RESNET an application for the specific Provider category for which they seek accreditation.
102.2.1 An entity seeking accreditation must file an application with RESNET for the specific Provider category for which they seek accreditation.
Accept in principle. This will be considered when staff conducts editorial review of standards.
Comment #16Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 2Paragraph / Figure / Table / Note: 102.2.1Comment Intent: Not an ObjectionComment Type: GeneralComment: I have an issue with the highlighted sentence: 102.2.1 An entity seeking accreditation must file with RESNET an application for the specific Provider category for which they seek accreditation. RESNET shall create the applications for each accreditation category. Proposed Change: Can we have a timeline for the creation of applications? Or do they already exist, just aren't published? Response: Reject No proposed change. A timeline cannot be created until the standard is adopted.
I have an issue with the highlighted sentence:
102.2.1 An entity seeking accreditation must file with RESNET an application for the specific Provider category for which they seek accreditation. RESNET shall create the applications for each accreditation category.
Can we have a timeline for the creation of applications? Or do they already exist, just aren't published?
No proposed change. A timeline cannot be created until the standard is adopted.
Comment #17Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-2Paragraph / Figure / Table / Note: 102.2.1Comment Intent: Not an ObjectionComment Type: EditorialComment: The structure of the first sentence is awkward and should be rewritten. The second sentence is nonsensical in that an organization to which individuals or other organizations are applying for recognition, acceptance, or some other reason always creates the application for the applicants. Applicants are never expected to create their own application. Therefore, it goes without saying that "RESNET shall create the applications for each accreditation category," so that sentence should be struck. Proposed Change: 102.2.1 An entity seeking accreditation must file with RESNET an application with RESNET for the specific Provider category infor which they seek accreditation. RESNET shall create the applications for each accreditation category. Response: ?Response:? Accept Accept in principle. This will be considered when staff conducts editorial review of standards
The structure of the first sentence is awkward and should be rewritten.
The second sentence is nonsensical in that an organization to which individuals or other organizations are applying for recognition, acceptance, or some other reason always creates the application for the applicants. Applicants are never expected to create their own application. Therefore, it goes without saying that "RESNET shall create the applications for each accreditation category," so that sentence should be struck.
102.2.1 An entity seeking accreditation must file with RESNET an application with RESNET for the specific Provider category infor which they seek accreditation. RESNET shall create the applications for each accreditation category.
?Response:?
Accept in principle. This will be considered when staff conducts editorial review of standards
Comment #18Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 2Paragraph / Figure / Table / Note: 102.2.3Comment Intent: ObjectionComment Type: EditorialComment: I take issue with this proposed standard: 102.2.3 Confidentiality of Information. Any applicant for a Provider accreditation who wishes to have certain information in their application treated as confidential in order to limit disclosure shall, at the time of submission, attach a statement specifying the proprietary information and requesting confidentiality. While I understand that the application would still undergo a review process that may or may not approved of the confidentiality of the information, I believe that leaving the door open to having certain things confidential could lead to issues for the consumers. Additionally, what kind of proprietary information on the application would be asked? Looking over the proposed standards I don't see anything that would 'need' a confidentiality request. I believe that by allowing a confidentiality request to go into an application would open the door for potential gaming of the system. I propose this language is completely struck. Proposed Change: 102.2.3 Confidentiality of Information. Any applicant for a Provider accreditation who wishes to have certain information in their application treated as confidential in order to limit disclosure shall, at the time of submission, attach a statement specifying the proprietary information and requesting confidentiality. Response: Response: Reject? This entire section should not be deleted and edits to this section will be made per action on comment #19
I take issue with this proposed standard:
102.2.3 Confidentiality of Information. Any applicant for a Provider accreditation who wishes to have certain information in their application treated as confidential in order to limit disclosure shall, at the time of submission, attach a statement specifying the proprietary information and requesting confidentiality.
While I understand that the application would still undergo a review process that may or may not approved of the confidentiality of the information, I believe that leaving the door open to having certain things confidential could lead to issues for the consumers.
Additionally, what kind of proprietary information on the application would be asked? Looking over the proposed standards I don't see anything that would 'need' a confidentiality request. I believe that by allowing a confidentiality request to go into an application would open the door for potential gaming of the system.
I propose this language is completely struck.
Response: Reject?
This entire section should not be deleted and edits to this section will be made per action on comment #19
Comment #19Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-2Paragraph / Figure / Table / Note: 102.2.3Comment Intent: ObjectionComment Type: TechnicalComment: I believe that confidentiality should be maintained for all applicants during the application process. I also believe that, once accredited, all Provider documentation should be made public. Proposed Change: 102.2.3 Confidentiality of Information. AllAny applicants for a Provider accreditation who wishes to have certain shall have all information in their application treated as confidential throughout the application process. Upon acceptance of the accreditation application, all governing documents shall be made public.in order to limit disclosure shall, at the time of submission, attach a statement specifying the proprietary information and requesting confidentiality. Response: Response:? Accept?
I believe that confidentiality should be maintained for all applicants during the application process. I also believe that, once accredited, all Provider documentation should be made public.
102.2.3 Confidentiality of Information. AllAny applicants for a Provider accreditation who wishes to have certain shall have all information in their application treated as confidential throughout the application process. Upon acceptance of the accreditation application, all governing documents shall be made public.in order to limit disclosure shall, at the time of submission, attach a statement specifying the proprietary information and requesting confidentiality.
Response:? Accept?
Comment #20Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-2Paragraph / Figure / Table / Note: 102.2.4.1.1-3Comment Intent: Not an ObjectionComment Type: EditorialComment: Since the sentence preceeding the list indicates that this list is actions that RESNET staff shall take, each of the items in the list should begin with a verb. Proposed Change: 102.2.4.1.1 Request for additional information. If additional information is required in order to complete the review of the application, the application shall be returned to the applicant along with a written request for additional information. Upon receipt of additional information, RESNET staff shall have twenty (20) fifteen (15) business days to take action in accordance with 102.2.4.1.2 or 102.2.4.1.3. 102.2.4.1.2 Recommendation for approval. If RESNET staff is satisfied that an application is complete and meets all the requirements for accreditation, they shall make a recommendation to the Accreditation Committee that the application be approved. 102.2.4.1.3 Recommendation for denial. If RESNET staff is not satisfied that an application is worthy of approval for accreditation, they shall make a recommendation to the Accreditation Committee that the application be denied and provide an explanation of the reasons for the recommendation (i.e. incompleteness, failure to meet/comply with a specific accreditation requirement, etc.). Response: Accept Accept in principle. This will be considered when staff conducts editorial review of standards.
Since the sentence preceeding the list indicates that this list is actions that RESNET staff shall take, each of the items in the list should begin with a verb.
102.2.4.1.1 Request for additional information. If additional information is required in order to complete the review of the application, the application shall be returned to the applicant along with a written request for additional information. Upon receipt of additional information, RESNET staff shall have twenty (20) fifteen (15) business days to take action in accordance with 102.2.4.1.2 or 102.2.4.1.3.
102.2.4.1.2 Recommendation for approval. If RESNET staff is satisfied that an application is complete and meets all the requirements for accreditation, they shall make a recommendation to the Accreditation Committee that the application be approved.
102.2.4.1.3 Recommendation for denial. If RESNET staff is not satisfied that an application is worthy of approval for accreditation, they shall make a recommendation to the Accreditation Committee that the application be denied and provide an explanation of the reasons for the recommendation (i.e. incompleteness, failure to meet/comply with a specific accreditation requirement, etc.).
Comment #21Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-2Paragraph / Figure / Table / Note: 102.2.4.1.3Comment Intent: Not an ObjectionComment Type: GeneralComment: Just a question. Where is the definition of the Accreditation Committee? How are they chosen? Proposed Change: N/A Just a question. Response: Accept Accreditation committee is defined in the RESNET Standards but a definition for Standing Committee is not. A definition for Standing Committee will be added.
Just a question. Where is the definition of the Accreditation Committee? How are they chosen?
N/A Just a question.
Accreditation committee is defined in the RESNET Standards but a definition for Standing Committee is not. A definition for Standing Committee will be added.
Comment #22Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-3Paragraph / Figure / Table / Note: 102.2.4.2.1-3Comment Intent: Not an ObjectionComment Type: EditorialComment: Since the sentence preceding the list indicates that this list is actions that RESNET staff shall take, each of the items in the list should begin with a verb. Proposed Change: 102.2.4.2.1 Request for additional information. If the Committee requires additional information, the application shall be returned to the applicant along with a written request for additional information. Upon receipt of additional information, the Committee shall have twenty (20) fifteen (15) business days to render a decision in accordance with 102.2.4.2.2 or 102.2.4.2.3. 102.2.4.2.2 Approve the application. 102.2.4.2.3 Deny the application. If an application is denied, RESNET staff shall inform the applicant in writing of the reasons for denial. Additionally, the applicant shall be informed of their right toof appeal under Section 910 of these Standards. Response: Accept? Accept in principle. This will be considered when staff conducts editorial review of standards.
Since the sentence preceding the list indicates that this list is actions that RESNET staff shall take, each of the items in the list should begin with a verb.
102.2.4.2.1 Request for additional information. If the Committee requires additional information, the application shall be returned to the applicant along with a written request for additional information. Upon receipt of additional information, the Committee shall have twenty (20) fifteen (15) business days to render a decision in accordance with 102.2.4.2.2 or 102.2.4.2.3.
102.2.4.2.2 Approve the application.
102.2.4.2.3 Deny the application. If an application is denied, RESNET staff shall inform the applicant in writing of the reasons for denial. Additionally, the applicant shall be informed of their right toof appeal under Section 910 of these Standards.
Accept?
Comment #23Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-3Paragraph / Figure / Table / Note: 102.2.4.2.3Comment Intent: Not an ObjectionComment Type: EditorialComment: Section 910 is incorrect Proposed Change: It should be Section 911 Response: Accept Accept in principle. Change reference to chapter nine instead of a specific section of the standards.
Section 910 is incorrect
It should be Section 911
Accept in principle. Change reference to chapter nine instead of a specific section of the standards.
Comment #24Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-3Paragraph / Figure / Table / Note: 102.2.6.2Comment Intent: Not an ObjectionComment Type: EditorialComment: Section is written in confusing sequence. If you have to explain the language you used with more language, make the initial language more clear instead. Proposed Change: 102.2.6.2 For first time applicants approved after September 1st, for any Provider category, initial accreditation is valid through the end of the calendar year, i.e. renewal of the accreditation shall not be required for the calendar year in which the application was approved. Replace with: "First time applications in any Provider category approved after September 1st, shall not be required to renew for the calendar year in which the application was approved." Response: Accept
Section is written in confusing sequence. If you have to explain the language you used with more language, make the initial language more clear instead.
102.2.6.2 For first time applicants approved after September 1st, for any Provider category, initial accreditation is valid through the end of the calendar year, i.e. renewal of the accreditation shall not be required for the calendar year in which the application was approved.
Replace with:
"First time applications in any Provider category approved after September 1st, shall not be required to renew for the calendar year in which the application was approved."
Comment #25Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-3Paragraph / Figure / Table / Note: 102.2.6.2Comment Intent: Not an ObjectionComment Type: EditorialComment: The current wording of this paragraph is confusing. Stating that first time applicants approved after September 1st will have their accreditation valid through the end of the calendar year makes one ask about those applicants who were approved prior to September 1st. When is their accreditation valid through if not through the end of the calendar year? I believe the intent is that late applicants have their accreditation vaid through the end of the next calendar year. The following edits clarify this. Proposed Change: 102.2.6.2 For first time applicants approved after September 1st, for any Provider category, initial accreditation is valid through the end of the next calendar year, i.e. renewal of the accreditation shall not be required for in the calendar year in which the application was approved. Response: Response: Accept Accept in principle. Comment 24 provides a clear and more succinct alternative.
The current wording of this paragraph is confusing. Stating that first time applicants approved after September 1st will have their accreditation valid through the end of the calendar year makes one ask about those applicants who were approved prior to September 1st. When is their accreditation valid through if not through the end of the calendar year? I believe the intent is that late applicants have their accreditation vaid through the end of the next calendar year. The following edits clarify this.
102.2.6.2 For first time applicants approved after September 1st, for any Provider category, initial accreditation is valid through the end of the next calendar year, i.e. renewal of the accreditation shall not be required for in the calendar year in which the application was approved.
Response: Accept
Accept in principle. Comment 24 provides a clear and more succinct alternative.
Comment #26Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-3Paragraph / Figure / Table / Note: 102.2.6.2Comment Intent: ObjectionComment Type: TechnicalComment: This wording implies that the first time applicants approved after September 1 are only approved through the end of the current year and would have to apply again the next year. Proposed Change: For first time applicants approved after September 1st, for any Provider category, initial accreditation is valid through the end of the next [D1] calendar year, i.e. renewal of the accreditation shall not be required for the next [D2] calendar year in which the application was approved. [D1]should be next year [D2]should be next year Response: Accept Accept in principle. Comment 24 provides a clear and more succinct alternative.
This wording implies that the first time applicants approved after September 1 are only approved through the end of the current year and would have to apply again the next year.
For first time applicants approved after September 1st, for any Provider category, initial accreditation is valid through the end of the next [D1] calendar year, i.e. renewal of the accreditation shall not be required for the next [D2] calendar year in which the application was approved.
[D1]should be next year
[D2]should be next year
Comment #27Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-3Paragraph / Figure / Table / Note: 102.2.6.2Comment Intent: Not an ObjectionComment Type: EditorialComment: The intent of this provision is unclear. Please see below for my interpretation. Proposed Change: 102.2.6.2 For first time applicants in any Provider category approved after September 1st, for any Provider category, initial accreditation is valid through the end of the following calendar year, i.e., renewal of the accreditation shall not be required for the calendar year following the year in which the application was approved. Response: Accept Accept in principle. Comment 24 provides a clear and more succinct alternative.
The intent of this provision is unclear. Please see below for my interpretation.
102.2.6.2 For first time applicants in any Provider category approved after September 1st, for any Provider category, initial accreditation is valid through the end of the following calendar year, i.e., renewal of the accreditation shall not be required for the calendar year following the year in which the application was approved.
Comment #28Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-3Paragraph / Figure / Table / Note: 102.2.6.2Comment Intent: Not an ObjectionComment Type: EditorialComment: This would read more clearly if it said: "For first time applicants approved between September 1st and December 31st, for any Provider category, initial accreditation is valid through the end of the next calendar year. Proposed Change: 102.2.6.2 For first time applicants approved after between September 1st and December 31st, for any Provider category, initial accreditation is valid through the end of the next calendar year. , i.e. renewal of the accreditation shall not be required for the calendar year in which the application was approved. Response: Accept Accept in principle. Comment 24 provides a clear and more succinct alternative.
This would read more clearly if it said: "For first time applicants approved between September 1st and December 31st, for any Provider category, initial accreditation is valid through the end of the next calendar year.
102.2.6.2 For first time applicants approved after between September 1st and December 31st, for any Provider category, initial accreditation is valid through the end of the next calendar year. , i.e. renewal of the accreditation shall not be required for the calendar year in which the application was approved.
Comment #29Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-3Paragraph / Figure / Table / Note: 102.3.1Comment Intent: Not an ObjectionComment Type: TechnicalComment: One month is very little time to complete an extensive application, especially when business is doing well! Please provide the application more than 30 days prior to its deadline. Proposed Change: 102.3.1 Accredited Providers must submit an “application for renewal” (renewal application) withto RESNET no later than October 1st of each calendar year. By AugustSeptember 1st, RESNET shall send to each Provider a renewal application and reminder of the deadline for submission to each Provider. Response: Reject Pushing back provider accreditation renewals has a cascading effect on individual QAD and Trainer renewal timing. By pushing it too far back the QAD and Trainers may not be able to obtain the needed requirements for renewal. The task group identified as issue with including specific dates within the standard. To allow flexibility the group decided to edit this section as follows: 102.3.1 Accredited Providers must submit an application for renewal annually. Providers will have at least thirty (30) days from notification until the submission is due.
One month is very little time to complete an extensive application, especially when business is doing well! Please provide the application more than 30 days prior to its deadline.
102.3.1 Accredited Providers must submit an “application for renewal” (renewal application) withto RESNET no later than October 1st of each calendar year. By AugustSeptember 1st, RESNET shall send to each Provider a renewal application and reminder of the deadline for submission to each Provider.
Pushing back provider accreditation renewals has a cascading effect on individual QAD and Trainer renewal timing. By pushing it too far back the QAD and Trainers may not be able to obtain the needed requirements for renewal. The task group identified as issue with including specific dates within the standard. To allow flexibility the group decided to edit this section as follows: 102.3.1 Accredited Providers must submit an application for renewal annually. Providers will have at least thirty (30) days from notification until the submission is due.
Comment #30Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-3Paragraph / Figure / Table / Note: 102.3.2Comment Intent: ObjectionComment Type: TechnicalComment: If Provider changes are substantive enough to warrant an evaluation in the same manner as the original application for accreditation, the review should be performed in the same manner as well. The last sentence leaves out the Accreditation Committee. My change puts them back in. Proposed Change: Changes will be evaluated by RESNET staff and the Accreditation Committee in the same manner as the original application for accreditation. Response: Accept Accept in principle, with modification. "Changes will be evaluated by RESNET following the procedures outlined in Section 102.2"
If Provider changes are substantive enough to warrant an evaluation in the same manner as the original application for accreditation, the review should be performed in the same manner as well. The last sentence leaves out the Accreditation Committee. My change puts them back in.
Changes will be evaluated by RESNET staff and the Accreditation Committee in the same manner as the original application for accreditation.
Accept in principle, with modification. "Changes will be evaluated by RESNET following the procedures outlined in Section 102.2"
Comment #31Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-3Paragraph / Figure / Table / Note: 102.3.2Comment Intent: Not an ObjectionComment Type: EditorialComment: Using the term "affects" leaves the judgment call with the Provider. Using the term "may affect" requires that Providers disclose all substantive changes so that RESNET can evaluate whether or not the changes have any bearing on their status. To minimize abuse, "substantive changes" should be defined. Proposed Change: 102.3.2 Program element changes. At the time of submitting a renewal application, it is the accredited Provider’s responsibility to inform RESNET staff of any substantive changes in the Provider’s operating policies and procedures or other information that may affect affects their meeting the minimum accreditation criteria for each Provider category for which it is seeking renewal. Substantive changes include any changes beyond grammatical corrections. Changes will be evaluated by RESNET in the same manner as the original application for accreditation. Response: Accept Accept with modification. Proposed sentence beginning with "Substantive changes may include..." seems superflous and contradictory. Section edits as follows: 102.3.2 Program element changes. At the time of submitting a renewal application, it is the accredited Provider’s responsibility to inform RESNET staff of any substantive changes in the Provider’s operating policies and procedures or other information that may affect affects the provider meeting the minimum accreditation criteria for each Provider category for which it is seeking renewal. Changes will be evaluated by RESNET in the same manner as the original application for accreditation.
Using the term "affects" leaves the judgment call with the Provider. Using the term "may affect" requires that Providers disclose all substantive changes so that RESNET can evaluate whether or not the changes have any bearing on their status.
To minimize abuse, "substantive changes" should be defined.
102.3.2 Program element changes. At the time of submitting a renewal application, it is the accredited Provider’s responsibility to inform RESNET staff of any substantive changes in the Provider’s operating policies and procedures or other information that may affect affects their meeting the minimum accreditation criteria for each Provider category for which it is seeking renewal. Substantive changes include any changes beyond grammatical corrections. Changes will be evaluated by RESNET in the same manner as the original application for accreditation.
Accept with modification. Proposed sentence beginning with "Substantive changes may include..." seems superflous and contradictory. Section edits as follows: 102.3.2 Program element changes. At the time of submitting a renewal application, it is the accredited Provider’s responsibility to inform RESNET staff of any substantive changes in the Provider’s operating policies and procedures or other information that may affect affects the provider meeting the minimum accreditation criteria for each Provider category for which it is seeking renewal. Changes will be evaluated by RESNET in the same manner as the original application for accreditation.
Comment #32Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 4Paragraph / Figure / Table / Note: 102.3.3Comment Intent: Not an ObjectionComment Type: TechnicalComment: I have a problem with the language in the proposed standard: 102.3.3 Rating Quality Assurance Provider Accreditation Renewal. To qualify for annual accreditation renewal, Rating Quality Assurance Providers must participate in an annual RESNET training which covers, at a minimum, the following: I understand that the training will be held annually- but what happens if someone can't attend? Does that mean this training would be held quarterly, or biannually to allow for a better fit into Providers' schedules? Additionally- would a representative of the Provider be an acceptable attendee to allow for the renewal to continue? Or would it have to be the person who is listed in the National Registry? This could open the door for a secretary or intern to attend this as a representative. Proposed Change: I suggest additionally information be added to the proposed standards, indicating who is supposed to attend the training, and the ideal schedule this 'annual' training would follow. Y'all are smart and have a strong grasp of the English language, maybe look at something like this: 102.3.3 Rating Quality Assurance Provider Accreditation Renewal. To qualify for annual accreditation renewal, Rating Quality Assurance Providers must participate in an annual RESNET training. Attendees must be the individual listed in the RESNET National Registry or a leading official for the Provider. The training would which covers, at a minimum, the following: Response: Response:? Accept Accept in principle with modification. Attendee must be the individual listed as the RESNET’s primary point of contact for the providership.
I have a problem with the language in the proposed standard:
102.3.3 Rating Quality Assurance Provider Accreditation Renewal. To qualify for annual accreditation renewal, Rating Quality Assurance Providers must participate in an annual RESNET training which covers, at a minimum, the following:
I understand that the training will be held annually- but what happens if someone can't attend? Does that mean this training would be held quarterly, or biannually to allow for a better fit into Providers' schedules?
Additionally- would a representative of the Provider be an acceptable attendee to allow for the renewal to continue? Or would it have to be the person who is listed in the National Registry? This could open the door for a secretary or intern to attend this as a representative.
I suggest additionally information be added to the proposed standards, indicating who is supposed to attend the training, and the ideal schedule this 'annual' training would follow.
Y'all are smart and have a strong grasp of the English language, maybe look at something like this:
102.3.3 Rating Quality Assurance Provider Accreditation Renewal. To qualify for annual accreditation renewal, Rating Quality Assurance Providers must participate in an annual RESNET training. Attendees must be the individual listed in the RESNET National Registry or a leading official for the Provider. The training would which covers, at a minimum, the following:
Response:? Accept
Accept in principle with modification. Attendee must be the individual listed as the RESNET’s primary point of contact for the providership.
Comment #33Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-4Paragraph / Figure / Table / Note: 102.3.3Comment Intent: Not an ObjectionComment Type: GeneralComment: The language for this requirement which calls for Providers to participate in an annual RESNET training in order to renew their accreditation needs to be expanded to include more information. Proposed Change: 102.3.3 Rating Quality Assurance Provider Accreditation Renewal. To qualify for annual accreditation renewal, Rating Quality Assurance Providers must participate in an annual RESNET training. This training shall be offered virtually on more than one occasion annually, and shall be attended by at least one HERS Rater per Provider. The training shall cover, at a minimum, the following: Response: Reject Raters are not the target audience for this training. The training will be offered in a similar way to the roundtables and does not need to be addressed in the standards.
The language for this requirement which calls for Providers to participate in an annual RESNET training in order to renew their accreditation needs to be expanded to include more information.
102.3.3 Rating Quality Assurance Provider Accreditation Renewal. To qualify for annual accreditation renewal, Rating Quality Assurance Providers must participate in an annual RESNET training. This training shall be offered virtually on more than one occasion annually, and shall be attended by at least one HERS Rater per Provider. The training shall cover, at a minimum, the following:
Raters are not the target audience for this training. The training will be offered in a similar way to the roundtables and does not need to be addressed in the standards.
Comment #34Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-4Paragraph / Figure / Table / Note: 102.3.3Comment Intent: ObjectionComment Type: GeneralComment: This section is vague. Are quality agents and quality assurance designees required to attend this annual training, or can some representative of the Rating Quality Assurance Provider company attend in lieu of the people doing the quality management work? The distinction needs to be made that individuals are trained, companies are accredited. Proposed Change: Strike this language in its entirety: 102.3.3 Rating Quality Assurance Provider Accreditation Renewal. To qualify for annual accreditation renewal, Rating Quality Assurance Providers must participate in an annual RESNET training which covers, at a minimum, the following: 102.3.3.1 Updates to the RESNET ANSI and Non-ANSI Standards; 102.3.3.2 Effective support and communication with HERS Raters; 102.3.3.3 RESNET Quality Assurance updates and overview of critical findings from the year; 102.3.3.4 Updates for National RESNET Registry use; 102.3.3.5 New business opportunities for Rating Quality Assurance Providers and HERS Raters. Replace with: 102.3.3 Rating Quality Assurance Provider Accreditation Renewal. To qualify for annual accreditation renewal, Quality Agents and Quality Assurance Designees employed or contracted by a Rating Quality Assurance Provider must participate in a RESNET training held in conjunction with the annual conference which covers, at a minimum, the following: 102.3.3.1 Updates to the RESNET ANSI and Non-ANSI Standards; 102.3.3.2 Effective support and communication with HERS Raters; 102.3.3.3 RESNET Quality Assurance updates and overview of critical findings from the year; 102.3.3.4 Updates for National RESNET Registry use; 102.3.3.5 Quality management systems. Response: Reject Quality Agents are not the intended audience for this training
This section is vague. Are quality agents and quality assurance designees required to attend this annual training, or can some representative of the Rating Quality Assurance Provider company attend in lieu of the people doing the quality management work? The distinction needs to be made that individuals are trained, companies are accredited.
Strike this language in its entirety:
102.3.3 Rating Quality Assurance Provider Accreditation Renewal. To qualify for annual accreditation renewal, Rating Quality Assurance Providers must participate in an annual RESNET training which covers, at a minimum, the following: 102.3.3.1 Updates to the RESNET ANSI and Non-ANSI Standards; 102.3.3.2 Effective support and communication with HERS Raters; 102.3.3.3 RESNET Quality Assurance updates and overview of critical findings from the year; 102.3.3.4 Updates for National RESNET Registry use; 102.3.3.5 New business opportunities for Rating Quality Assurance Providers and HERS Raters.
102.3.3 Rating Quality Assurance Provider Accreditation Renewal. To qualify for annual accreditation renewal, Quality Agents and Quality Assurance Designees employed or contracted by a Rating Quality Assurance Provider must participate in a RESNET training held in conjunction with the annual conference which covers, at a minimum, the following: 102.3.3.1 Updates to the RESNET ANSI and Non-ANSI Standards; 102.3.3.2 Effective support and communication with HERS Raters; 102.3.3.3 RESNET Quality Assurance updates and overview of critical findings from the year; 102.3.3.4 Updates for National RESNET Registry use; 102.3.3.5 Quality management systems.
Quality Agents are not the intended audience for this training
Comment #35Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-4Paragraph / Figure / Table / Note: 102.3.3Comment Intent: Not an ObjectionComment Type: GeneralComment: Who will provide this training? How will it be given? How often? Who specifically in the Provider's organization will have to attend? Proposed Change: N/A Just a question Response: Accept Accept in principle. This is addressed in comment #31. The training will be offered in a similar way to the roundtables and does not need to be addressed in the standards.
Who will provide this training? How will it be given? How often? Who specifically in the Provider's organization will have to attend?
N/A Just a question
Accept in principle. This is addressed in comment #31. The training will be offered in a similar way to the roundtables and does not need to be addressed in the standards.
Comment #36Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-4Paragraph / Figure / Table / Note: 102.3.3.5Comment Intent: ObjectionComment Type: GeneralComment: Unless the RESNET Board of Directors has decided otherwise, RESNET is NOT a trade association and should not pretend to be one. Discussing new business opportunities for Rating Quality Assurance Providers and HERS Raters is not something that should be a subject at a required annual training, particularly since the subject is specifically to be on quality management systems for quality assurance providers. Proposed Change: 102.3.3.5 New business opportunities for Rating Quality Assurance Providers and HERS Raters. Strike this language in its entirety and do not replace. Response: Accept
Unless the RESNET Board of Directors has decided otherwise, RESNET is NOT a trade association and should not pretend to be one. Discussing new business opportunities for Rating Quality Assurance Providers and HERS Raters is not something that should be a subject at a required annual training, particularly since the subject is specifically to be on quality management systems for quality assurance providers.
102.3.3.5 New business opportunities for Rating Quality Assurance Providers and HERS Raters.
Strike this language in its entirety and do not replace.
Comment #37Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-4Paragraph / Figure / Table / Note: 102.3.6Comment Intent: Not an ObjectionComment Type: EditorialComment: Section 910 is incorrect Proposed Change: It should be Section 911 Response: Accept Accept in principle. Change reference to chapter nine instead of a specific section of the standards.
Comment #38Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1Comment Intent: ObjectionComment Type: TechnicalComment: The definition of a Direct Provider put forward in this section does NOT comply with the RESNET Board of Directors' definition approved during the fall Board meeting November 3, 2014. It is a RESNET Board Policy that no committee can produce work contrary to Board policy. Proposed Change: Strike this language in its entirety: 103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. Replace with the definition approved by the RESNET Board of Directors: 103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who either receives fees for the rating or whose staff conduct any portion of the rating. Response: Accept
The definition of a Direct Provider put forward in this section does NOT comply with the RESNET Board of Directors' definition approved during the fall Board meeting November 3, 2014. It is a RESNET Board Policy that no committee can produce work contrary to Board policy.
103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating.
Replace with the definition approved by the RESNET Board of Directors:
103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who either receives fees for the rating or whose staff conduct any portion of the rating.
Comment #39Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 5Paragraph / Figure / Table / Note: 103.1Comment Intent: ObjectionComment Type: TechnicalComment: The terminology for Rating Providers needs to be simplified and made more consistent. Direct Rating Providers should no longer be referred to as "Quality Assurance" providers. Using the term "Quality Assurance" to refer to so many different categories of companies is also confusing. Also, instead of using two new terms for a Direct Rating Provider, it should be simplified to a single term, "Direct Rating Provider". This change will need to be made throughout the standards. Proposed Change: 103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. 103.1.1 Direct Rating Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. 103.1.2 RESNET will provide a list of RESNET-approved Quality Assurance Contractors from which Direct Rating Providers may select. 103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Rating Providers, and the Quality Agents they employ, will have no financial interest in the Direct Rating Provider company, the Direct Rating Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Rating Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Rating Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Rating Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Rating Provider. 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Rating Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. In the interest of time involved in pointing out every section where this term should be updated, please accept this proposed change as referring to all other sections within the standards where the terms "Direct Quality Assurance Rating Provider" and "Direct Provider" are being proposed by this amendment. Response: Reject This edit changes the intent of the standard in relation to all types of quality assurance providers
The terminology for Rating Providers needs to be simplified and made more consistent. Direct Rating Providers should no longer be referred to as "Quality Assurance" providers. Using the term "Quality Assurance" to refer to so many different categories of companies is also confusing. Also, instead of using two new terms for a Direct Rating Provider, it should be simplified to a single term, "Direct Rating Provider". This change will need to be made throughout the standards.
103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. 103.1.1 Direct Rating Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. 103.1.2 RESNET will provide a list of RESNET-approved Quality Assurance Contractors from which Direct Rating Providers may select. 103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Rating Providers, and the Quality Agents they employ, will have no financial interest in the Direct Rating Provider company, the Direct Rating Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Rating Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Rating Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Rating Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Rating Provider. 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Rating Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest.
In the interest of time involved in pointing out every section where this term should be updated, please accept this proposed change as referring to all other sections within the standards where the terms "Direct Quality Assurance Rating Provider" and "Direct Provider" are being proposed by this amendment.
This edit changes the intent of the standard in relation to all types of quality assurance providers
Comment #40Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1Comment Intent: ObjectionComment Type: GeneralComment: Throughout the document the term "Rating Quality Assurance Provider" should be changed to just "Direct Provider". Calling a Provider type that does not perform any QA a QA provider is just confusing. They should be called direct providers. Response: Reject This edit changes the intent of the standard in relation to all types of quality assurance providers.
Throughout the document the term "Rating Quality Assurance Provider" should be changed to just "Direct Provider".
Calling a Provider type that does not perform any QA a QA provider is just confusing. They should be called direct providers.
This edit changes the intent of the standard in relation to all types of quality assurance providers.
Comment #41Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 5Paragraph / Figure / Table / Note: 103.1 & 103.2Comment Intent: ObjectionComment Type: GeneralComment: I have an issue with separating QA Providers into two separate categories- to the general public it could be confusing and still not eliminate the bias that is in place with a 'direct' provider. If you want the best kind of 'quality assurance', have it be a completely independent third-party. Proposed Change: I move to completely strike a "Direct Rating Quality Assurance Provider" and all related mention of it from the proposed standards. 103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. 103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. 103.1.2 RESNET will provide a list of RESNET-approved Quality Assurance Contractors from which Direct Providers may select. 103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Providers, and the Quality Agents they employ, will have no financial interest in the Direct Provider company, the Direct Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work. 103.2.3 An organization who is a Third-Party Rating Quality Assurance Provider may also have a separate Direct Rating Quality Assurance Providership. However, quality assurance of the Direct Provider’s work shall not be performed by the organization’s Third-party Rating Quality Assurance Providership. 103.2.5 Two organizations that are both a Third-Party Rating Quality Assurance Provider and Direct Rating Quality Assurance Provider shall not exchange quality assurance services specified in these Standards. 103.3 Rating Quality Assurance Provider Responsibilities. All accredited Direct and Third-Party Home Energy Rating Quality Assurance Providers shall have the following minimum responsibilities: 103.4.2 To apply for accreditation as a RESNET Rating Quality Assurance Provider, applicants must complete an accreditation application developed by RESNET that will demonstrate their understanding of the responsibilities of being a Direct Provider or Third-party Provider. Direct Rating Quality Assurance Provider (Direct Provider) – A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. Quality Assurance Provider – See Direct Rating Quality Assurance Provider and Third-party Rating Quality Assurance Provider Response: Reject Contradicts board policy on quality assurance
I have an issue with separating QA Providers into two separate categories- to the general public it could be confusing and still not eliminate the bias that is in place with a 'direct' provider. If you want the best kind of 'quality assurance', have it be a completely independent third-party.
I move to completely strike a "Direct Rating Quality Assurance Provider" and all related mention of it from the proposed standards.
103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. 103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. 103.1.2 RESNET will provide a list of RESNET-approved Quality Assurance Contractors from which Direct Providers may select. 103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Providers, and the Quality Agents they employ, will have no financial interest in the Direct Provider company, the Direct Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work.
103.2.3 An organization who is a Third-Party Rating Quality Assurance Provider may also have a separate Direct Rating Quality Assurance Providership. However, quality assurance of the Direct Provider’s work shall not be performed by the organization’s Third-party Rating Quality Assurance Providership.
103.2.5 Two organizations that are both a Third-Party Rating Quality Assurance Provider and Direct Rating Quality Assurance Provider shall not exchange quality assurance services specified in these Standards.
103.3 Rating Quality Assurance Provider Responsibilities. All accredited Direct and Third-Party Home Energy Rating Quality Assurance Providers shall have the following minimum responsibilities:
103.4.2 To apply for accreditation as a RESNET Rating Quality Assurance Provider, applicants must complete an accreditation application developed by RESNET that will demonstrate their understanding of the responsibilities of being a Direct Provider or Third-party Provider.
Direct Rating Quality Assurance Provider (Direct Provider) – A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating.
Quality Assurance Provider – See Direct Rating Quality Assurance Provider and Third-party Rating Quality Assurance Provider
Contradicts board policy on quality assurance
Comment #42Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1 - 5Paragraph / Figure / Table / Note: 103.1 - 103.1.3Comment Intent: ObjectionComment Type: GeneralComment: The current system works well when the requirements are properly followed. It can be made better but to re-invent the process may not be the best course of action. We are in favor of the previous proposal as follows: Direct Providers should be allowed to perform internal quality management if they are ISO-9001 certified. Proposed Change: Strike the following language in its entirety: 103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. 103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. 103.1.2 RESNET will provide a list of RESNET-approved Quality Assurance Contractors from which Direct Providers may select. 103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Providers, and the Quality Agents they employ, will have no financial interest in the Direct Provider company, the Direct Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work. Replace with: 103.1 Direct Rating Quality Assurance Provider (Direct Provider). Provider who receives fees for the rating or whose staff conduct any portion of the rating and who is ISO-9001 certified. Response: Reject Proposing a third class of providership, that is a direct providership that has ISO-9001 certification which does not meet the criteria established in the RESNET Board policy that Quality Assurance Designees act as agents of RESNET. Any determination of equivalency between that policy and ISO-9001 certification would have to be made at the board level.
The current system works well when the requirements are properly followed. It can be made better but to re-invent the process may not be the best course of action.
We are in favor of the previous proposal as follows:
Direct Providers should be allowed to perform internal quality management if they are ISO-9001 certified.
Strike the following language in its entirety:
103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization.
103.1.2 RESNET will provide a list of RESNET-approved Quality Assurance Contractors from which Direct Providers may select.
103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Providers, and the Quality Agents they employ, will have no financial interest in the Direct Provider company, the Direct Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest.
103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work.
103.1 Direct Rating Quality Assurance Provider (Direct Provider). Provider who receives fees for the rating or whose staff conduct any portion of the rating and who is ISO-9001 certified.
Proposing a third class of providership, that is a direct providership that has ISO-9001 certification which does not meet the criteria established in the RESNET Board policy that Quality Assurance Designees act as agents of RESNET. Any determination of equivalency between that policy and ISO-9001 certification would have to be made at the board level.
Comment #43Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1-103.1.3Comment Intent: ObjectionComment Type: GeneralComment: Direct Providers should be allowed to perform internal quality management if they are ISO-9001 certified. Proposed Change: Strike the following language in its entirety: 103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. 103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. 103.1.2 RESNET will provide a list of RESNET-approved Quality Assurance Contractors from which Direct Providers may select. 103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Providers, and the Quality Agents they employ, will have no financial interest in the Direct Provider company, the Direct Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work. Replace with: 103.1 Direct Rating Quality Assurance Provider (Direct Provider). Provider who receives fees for the rating or whose staff conduct any portion of the rating and who is ISO-9001 certified. Response: Reject Proposing a third class of providership, that is a direct providership that has ISO-9001 certification which does not meet the criteria established in the RESNET Board policy that Quality Assurance Designees act as agents of RESNET. Any determination of equivalency between that policy and ISO-9001 certification would have to be made at the board level.
Comment #44Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1-103.1.3Comment Intent: Not an ObjectionComment Type: GeneralComment: Would there be any consideration by the SDC to consider an “exemption” proposal to the changes on Direct QA Providers? And that exemption be that the Direct QA Provider company be certified (and provide RESNET annual documentation proving active certification) as an ISO-9001 company. The ISO-9001 certification is a very well established and rigid system for a company to control their Total Quality Management and Quality Assurance with an annual peer review requirement. Proposed Change: Add: 103.1.4 Direct Providers should be allowed to perform internal quality assurance management if they are ISO-9001 certified and provide RESNET annual documentation proving active certification as an ISO-9001 certified company. Response: Reject Proposing a third class of providership, that is a direct providership that has ISO-9001 certification which does not meet the criteria established in the RESNET Board policy that Quality Assurance Designees act as agents of RESNET. Any determination of equivalency between that policy and ISO-9001 certification would have to be made at the board level.
Would there be any consideration by the SDC to consider an “exemption” proposal to the changes on Direct QA Providers? And that exemption be that the Direct QA Provider company be certified (and provide RESNET annual documentation proving active certification) as an ISO-9001 company. The ISO-9001 certification is a very well established and rigid system for a company to control their Total Quality Management and Quality Assurance with an annual peer review requirement.
Add:
103.1.4 Direct Providers should be allowed to perform internal quality assurance management if they are ISO-9001 certified and provide RESNET annual documentation proving active certification as an ISO-9001 certified company.
Comment #45Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 5Paragraph / Figure / Table / Note: 103.1.1Comment Intent: ObjectionComment Type: TechnicalComment: If a Direct Provider has to have a completely independent Quality Assurance Contractor...why does this accreditation exist? It only serves to complicate the current landscape, which is already mangled with a ridiculous number of certifications and accreditations. If a Direct Provider has an independent party over-looking their QA process, why does this accreditation exist? 103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. Proposed Change: I move to completely strike a "Direct Rating Quality Assurance Provider" and all related mention of it from the proposed standards. 103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. 103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. 103.1.2 RESNET will provide a list of RESNET-approved Quality Assurance Contractors from which Direct Providers may select. 103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Providers, and the Quality Agents they employ, will have no financial interest in the Direct Provider company, the Direct Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work. 103.2.3 An organization who is a Third-Party Rating Quality Assurance Provider may also have a separate Direct Rating Quality Assurance Providership. However, quality assurance of the Direct Provider’s work shall not be performed by the organization’s Third-party Rating Quality Assurance Providership. 103.2.5 Two organizations that are both a Third-Party Rating Quality Assurance Provider and Direct Rating Quality Assurance Provider shall not exchange quality assurance services specified in these Standards. 103.3 Rating Quality Assurance Provider Responsibilities. All accredited Direct and Third-Party Home Energy Rating Quality Assurance Providers shall have the following minimum responsibilities: 103.4.2 To apply for accreditation as a RESNET Rating Quality Assurance Provider, applicants must complete an accreditation application developed by RESNET that will demonstrate their understanding of the responsibilities of being a Direct Provider or Third-party Provider. Direct Rating Quality Assurance Provider (Direct Provider) – A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. Quality Assurance Provider – See Direct Rating Quality Assurance Provider and Third-party Rating Quality Assurance Provider Response: Accept Accept 103.1.3.1 and 103.1.3.1.1 only. 103.1.3.1.2 does not seem to be enforceable
If a Direct Provider has to have a completely independent Quality Assurance Contractor...why does this accreditation exist? It only serves to complicate the current landscape, which is already mangled with a ridiculous number of certifications and accreditations.
If a Direct Provider has an independent party over-looking their QA process, why does this accreditation exist?
Accept 103.1.3.1 and 103.1.3.1.1 only. 103.1.3.1.2 does not seem to be enforceable
Comment #46Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1.1Comment Intent: ObjectionComment Type: GeneralComment: What does this provision mean? The terminology is very similar between types of Providers here, and, elsewhere in the Standard, the term Provider is used on its own. Does "Provider" always include all types of possible providers unless specified? Can we agree that all positions defined in this Standard are either certified or accredited by RESNET and drop that repetitive language? That umbrella statement needs to occur at the beginning of the Standards and only once. The specific responsibilities and obligations of Direct Providers and Quality Assurance Contractors remains unclear to me, even after reading the entire document that is up for comment. It's certainly not practicable as written. Proposed Change: 103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. Response: Reject This is already addressed in the proposed standard amendment
What does this provision mean? The terminology is very similar between types of Providers here, and, elsewhere in the Standard, the term Provider is used on its own. Does "Provider" always include all types of possible providers unless specified?
Can we agree that all positions defined in this Standard are either certified or accredited by RESNET and drop that repetitive language? That umbrella statement needs to occur at the beginning of the Standards and only once.
The specific responsibilities and obligations of Direct Providers and Quality Assurance Contractors remains unclear to me, even after reading the entire document that is up for comment. It's certainly not practicable as written.
This is already addressed in the proposed standard amendment
Comment #47Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1.1-103.1.2.2Comment Intent: ObjectionComment Type: GeneralComment: This section identifies a Quality Assurance Contractor as an entity that must be hired by the Direct Provider to oversee compliance, but fails to establish what the requirements are for such an entity to be accredited by RESNET. For example, Third-party Providers are required to demonstrate proof of insurance (liability and errors and omissions) while Direct Providers and Quality Assurance Contractors are not. This is in direct contradiction of the RESNET Board's decision to not favor one business model over another. This standard clearly favors the Direct Provider model over the Third-party Provider model when the Third-party Provider requirements are more stringent than the non-existent requirements for QA Contractors. Proposed Change: Insert the following language and renumber accordingly: 103.1.2.1 Quality Assurance Contractors must employ one or more Quality Agents certified by RESNET. The Quality Agent will oversee the Direct Provider’s compliance with Chapter 9 of these Standards and any specific quality assurance requirements for other Provider categories that may apply to the organization. 103.1.2.2 Other than compensation for services necessary for the fulfillment of the Rating Provider, quality assurance requirements specified in these Standards, and other non-HERS rating related services (e.g. LEED for Homes Provider fees), Quality Assurance Contractors and the Quality Agents they employ, or contract with, will have no financial interest in their Direct Provider clients, or any ratings completed by HERS Raters working with their Direct Providere clients. 103.1.2.3 Quality Assurance Contractors shall demonstrate to RESNET a minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage. Response: Accept
This section identifies a Quality Assurance Contractor as an entity that must be hired by the Direct Provider to oversee compliance, but fails to establish what the requirements are for such an entity to be accredited by RESNET.
For example, Third-party Providers are required to demonstrate proof of insurance (liability and errors and omissions) while Direct Providers and Quality Assurance Contractors are not. This is in direct contradiction of the RESNET Board's decision to not favor one business model over another. This standard clearly favors the Direct Provider model over the Third-party Provider model when the Third-party Provider requirements are more stringent than the non-existent requirements for QA Contractors.
Insert the following language and renumber accordingly:
103.1.2.1 Quality Assurance Contractors must employ one or more Quality Agents certified by RESNET. The Quality Agent will oversee the Direct Provider’s compliance with Chapter 9 of these Standards and any specific quality assurance requirements for other Provider categories that may apply to the organization.
103.1.2.2 Other than compensation for services necessary for the fulfillment of the Rating Provider, quality assurance requirements specified in these Standards, and other non-HERS rating related services (e.g. LEED for Homes Provider fees), Quality Assurance Contractors and the Quality Agents they employ, or contract with, will have no financial interest in their Direct Provider clients, or any ratings completed by HERS Raters working with their Direct Providere clients.
103.1.2.3 Quality Assurance Contractors shall demonstrate to RESNET a minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage.
Comment #48Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1.1-103.1.3Comment Intent: ObjectionComment Type: GeneralComment: This section creates a complicated solution to a complex problem and an additional layer of confusion. There already exists an entity that qualifies as a QA Contractor- why not simply refer to that existing entity instead of creating another one that does the same thing? Proposed Change: Strike the following language in its entirety: 103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. 103.1.2 RESNET will provide a list of RESNET-approved Quality Assurance Contractors from which Direct Providers may select. 103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Providers, and the Quality Agents they employ, will have no financial interest in the Direct Provider company, the Direct Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work. Replace with: 103.1.1 Direct Providers must contract with one or more Third-party Providers who shall oversee the Direct Provider's compliance with Chapter 9 of these Standards. Response: Reject Proposing a model that eliminates the business model of quality assurance contractors/direct rating providers
This section creates a complicated solution to a complex problem and an additional layer of confusion.
There already exists an entity that qualifies as a QA Contractor- why not simply refer to that existing entity instead of creating another one that does the same thing?
103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. 103.1.2 RESNET will provide a list of RESNET-approved Quality Assurance Contractors from which Direct Providers may select. 103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Providers, and the Quality Agents they employ, will have no financial interest in the Direct Provider company, the Direct Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work.
103.1.1 Direct Providers must contract with one or more Third-party Providers who shall oversee the Direct Provider's compliance with Chapter 9 of these Standards.
Proposing a model that eliminates the business model of quality assurance contractors/direct rating providers
Comment #49Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 5Paragraph / Figure / Table / Note: 103.1.2.1Comment Intent: Not an ObjectionComment Type: GeneralComment: These sets of rules need to include the possibity of two Third Party and Direct Rating QA Providers from hiring each others Agents to perform QA in a reciprocal manner. Proposed Change: 103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Providers, and the Quality Agents they employ, will have no financial interest in the Direct Provider company, the Direct Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. Response: Reject Accept in principle and language will be drafted to specifically address the issue of reciprocal QA between two third party providers. Add to section 103.2.2
These sets of rules need to include the possibity of two Third Party and Direct Rating QA Providers from hiring each others Agents to perform QA in a reciprocal manner.
103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Providers, and the Quality Agents they employ, will have no financial interest in the Direct Provider company, the Direct Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider.
Accept in principle and language will be drafted to specifically address the issue of reciprocal QA between two third party providers. Add to section 103.2.2
Comment #50Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5, 1-6Paragraph / Figure / Table / Note: 103.1.2.1, 103.1.3, 103.2.1, 103.2.3Comment Intent: Not an ObjectionComment Type: GeneralComment: There appears to be some confusion in the wording concerning "financial interest" between a Direct Provider and Third Party Provider. It states that a DP is allowed to have a separate TP. However, a DP can have no financial interest in a Quality Assurance Contractor or Quality Agent while a TP must employ a Quality Assurance Contractor or Quality Agent. This appears to be a conflict since if the the DP had a separate TP they would have a financial interest in the QAC or QA that was employed by the TP. Please clear up this confusion. Proposed Change: N/A Just a general comment Response: Reject No proposed language and is in alignment with the board of directors policy that was clarified further at another board meeting on September 12, 2016
There appears to be some confusion in the wording concerning "financial interest" between a Direct Provider and Third Party Provider.
It states that a DP is allowed to have a separate TP. However, a DP can have no financial interest in a Quality Assurance Contractor or Quality Agent while a TP must employ a Quality Assurance Contractor or Quality Agent.
This appears to be a conflict since if the the DP had a separate TP they would have a financial interest in the QAC or QA that was employed by the TP.
Please clear up this confusion.
N/A Just a general comment
No proposed language and is in alignment with the board of directors policy that was clarified further at another board meeting on September 12, 2016
Comment #51Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 5Paragraph / Figure / Table / Note: 103.1.2.1.1Comment Intent: ObjectionComment Type: GeneralComment: I have a problem with the highlighted proposed standard: 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: What is the job description of the QA Manager? I'm asking this because if there is an "equivalent" position to the QA Manager perhaps we should rethink the duties and description of the QA Manager position. Try to get rid of redundancies in the system. Proposed Change: 103.1.2.1.1 RESNET Staff ( The RESNET QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: Response: Accept
I have a problem with the highlighted proposed standard:
103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include:
What is the job description of the QA Manager? I'm asking this because if there is an "equivalent" position to the QA Manager perhaps we should rethink the duties and description of the QA Manager position. Try to get rid of redundancies in the system.
103.1.2.1.1 RESNET Staff ( The RESNET QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include:
Comment #52Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1.2.1.1Comment Intent: ObjectionComment Type: GeneralComment: RESNET is creating a business opportunity in some areas of the country by making these changes. An individual may decide to to take a business risk and start a QA company or work for another as a QA person. Because many areas have a small network of people in this industry it may be quite likely a past business realtionship exists. If a QA contractor is unjustly denied ability to work with a provider due only to a past relationship that makes RESNET uncomfortable that is a very unfortunate result. RESNET doing their job of QA company oversight and holding their agents accountable should lead to identifying any possible corruption and thus there should be no reason a past buniness relationship matters at all. This is language is too open and all powerful to RESNET. Don't penalize the many honest people doing this work for the actions of a minority. Proposed Change: 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. Response: Reject Conflict of interest provisions need to be in place in order to protect RESNET and all parties. This is in keeping with stated board policy. The SDC cannot act in contradiction to board policy. Full disclosure and transparency will not necessarily disqualify a QA contractor working with a direct provider.
RESNET is creating a business opportunity in some areas of the country by making these changes. An individual may decide to to take a business risk and start a QA company or work for another as a QA person. Because many areas have a small network of people in this industry it may be quite likely a past business realtionship exists. If a QA contractor is unjustly denied ability to work with a provider due only to a past relationship that makes RESNET uncomfortable that is a very unfortunate result.
RESNET doing their job of QA company oversight and holding their agents accountable should lead to identifying any possible corruption and thus there should be no reason a past buniness relationship matters at all. This is language is too open and all powerful to RESNET. Don't penalize the many honest people doing this work for the actions of a minority.
103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider.
Conflict of interest provisions need to be in place in order to protect RESNET and all parties. This is in keeping with stated board policy. The SDC cannot act in contradiction to board policy. Full disclosure and transparency will not necessarily disqualify a QA contractor working with a direct provider.
Comment #53Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 5 (1-5)Paragraph / Figure / Table / Note: 103.1.2.1.1Comment Intent: ObjectionComment Type: GeneralComment: RESNET is creating a business opportunity in some areas of the country by making these changes. An individual may decide to to take a business risk and start a QA company or work for another as a QA person. Because many areas have a small network of people in this industry it may be quite likely a past business realtionship exists. If a QA contractor is unjustly denied ability to work with a provider due only to a past relationship that makes RESNET uncomfortable that is a very unfortunate result. RESNET doing their job of QA company oversight and holding their agents accountable should lead to identifying any possible corruption and thus there should be no reason a past buniness relationship matters at all. This is language is too open and all powerful to RESNET. Don't penalize the many honest people doing this work for the actions of a minority. I copied this from comment #64, Ditto. Proposed Change: 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. Response: Reject Conflict of interest provisions need to be in place in order to protect RESNET and all parties. This is in keeping with stated board policy. The SDC cannot act in contradiction to board policy. Full disclosure and transparency will not necessarily disqualify a QA contractor working with a direct provider.
I copied this from comment #64, Ditto.
Comment #54Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 5Paragraph / Figure / Table / Note: 103.1.2.1.1.2Comment Intent: Not an ObjectionComment Type: TechnicalComment: I think this is an excellent point, but I would like to see an additional point added to the proposed standard. This would also change the numbers of the proposed standard- see below: Proposed Change: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships between the owners of the QA Contracting Company and Direct Provider. 103.1.2.1.1.23 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.34 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. Response: Reject Redundant and covered in existing section 103.1.2.1.1.2
I think this is an excellent point, but I would like to see an additional point added to the proposed standard. This would also change the numbers of the proposed standard- see below:
103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET.
103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships between the owners of the QA Contracting Company and Direct Provider.
103.1.2.1.1.23 Require a full disclosure of any existing or prior business relationships with any potential contracted entity.
103.1.2.1.1.34 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider.
Redundant and covered in existing section 103.1.2.1.1.2
Comment #55Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1.2.1.1.3Comment Intent: ObjectionComment Type: GeneralComment: RESNET cannot decide who may or may not be employed by a QA Contractor outside of the minimum requirements to be certified as a QA Agent. This is unnecessarily restrictive and discriminatory. By the way, if a commenter comments to strike language without replacement, the comment cannot be dismissed because no replacement language was suggested. That is not a proper response to a comment. Bad ideas are bad ideas and do not necessarily require another idea to replace them. Proposed Change: Strike this language in its entirety: 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. Do NOT replace. Response: Reject Conflict of interest provisions need to be in place in order to protect RESNET and all parties. This is in keeping with stated board policy. The SDC cannot act in contradiction to board policy. Full disclosure and transparency will not necessarily disqualify a QA contractor working with a direct provider.
RESNET cannot decide who may or may not be employed by a QA Contractor outside of the minimum requirements to be certified as a QA Agent. This is unnecessarily restrictive and discriminatory.
By the way, if a commenter comments to strike language without replacement, the comment cannot be dismissed because no replacement language was suggested. That is not a proper response to a comment. Bad ideas are bad ideas and do not necessarily require another idea to replace them.
103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider.
Do NOT replace.
Comment #56Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1.2.1.1.3Comment Intent: Not an ObjectionComment Type: GeneralComment: What will RESNET do with this information? Is it an automatic disqualifier, or just an additive piece of information that is taken into account for marginal situations? Proposed Change: N/A Just a question Response: Reject No proposed change suggested. Conflict of interest provisions need to be in place in order to protect RESNET and all parties. This is in keeping with stated board policy. The SDC cannot act in contradiction to board policy. Full disclosure and transparency will not necessarily disqualify a QA contractor working with a direct provider.
What will RESNET do with this information? Is it an automatic disqualifier, or just an additive piece of information that is taken into account for marginal situations?
No proposed change suggested. Conflict of interest provisions need to be in place in order to protect RESNET and all parties. This is in keeping with stated board policy. The SDC cannot act in contradiction to board policy. Full disclosure and transparency will not necessarily disqualify a QA contractor working with a direct provider.
Comment #57Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1.2.2Comment Intent: ObjectionComment Type: GeneralComment: This section is vague and can broadly restrict trade. The regulatory entity in this case is RESNET, represented by the Board of Directors, but this section does not identify precisely who may place restrictions on QA Contractor selection. Is this decision maker RESNET Staff, the Accreditation Committee, or the Board of Directors, or the Executive Committee, or the Executive Director? If it is RESNET Staff, who is it? The criteria for placing restrictions is non-existent and therefore unenforceable. Perceived conflicts of interest? From whose perspective? This section goes well beyond the mandate provided by the Board of Directors. Proposed Change: Strike this language in its entirety: 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. Do NOT replace. Response: Accept
This section is vague and can broadly restrict trade. The regulatory entity in this case is RESNET, represented by the Board of Directors, but this section does not identify precisely who may place restrictions on QA Contractor selection. Is this decision maker RESNET Staff, the Accreditation Committee, or the Board of Directors, or the Executive Committee, or the Executive Director? If it is RESNET Staff, who is it?
The criteria for placing restrictions is non-existent and therefore unenforceable. Perceived conflicts of interest? From whose perspective?
This section goes well beyond the mandate provided by the Board of Directors.
103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest.
Comment #58Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 5Paragraph / Figure / Table / Note: 103.1.3Comment Intent: ObjectionComment Type: TechnicalComment: Again, why does this particular accreditation exist if they have an independent QA Contractor Company and can have a third-party QA Providership? It only serves to confuse consumers, Raters, and does nothing beneficial for the industry. Proposed Change: I move to completely strike a "Direct Rating Quality Assurance Provider" and all related mention of it from the proposed standards. 103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. 103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. 103.1.2 RESNET will provide a list of RESNET-approved Quality Assurance Contractors from which Direct Providers may select. 103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Providers, and the Quality Agents they employ, will have no financial interest in the Direct Provider company, the Direct Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following to determine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work. 103.2.3 An organization who is a Third-Party Rating Quality Assurance Provider may also have a separate Direct Rating Quality Assurance Providership. However, quality assurance of the Direct Provider’s work shall not be performed by the organization’s Third-party Rating Quality Assurance Providership. 103.2.5 Two organizations that are both a Third-Party Rating Quality Assurance Provider and Direct Rating Quality Assurance Provider shall not exchange quality assurance services specified in these Standards. 103.3 Rating Quality Assurance Provider Responsibilities. All accredited Direct and Third-Party Home Energy Rating Quality Assurance Providers shall have the following minimum responsibilities: 103.4.2 To apply for accreditation as a RESNET Rating Quality Assurance Provider, applicants must complete an accreditation application developed by RESNET that will demonstrate their understanding of the responsibilities of being a Direct Provider or Third-party Provider. Direct Rating Quality Assurance Provider (Direct Provider) – A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. Quality Assurance Provider – See Direct Rating Quality Assurance Provider and Third-party Rating Quality Assurance Provider Response: Reject Is not in alignment with the board of directors policy
Again, why does this particular accreditation exist if they have an independent QA Contractor Company and can have a third-party QA Providership? It only serves to confuse consumers, Raters, and does nothing beneficial for the industry.
Is not in alignment with the board of directors policy
Comment #59Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 5Paragraph / Figure / Table / Note: 103.1.3Comment Intent: ObjectionComment Type: TechnicalComment: Comment: Again, why does this particular accreditation exist if they have an independent QA Contractor Company and can have a third-party QA Providership? It only serves to confuse consumers, Raters, and does nothing beneficial for the industry. Response: Reject Is not in alignment with the board of directors policy
Comment:
Comment #60Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1.3Comment Intent: Not an ObjectionComment Type: GeneralComment: The language for this requirement which allows a Provider to have separate Direct Rating and Third Party Providerships needs to be expanded to include more information on how RESNET will handle the fees and accreditation application process. Response: Reject No proposed change suggested. Fees and accreditation will be handled through policy rather than through standards.
The language for this requirement which allows a Provider to have separate Direct Rating and Third Party Providerships needs to be expanded to include more information on how RESNET will handle the fees and accreditation application process.
No proposed change suggested. Fees and accreditation will be handled through policy rather than through standards.
Comment #61Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1.3Comment Intent: ObjectionComment Type: GeneralComment: This section is unnecessary and adds complicatedness. Direct Providers and Third-party Providers were created by the RESNET Board of Directors to prevent any financial entanglements between the quality management of ratings and the entities performing the ratings. With this one section, those distinctions are blurred. Providing an exception does not make it more clear. Proposed Change: Strike this language in its entirety: 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work. Do NOT replace. Response: Reject Is not in alignment with the board of directors policy that was clarified further at another board meeting on September 12, 2016
This section is unnecessary and adds complicatedness. Direct Providers and Third-party Providers were created by the RESNET Board of Directors to prevent any financial entanglements between the quality management of ratings and the entities performing the ratings. With this one section, those distinctions are blurred. Providing an exception does not make it more clear.
Is not in alignment with the board of directors policy that was clarified further at another board meeting on September 12, 2016
Comment #62Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1.3Comment Intent: ObjectionComment Type: EditorialComment: 103.1.2.1 states that “RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor…” • 103.1.2.1.1.1 requires the QA Manager to identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. • 103.1.2.1.1.2 requires the QA Manager to obtain a full disclosure of any existing or prior business relationships with any potential contracted entity. • 103.1.2.1.1.3 requires the QA Manager to review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. • 103.1.3 states a Direct Rating QA Provider may also have a separate Third-Party Rating QA Providership, but they cannot perform QA of their own work. • There is no wording in the standard to protect trade secrets, or prevents other Third-Party Rating QA Providers from poaching clients during a field QA. Proposed Change: 103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. 103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. 103.1.2 RESNET will provide a list of RESNET-approved Quality Assurance Contractors from which Direct Providers may select. 103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Providers, and the Quality Agents they employ, will have no financial interest in the Direct Provider company, the Direct Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following todetermine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work. • Recommend adding the following subsections and language: o 103.1.3.1 An organization who is a Direct Rating Quality Assurance Provider providing Third-Party Rating Quality Assurance services for a Rating company or another Direct Rating Quality Assurance Provider shall not willfully cause a conflict of interest such as, but not limited to the following: ? 103.1.3.1.1 Shall not solicit the clients of the company on which Quality Assurance is being performed. ? 103.1.3.1.2 Shall protect the trade secrets, services, and any other information that could reasonably be determined necessary to that businesses’ operations and would be harmful to that businesses’ ability to remain competitive in the market if exposed. Response: Accept Accept 103.1.3.1 and 103.1.3.1.1 only. 103.1.3.1.2 does not seem to be enforceable
103.1.2.1 states that “RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor…” • 103.1.2.1.1.1 requires the QA Manager to identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. • 103.1.2.1.1.2 requires the QA Manager to obtain a full disclosure of any existing or prior business relationships with any potential contracted entity. • 103.1.2.1.1.3 requires the QA Manager to review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. • 103.1.3 states a Direct Rating QA Provider may also have a separate Third-Party Rating QA Providership, but they cannot perform QA of their own work. • There is no wording in the standard to protect trade secrets, or prevents other Third-Party Rating QA Providers from poaching clients during a field QA.
103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. 103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. 103.1.2 RESNET will provide a list of RESNET-approved Quality Assurance Contractors from which Direct Providers may select. 103.1.2.1 Other than compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, Quality Assurance Contractors for Direct Providers, and the Quality Agents they employ, will have no financial interest in the Direct Provider company, the Direct Provider’s employed Raters and Rating Company clients, or any ratings completed by HERS Raters working with the Direct Provider. 103.1.2.1.1 RESNET Staff (QA Manager or equivalent) will be required to approve a Direct Providers selected QA Contractor and review the following todetermine actual or perceived conflict of interest. This shall at a minimum include: 103.1.2.1.1.1 Identify the owners of the QA Contracting Company and Direct Provider and require that each owner complete a Financial Interest Disclosure Form provided by RESNET. 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity. 103.1.2.1.1.3 Review the RESNET Registry of all QA Agents of a QA Contracting Company to determine whether there was any past work history with the Direct Provider. 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work.
• Recommend adding the following subsections and language:
o 103.1.3.1 An organization who is a Direct Rating Quality Assurance Provider providing Third-Party Rating Quality Assurance services for a Rating company or another Direct Rating Quality Assurance Provider shall not willfully cause a conflict of interest such as, but not limited to the following: ? 103.1.3.1.1 Shall not solicit the clients of the company on which Quality Assurance is being performed. ? 103.1.3.1.2 Shall protect the trade secrets, services, and any other information that could reasonably be determined necessary to that businesses’ operations and would be harmful to that businesses’ ability to remain competitive in the market if exposed.
Comment #63Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-5Paragraph / Figure / Table / Note: 103.1.3Comment Intent: ObjectionComment Type: GeneralComment: Comment- Section 103.1.3.1 allowing third party providers to have a separate direct providership does not meet the intent of original policy on quality agents approved by the board of directors even with a separation in quality assurance performed for the direct providership. Ensuring that there is truly no conflict of interest regarding the two divisions of the providership would be difficult to document. The original board policy states- RESNET certified Quality Assurance Designees must in the future: o Have neither a financial interest nor an employee/employer relationship with the entity performing the rating Proposed change- Strike in entirely- 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work. Proposed Change: Proposed change- Strike in entirely- 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work. Response: Reject Is not in alignment with the board of directors policy that was clarified further at another board meeting on September 12, 2016
Comment- Section 103.1.3.1 allowing third party providers to have a separate direct providership does not meet the intent of original policy on quality agents approved by the board of directors even with a separation in quality assurance performed for the direct providership. Ensuring that there is truly no conflict of interest regarding the two divisions of the providership would be difficult to document. The original board policy states- RESNET certified Quality Assurance Designees must in the future: o Have neither a financial interest nor an employee/employer relationship with the entity performing the rating Proposed change- Strike in entirely- 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work.
Proposed change- Strike in entirely- 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work.
Comment #64Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 5Paragraph / Figure / Table / Note: 103.1.3Comment Intent: ObjectionComment Type: GeneralComment: The section above eliminates the need for restriction to be placed on the Quality Assurance Contractor, which will allow the market to decide who is best fit for QA Contractor services. Excluding QA Agents in Direct Rating Quality Assurance Providership’ s from also preforming ratings is unnecessary to meeting the burden of proof in the proposed definition of financial interest. I would remove this sections as I believe it causes an undue burden on the Direct Rating Quality Assurance Providership’ s as well as on the Quality Assurance Contractor. From the QAC perspective this section would require the QAC to “give-up” doing ratings to be a QA Agent and/or QA Contractor. In this new structure the QAC may not be the most experienced rater on one’s staff and providers are losing the ability to offer paths of advancement and professional grow to their rater staff. In addition, we have found that it is particularly beneficial for raters to understand the rating process from the both the rater and QA agents perspective. That each approach to a rating is unique and that by doing both the individual actually becomes better at what they do. Collaboration with other raters in this process, and exposure to processes and markets that are new to the Raters/QA Agents is extremely beneficial to the Providership, the Rater/QA Agent, and to RESNETs proposed new QA structure. The Raters who do QA for us, consistently say they are much better at what they do because of the experience and perspective they have gained from doing both QA and rating work.. In reality allowing raters to perform QA, makes for better raters, ratings, and quality assurance. As long as there is a firewall between the rating side and the quality assurance side of a provider ship and an assurance that QA will always be performed by a third party, this troublesome section of the proposed language is not needed. Shifting to third party external QA is critical for our industry. Allowing Rating companies to also be QA Contractors and QA Agents to be Active Raters, allows the industry to more smoothly take this step forward in an effective and minimally disruptive manner. The QA Agent training will be a filtering mechanism to allow the best, most qualified raters to become QA Agents. Couple this with the approval process in section 103.1.2, whereby RESNET Staff reviews the conflicts of interest disclosures and we have a tremendously strong QA path in the process of approval of the QA relationship. Ensuring that we have strong companies that are blocked from conflict is the main purpose here. I see a path to achieving this goal that does not limit providers but rather ensures flexibility and viability as a company. Proposed Change: Proposed Change to Amendment: QA Agents 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; QA Contractors 905.1.3.45 Shall not provide other HERS rating services. Amendment: 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership and/or operate as a QA Contractor. However, the organization’s Third-Party Rating Quality Assurance Providership, QA Contractor Operation, and/or QA Agents may not perform RESNET quality assurance of the Direct Provider’s work. Response: Accept Accept in principle. Direct providers may have a separate third party providership that may be a QA contractor Revise to- 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may shall not perform quality assurance of the Direct Rating Provider’s work
The section above eliminates the need for restriction to be placed on the Quality Assurance Contractor, which will allow the market to decide who is best fit for QA Contractor services. Excluding QA Agents in Direct Rating Quality Assurance Providership’ s from also preforming ratings is unnecessary to meeting the burden of proof in the proposed definition of financial interest.
I would remove this sections as I believe it causes an undue burden on the Direct Rating Quality Assurance Providership’ s as well as on the Quality Assurance Contractor. From the QAC perspective this section would require the QAC to “give-up” doing ratings to be a QA Agent and/or QA Contractor. In this new structure the QAC may not be the most experienced rater on one’s staff and providers are losing the ability to offer paths of advancement and professional grow to their rater staff. In addition, we have found that it is particularly beneficial for raters to understand the rating process from the both the rater and QA agents perspective. That each approach to a rating is unique and that by doing both the individual actually becomes better at what they do. Collaboration with other raters in this process, and exposure to processes and markets that are new to the Raters/QA Agents is extremely beneficial to the Providership, the Rater/QA Agent, and to RESNETs proposed new QA structure. The Raters who do QA for us, consistently say they are much better at what they do because of the experience and perspective they have gained from doing both QA and rating work.. In reality allowing raters to perform QA, makes for better raters, ratings, and quality assurance. As long as there is a firewall between the rating side and the quality assurance side of a provider ship and an assurance that QA will always be performed by a third party, this troublesome section of the proposed language is not needed.
Shifting to third party external QA is critical for our industry. Allowing Rating companies to also be QA Contractors and QA Agents to be Active Raters, allows the industry to more smoothly take this step forward in an effective and minimally disruptive manner. The QA Agent training will be a filtering mechanism to allow the best, most qualified raters to become QA Agents. Couple this with the approval process in section 103.1.2, whereby RESNET Staff reviews the conflicts of interest disclosures and we have a tremendously strong QA path in the process of approval of the QA relationship. Ensuring that we have strong companies that are blocked from conflict is the main purpose here. I see a path to achieving this goal that does not limit providers but rather ensures flexibility and viability as a company.
Proposed Change to Amendment:
QA Agents 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; QA Contractors 905.1.3.45 Shall not provide other HERS rating services.
Amendment:
103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership and/or operate as a QA Contractor. However, the organization’s Third-Party Rating Quality Assurance Providership, QA Contractor Operation, and/or QA Agents may not perform RESNET quality assurance of the Direct Provider’s work.
Accept in principle. Direct providers may have a separate third party providership that may be a QA contractor Revise to- 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may shall not perform quality assurance of the Direct Rating Provider’s work
Comment #65Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6Paragraph / Figure / Table / Note: 103.2Comment Intent: ObjectionComment Type: GeneralComment: This definition does not meet the definition approved by the RESNET Board of Directors at the fall Board meeting in November 2014. The additional things listed that Third-party QA Providers can charge fees for is unnecessary. Proposed Change: Strike this language in its entirety: 103.2 Third-party Rating Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider whose employees are not allowed to conduct any portion of the work for a HERS rating but who may receive fees for performing quality assurance work as outlined in these Standards, quality assurance oversight, certification and other Quality Assurance Provider related duties. Replace with: 103.2 Third-party Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider who does not receive fees for the rating and whose staff do not conduct any portion of the rating. Response: Accept
This definition does not meet the definition approved by the RESNET Board of Directors at the fall Board meeting in November 2014.
The additional things listed that Third-party QA Providers can charge fees for is unnecessary.
103.2 Third-party Rating Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider whose employees are not allowed to conduct any portion of the work for a HERS rating but who may receive fees for performing quality assurance work as outlined in these Standards, quality assurance oversight, certification and other Quality Assurance Provider related duties.
103.2 Third-party Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider who does not receive fees for the rating and whose staff do not conduct any portion of the rating.
Comment #66Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 6Paragraph / Figure / Table / Note: 103.2 & subsectionsComment Intent: ObjectionComment Type: TechnicalComment: The terminology for Rating Providers needs to be simplified and made more consistent. Third-Party Rating Providers should no longer be referred to as "Quality Assurance" providers. Using the term "Quality Assurance" to refer to so many different categories of companies is also confusing. Also, instead of using two new terms for a Direct Rating Provider, it should be simplified to a single term, "Third-Party Rating Provider". This change will need to be made throughout the standards. Proposed Change: 103.2 Third-party Rating Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider whose employees are not allowed to conduct any portion of the work for a HERS rating but who may receive fees for performing quality assurance work as outlined in these Standards, quality assurance oversight, certification and other Quality Assurance Rating Provider related duties. 103.2.1 Third-party Rating Providers must employ one or more Quality Agents certified by RESNET. The Quality Agent will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific quality assurance requirements for other Provider categories that may apply to the organization. 103.2.2 Other than compensation for services necessary for the fulfillment of the Rating Provider, quality assurance requirements specified in these Standards, and other non-HERS rating related services (e.g. LEED for Homes Provider fees), Third-party Rating Providers and the Quality Agents they employ, or contract with, will have no financial interest in their HERS Rating Company clients, or any ratings completed by HERS Raters working with their HERS Rating Company clients. 103.2.3 An organization who is a Third-Party Rating Quality Assurance Provider may also have a separate Direct Rating Quality Assurance Providership. However, quality assurance of the Direct Rating Provider’s work shall not be performed by the organization’sThird-party Rating Quality Assurance Providership. 103.2.4 A Third-party Rating Quality Assurance Provider may also be a Quality Assurance Contractor. 103.4.1 Third-Party Rating Quality Assurance Providers shall demonstrate to RESNET a minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage. 103.2.5 Two organizations that are both a Third-Party Rating Quality Assurance Provider and Direct Rating Quality Assurance Provider shall not exchange quality assurance services specified in these Standards. In the interest of time involved in pointing out every section in which this terminology is referenced, please accept this proposed revision as referring to all sections throughout the standard in which the terms "Third-party Rating Quality Assurance Provider" and "Third-party Provider" are being proposed. Response: Reject This edit changes the intent of the standard in relation to all types of quality assurance providers
The terminology for Rating Providers needs to be simplified and made more consistent. Third-Party Rating Providers should no longer be referred to as "Quality Assurance" providers. Using the term "Quality Assurance" to refer to so many different categories of companies is also confusing. Also, instead of using two new terms for a Direct Rating Provider, it should be simplified to a single term, "Third-Party Rating Provider". This change will need to be made throughout the standards.
103.2 Third-party Rating Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider whose employees are not allowed to conduct any portion of the work for a HERS rating but who may receive fees for performing quality assurance work as outlined in these Standards, quality assurance oversight, certification and other Quality Assurance Rating Provider related duties. 103.2.1 Third-party Rating Providers must employ one or more Quality Agents certified by RESNET. The Quality Agent will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific quality assurance requirements for other Provider categories that may apply to the organization. 103.2.2 Other than compensation for services necessary for the fulfillment of the Rating Provider, quality assurance requirements specified in these Standards, and other non-HERS rating related services (e.g. LEED for Homes Provider fees), Third-party Rating Providers and the Quality Agents they employ, or contract with, will have no financial interest in their HERS Rating Company clients, or any ratings completed by HERS Raters working with their HERS Rating Company clients. 103.2.3 An organization who is a Third-Party Rating Quality Assurance Provider may also have a separate Direct Rating Quality Assurance Providership. However, quality assurance of the Direct Rating Provider’s work shall not be performed by the organization’sThird-party Rating Quality Assurance Providership. 103.2.4 A Third-party Rating Quality Assurance Provider may also be a Quality Assurance Contractor. 103.4.1 Third-Party Rating Quality Assurance Providers shall demonstrate to RESNET a minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage. 103.2.5 Two organizations that are both a Third-Party Rating Quality Assurance Provider and Direct Rating Quality Assurance Provider shall not exchange quality assurance services specified in these Standards.
In the interest of time involved in pointing out every section in which this terminology is referenced, please accept this proposed revision as referring to all sections throughout the standard in which the terms "Third-party Rating Quality Assurance Provider" and "Third-party Provider" are being proposed.
Comment #67Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6Paragraph / Figure / Table / Note: 103.2.1Comment Intent: ObjectionComment Type: GeneralComment: What does this provision mean? The terminology is very similar between types of Providers here, and, elsewhere in the Standard, the term Provider is used on its own. Does "Provider" always include all types of possible providers unless specified? The specific responsibilities and obligations of Direct Providers and Third-Party Rating Quality Assurance Providers remains unclear to me, even after reading the entire document that is up for comment. It's certainly not practicable as written. Who does what? Are most quality oversight tasks meant to be duplicated by different parties in order to "improve the consistency of the HERS Index score?" Can somebody please create a flow chart of responsibility if this structure is to be incorporated into the Standard? Again, yes, of course the Quality Agents will be certified by RESNET. That's defined in another section. Proposed Change: 103.2.1 Third-Pparty Providers must employ one or more Quality Agents certified by RESNET. The Quality Agent will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific quality assurance requirements for other Provider categories that may apply to the organization. Response: Reject Restating that Quality Agents are certified by RESNET does no harm
The specific responsibilities and obligations of Direct Providers and Third-Party Rating Quality Assurance Providers remains unclear to me, even after reading the entire document that is up for comment. It's certainly not practicable as written. Who does what? Are most quality oversight tasks meant to be duplicated by different parties in order to "improve the consistency of the HERS Index score?" Can somebody please create a flow chart of responsibility if this structure is to be incorporated into the Standard?
Again, yes, of course the Quality Agents will be certified by RESNET. That's defined in another section.
103.2.1 Third-Pparty Providers must employ one or more Quality Agents certified by RESNET. The Quality Agent will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific quality assurance requirements for other Provider categories that may apply to the organization.
Restating that Quality Agents are certified by RESNET does no harm
Comment #68Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6Paragraph / Figure / Table / Note: 103.2.1Comment Intent: ObjectionComment Type: GeneralComment: I believe Third Party Providers should be allowed to contract with Quality Agents and not neccessairly have Quality agents in their direct employ. Energy Raters of Massachusetts has worked this way sucessfully for several years. I'm not sure whether it was the intent of this language to eliminate this possibility, but it seems to. Proposed Change: 103.2.1 Third-party Providers must employ or Contract with one or more Quality Agents certified by RESNET. The Quality Agent will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific quality assurance requirements for other Provider categories that may apply to the organization. Response: Accept
I believe Third Party Providers should be allowed to contract with Quality Agents and not neccessairly have Quality agents in their direct employ. Energy Raters of Massachusetts has worked this way sucessfully for several years. I'm not sure whether it was the intent of this language to eliminate this possibility, but it seems to.
103.2.1 Third-party Providers must employ or Contract with one or more Quality Agents certified by RESNET. The Quality Agent will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific quality assurance requirements for other Provider categories that may apply to the organization.
Comment #69Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6Paragraph / Figure / Table / Note: 103.2.2Comment Intent: ObjectionComment Type: EditorialComment: EAM disagrees with the term "non-HERS" services in that we feel it is too broad a description. The example given, LEED for Homes Provider Fees, is not one we would object to a Third-Party Provider being allowed to provide in additon to RESNET QA because LEED for Homes Provider Fees are generally for QA of that program's additional requirements. However there are other services which Third-Party Providers currently conduct on the homes where they provide RESNET QA that are NOT quality assurance. An example would be HVAC design. That type of work is not quality assurance, but direct consulting/design work on the home. If a Provider wants to provide that type of service it should be done through a Direct Rating Providership with the QA requirements that type of Providership entails. For a Provider to enjoy Third-Party status under this new system of RESNET QA they should not be doing anything except for quality assurance work on the homes where they are the QA Contractor. Proposed Change: 103.2.2 Other than compensation for services necessary for the fulfillment of the Rating Provider, quality assurance requirements specified in these Standards, and other non-HERS rating third-party quality assurance related services (e.g. LEED for Homes Provider fees), Third-party Providers and the Quality Agents they employ, or contract with, will have no financial interest in their HERS Rating Company clients, or any ratings completed by HERS Raters working with their HERS Rating Company clients. Response: Reject Comment offers no understandable clarification
EAM disagrees with the term "non-HERS" services in that we feel it is too broad a description. The example given, LEED for Homes Provider Fees, is not one we would object to a Third-Party Provider being allowed to provide in additon to RESNET QA because LEED for Homes Provider Fees are generally for QA of that program's additional requirements. However there are other services which Third-Party Providers currently conduct on the homes where they provide RESNET QA that are NOT quality assurance. An example would be HVAC design. That type of work is not quality assurance, but direct consulting/design work on the home. If a Provider wants to provide that type of service it should be done through a Direct Rating Providership with the QA requirements that type of Providership entails. For a Provider to enjoy Third-Party status under this new system of RESNET QA they should not be doing anything except for quality assurance work on the homes where they are the QA Contractor.
103.2.2 Other than compensation for services necessary for the fulfillment of the Rating Provider, quality assurance requirements specified in these Standards, and other non-HERS rating third-party quality assurance related services (e.g. LEED for Homes Provider fees), Third-party Providers and the Quality Agents they employ, or contract with, will have no financial interest in their HERS Rating Company clients, or any ratings completed by HERS Raters working with their HERS Rating Company clients.
Comment offers no understandable clarification
Comment #70Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6Paragraph / Figure / Table / Note: 103.2.2Comment Intent: Not an ObjectionComment Type: TechnicalComment: I believe that "financial interest" should be expanded to include any contractual relationship other than performing verifications for another EEP. Third-party inspections need to be truly third-party to the Rater and the builder. The Quality Agents should not be affiliated with any company that performed any direct-installations on the home being Rated, nor should they be affiliated with any company that provided the project with any design services. The relationship between the Rater and the project may be different, but the quality oversight needs to be once removed. The Quality Agents need to be truly third-party to a project in order to most fairly evaluate its outcome. Proposed Change: 103.2.2 Other than compensation for services necessary for the fulfillment of the Rating Provider, quality assurance requirements specified in these Standards, and other non-HERS rating related services (e.g. LEED for Homes Provider fees), Third-Pparty Providers and the Quality Agents they employ, or contract with, shallwill have no financial interest in or contractual relationship to their HERS Rating Company clients, or any ratings completed by HERS Raters working with their HERS Rating Company clients. Financial interest is defined in Appendix B. Contractual relationship includes providing design or subcontractor services to a project, whether or not a signed contract exists. Response: Accept Accept all suggested changes except for “or contractual relationship to”
I believe that "financial interest" should be expanded to include any contractual relationship other than performing verifications for another EEP. Third-party inspections need to be truly third-party to the Rater and the builder. The Quality Agents should not be affiliated with any company that performed any direct-installations on the home being Rated, nor should they be affiliated with any company that provided the project with any design services. The relationship between the Rater and the project may be different, but the quality oversight needs to be once removed.
The Quality Agents need to be truly third-party to a project in order to most fairly evaluate its outcome.
103.2.2 Other than compensation for services necessary for the fulfillment of the Rating Provider, quality assurance requirements specified in these Standards, and other non-HERS rating related services (e.g. LEED for Homes Provider fees), Third-Pparty Providers and the Quality Agents they employ, or contract with, shallwill have no financial interest in or contractual relationship to their HERS Rating Company clients, or any ratings completed by HERS Raters working with their HERS Rating Company clients. Financial interest is defined in Appendix B. Contractual relationship includes providing design or subcontractor services to a project, whether or not a signed contract exists.
Accept all suggested changes except for “or contractual relationship to”
Comment #71Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6Paragraph / Figure / Table / Note: 103.2.3Comment Intent: ObjectionComment Type: GeneralComment: This section blurs the distinctions created by the RESNET Board of Directors in the policy statements approved at the November 2014 Board meeting. Direct Providers and Third-party Providers were created to prevent financial entanglements and confusion, this section sets the stage for those to continue to exist. Proposed Change: Strike this language in its entirety: 103.2.3 An organization who is a Third-Party Rating Quality Assurance Provider may also have a separate Direct Rating Quality Assurance Providership. However, quality assurance of the Direct Provider’s work shall not be performed by the organization’s Third-party Rating Quality Assurance Providership. Do NOT replace. Response: Reject Is not in alignment with the board of directors policy that was clarified further at another board meeting on September 12, 2016
This section blurs the distinctions created by the RESNET Board of Directors in the policy statements approved at the November 2014 Board meeting. Direct Providers and Third-party Providers were created to prevent financial entanglements and confusion, this section sets the stage for those to continue to exist.
Comment #72Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6Paragraph / Figure / Table / Note: 103.2.3Comment Intent: ObjectionComment Type: GeneralComment: Section 103.1 defines a Direct Rating QA Provider. Section 103.2 defines a 3rd Party Rating QA Provider with the principal distinction being that they "are not allowed to conduct any portion of the work for a HERS rating" Yet 103.2.3 allows them to have a "a separate Direct Rating Quality Assurance Providership" This in effect makes them a Direct Rating QA Provider. Why complicate definitions by including this exception. If yyou are going to do both, why not be classified a Direct Rating QA Provider? Proposed Change: Delete exception provided under 103.2.3 Response: Reject Is not in alignment with the board of directors policy that was clarified further at another board meeting on September 12, 2016
Section 103.1 defines a Direct Rating QA Provider.
Section 103.2 defines a 3rd Party Rating QA Provider with the principal distinction being that they "are not allowed to conduct any portion of the work for a HERS rating"
Yet 103.2.3 allows them to have a "a separate Direct Rating Quality Assurance Providership" This in effect makes them a Direct Rating QA Provider.
Why complicate definitions by including this exception. If yyou are going to do both, why not be classified a Direct Rating QA Provider?
Delete exception provided under 103.2.3
Comment #73Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 6Paragraph / Figure / Table / Note: 103.2.3Comment Intent: Not an ObjectionComment Type: GeneralComment: We believe there should be an exception for underserved/rural areas and areas where economic hardship would make these new rules disasterous to the continuing of gaining HERs Ratings. Many rural providers can only financially survive by providing both certifications as well as quality assurance to their market. Eliminating these market actors weakens RESNET and all of her EEPs in underdeveloped markets that may thrive in the future or where the possibility of Raters providing Code inspection is a legitimate addition to the current landscape. It is important to many stakeholders to continue servicing rural and economically strapped areas equally to other markets in terms of coverage and services provided. Proposed Change: 103.2.3 An organization who is a Third-Party Rating Quality Assurance Provider may also have a separate Direct Rating Quality Assurance Providership. However, quality assurance of the Direct Provider’s work shall not be performed by the organization’s Third-party Rating Quality Assurance Providership, except in under-served communities, where the creation of and maintenance of both Rating Providership and Third-Party Rating Quality Assurance Providers is not financially feasible. Providers in underserved areas should submit to the RESNET QA Manager (or appropriate committee/working group) for working allowances and will accept greater RESNET oversight of their work. Either the Provider or the RESNET QA institution may recommend alternative processes for the markets in question. Response: Reject The commenter makes a good point but this issue can be addressed in other ways rather than making exceptions for under-served communities
We believe there should be an exception for underserved/rural areas and areas where economic hardship would make these new rules disasterous to the continuing of gaining HERs Ratings.
Many rural providers can only financially survive by providing both certifications as well as quality assurance to their market. Eliminating these market actors weakens RESNET and all of her EEPs in underdeveloped markets that may thrive in the future or where the possibility of Raters providing Code inspection is a legitimate addition to the current landscape. It is important to many stakeholders to continue servicing rural and economically strapped areas equally to other markets in terms of coverage and services provided.
103.2.3 An organization who is a Third-Party Rating Quality Assurance Provider may also have a separate Direct Rating Quality Assurance Providership. However, quality assurance of the Direct Provider’s work shall not be performed by the organization’s Third-party Rating Quality Assurance Providership, except in under-served communities, where the creation of and maintenance of both Rating Providership and Third-Party Rating Quality Assurance Providers is not financially feasible. Providers in underserved areas should submit to the RESNET QA Manager (or appropriate committee/working group) for working allowances and will accept greater RESNET oversight of their work. Either the Provider or the RESNET QA institution may recommend alternative processes for the markets in question.
The commenter makes a good point but this issue can be addressed in other ways rather than making exceptions for under-served communities
Comment #74Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 6Paragraph / Figure / Table / Note: 103.2.4Comment Intent: Not an ObjectionComment Type: TechnicalComment: Numbering ommision, see below. Proposed Change: Change the numbering on this text to "103.2.4.1" 103.4.1 Third-Party Rating Quality Assurance Providers shall demonstrate to RESNET a minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage Response: Accept RESNET will staff will review entire document for numbering prior to final release
Numbering ommision, see below.
Change the numbering on this text to "103.2.4.1" 103.4.1 Third-Party Rating Quality Assurance Providers shall demonstrate to RESNET a minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage
RESNET will staff will review entire document for numbering prior to final release
Comment #75Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6Paragraph / Figure / Table / Note: 103.2.5Comment Intent: ObjectionComment Type: GeneralComment: This section is unnecessary IF my earlier comments are adopted. There simply is no need for additional layers of complicatedness when the complex challenge can be resolved simply: Direct Providers do not perform Quality Assurance work on their ratings and must hire a Third-party Provider to do so. Eliminate the ability for a Direct Provider to also operate a Third-party Provider business, and a Third-party Provider to operate a Direct Provider business and you won't need this section at all. It addresses a problem created by the creation of additional layers that didn't need to be created to begin with. Proposed Change: Strike the following language in its entirety: 103.2.5 Two organizations that are both a Third-Party Rating Quality Assurance Provider and Direct Rating Quality Assurance Provider shall not exchange quality assurance services specified in these Standards. Do NOT replace. Response: Reject Is not in alignment with the board of directors policy that was clarified further at another board meeting on September 12, 2016
This section is unnecessary IF my earlier comments are adopted. There simply is no need for additional layers of complicatedness when the complex challenge can be resolved simply: Direct Providers do not perform Quality Assurance work on their ratings and must hire a Third-party Provider to do so. Eliminate the ability for a Direct Provider to also operate a Third-party Provider business, and a Third-party Provider to operate a Direct Provider business and you won't need this section at all. It addresses a problem created by the creation of additional layers that didn't need to be created to begin with.
Comment #76Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6Paragraph / Figure / Table / Note: 103.2.5Comment Intent: ObjectionComment Type: GeneralComment: Section 103.1 defines a Direct Rating QA Provider Section 103.2 defines a 3rd Party Rating QA Provider They seem to be two separate entities with two unique roles. Section 103.2.5 puts limits on an organization that acts in both capacities. While section 103.2.3, describes a 3rd Party Rating QA Provider that could also act as a Direct Rating QA Provider, it would be much clearer to not create this special case - If you act as a Direct Rating QA Provider, that's what you should be called. This would also make 103.2.5 unnecessary. Proposed Change: Delete provision 103.2.5 Response: Reject Is not in alignment with the board of directors policy that was clarified further at another board meeting on September 12, 2016
Section 103.1 defines a Direct Rating QA Provider
Section 103.2 defines a 3rd Party Rating QA Provider
They seem to be two separate entities with two unique roles.
Section 103.2.5 puts limits on an organization that acts in both capacities. While section 103.2.3, describes a 3rd Party Rating QA Provider that could also act as a Direct Rating QA Provider, it would be much clearer to not create this special case - If you act as a Direct Rating QA Provider, that's what you should be called. This would also make 103.2.5 unnecessary.
Delete provision 103.2.5
Comment #77Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6Paragraph / Figure / Table / Note: 103.3Comment Intent: ObjectionComment Type: EditorialComment: Glossary of terms.. Page B1 does not have a Rating QA Provider-only has QA Provider- Terms should be consistent. Seems also this maybe this section should be only Direct Rating QA Provider section-since other type is third party and has no raters under them...therefore they would not be responsible for raters software, etc.... Proposed Change: 103.3. Direct Rating Quality Assurance Provider Responsibilities. Response: Reject Proposed change is not acceptable because section applies to both direct and third party providers
Glossary of terms.. Page B1 does not have a Rating QA Provider-only has QA Provider- Terms should be consistent. Seems also this maybe this section should be only Direct Rating QA Provider section-since other type is third party and has no raters under them...therefore they would not be responsible for raters software, etc....
103.3. Direct Rating Quality Assurance Provider Responsibilities.
Proposed change is not acceptable because section applies to both direct and third party providers
Comment #78Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6 and 1-7Paragraph / Figure / Table / Note: 103.3 and subsectionsComment Intent: ObjectionComment Type: TechnicalComment: This section implies that both Direct and Third-Party Home Energy Rating Quality Assurance Providers have substantial overlapping responsibilities. It also uses extended terminology that could be condensed, as defined and abbreviated in Appendix B. My best guess of the writer's intent and future Providers' implementation is that (1) is the responsibility of the Third-Party Provider, (2) - (6) and (8) are responsibilities of the Direct Provider, and that (7) is the responsibility of both types of Providers. But that's my guess and not my preference. In order to implement a double-triple-quadruple layer quality assurance oversight system, each party's roles and responsibilities must be clearly defined in order to avoid both the duplication of efforts and the corresponding high costs of implementation and the diffusion of responsibility. Neither scenario truly "improves the consistency of the HERS Index score." In addition, stronger verbs should be used so that whomever is assigned these tasks will unquestionably be required to enforce them. I also believe that the 60-day limit should be removed since it will always be in somebody's interest to add as many Confirmed Ratings to the Registry as possible. Isn't it in RESNET's interest to ensure that as many homes as possible are submitted to the Registry? Proposed Change: 103.3.1 Perform sufficient quality assurance oversight of Home Energy Raters and Rating Field Inspectors (RFI’s) to ensure compliance with these Standards and the minimum quality assurance requirements outlined in Chapter 9. This oversight is in addition to the oversight performed by RESNET and quality assurance performed by Quality Agents of RESNET defined in Chapter 9 of these Standards. 103.3.2 Assess, certify and recertify HERS Raters and RFI’s as required in Chapter 2 of these Standards. 103.3.3 Provide RESNET accredited rating software to HERS Raters and ensure that they are using the latest version of the software to perform ratings. 103.3.4 Ensure that all Home EnergySubmit Ratings conducted by their certified HERS Raters are submitted to the National RESNET Registry. Confirmed Ratings shall be submitted to the Registry as soon as is practically feasible.Submittal of ratings to the Registry must be completed within 60 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer. 103.3.5 EnsureRequire that Rated Home Registration ID’s provided by the National RESNET Registry are prominently displayed on all Rating Certifications. 103.3.6 Resolve HERS Rater compliance complaints. 103.3.7 Undertake disciplinary action on HERS Raters and RFI’s when required. 103.3.8 EnsureProvide their certified HERS Raters with access to have thorough working knowledge of RESNET Sstandards, The RESNET Ccode of Eethics and standards of practice. Provide notification within 30 days of any revisions to these documents or to the energy simulation software used by that Rater. Evaluate their working knowledge of these policies and procedures during their annual QA Field review. Response: Accept Accept change in 103.3.1 Accept with modification to 103.3.4- Submit Confirmed or Sampled Ratings conducted by their certified HERS Raters to the National RESNET Registry. Cannot accept subjectable language for second change to 103.3.4 Accept with modifications to 103.3.5- Require that Rated Home Registration ID’s provided by the National RESNET Registry are prominently displayed on all Rating Certifications. Accept with modifications to 103.3.8- Ensure their certified HERS Raters have a working knowledge of RESNET Standards, The RESNET Code of Ethics and standards of practice. Accept with modifications to 103.3.3- Ensure HERS Raters under their Providership use the latest version of RESNET-accredited software tools to produce ratings and provide notification within 30 days of any software changes.
This section implies that both Direct and Third-Party Home Energy Rating Quality Assurance Providers have substantial overlapping responsibilities. It also uses extended terminology that could be condensed, as defined and abbreviated in Appendix B.
My best guess of the writer's intent and future Providers' implementation is that (1) is the responsibility of the Third-Party Provider, (2) - (6) and (8) are responsibilities of the Direct Provider, and that (7) is the responsibility of both types of Providers. But that's my guess and not my preference.
In order to implement a double-triple-quadruple layer quality assurance oversight system, each party's roles and responsibilities must be clearly defined in order to avoid both the duplication of efforts and the corresponding high costs of implementation and the diffusion of responsibility. Neither scenario truly "improves the consistency of the HERS Index score."
In addition, stronger verbs should be used so that whomever is assigned these tasks will unquestionably be required to enforce them.
I also believe that the 60-day limit should be removed since it will always be in somebody's interest to add as many Confirmed Ratings to the Registry as possible. Isn't it in RESNET's interest to ensure that as many homes as possible are submitted to the Registry?
103.3.1 Perform sufficient quality assurance oversight of Home Energy Raters and Rating Field Inspectors (RFI’s) to ensure compliance with these Standards and the minimum quality assurance requirements outlined in Chapter 9. This oversight is in addition to the oversight performed by RESNET and quality assurance performed by Quality Agents of RESNET defined in Chapter 9 of these Standards.
103.3.2 Assess, certify and recertify HERS Raters and RFI’s as required in Chapter 2 of these Standards.
103.3.3 Provide RESNET accredited rating software to HERS Raters and ensure that they are using the latest version of the software to perform ratings.
103.3.4 Ensure that all Home EnergySubmit Ratings conducted by their certified HERS Raters are submitted to the National RESNET Registry. Confirmed Ratings shall be submitted to the Registry as soon as is practically feasible.Submittal of ratings to the Registry must be completed within 60 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer.
103.3.5 EnsureRequire that Rated Home Registration ID’s provided by the National RESNET Registry are prominently displayed on all Rating Certifications.
103.3.6 Resolve HERS Rater compliance complaints.
103.3.7 Undertake disciplinary action on HERS Raters and RFI’s when required.
103.3.8 EnsureProvide their certified HERS Raters with access to have thorough working knowledge of RESNET Sstandards, The RESNET Ccode of Eethics and standards of practice. Provide notification within 30 days of any revisions to these documents or to the energy simulation software used by that Rater. Evaluate their working knowledge of these policies and procedures during their annual QA Field review.
Accept change in 103.3.1
Accept with modification to 103.3.4- Submit Confirmed or Sampled Ratings conducted by their certified HERS Raters to the National RESNET Registry. Cannot accept subjectable language for second change to 103.3.4
Accept with modifications to 103.3.5- Require that Rated Home Registration ID’s provided by the National RESNET Registry are prominently displayed on all Rating Certifications.
Accept with modifications to 103.3.8- Ensure their certified HERS Raters have a working knowledge of RESNET Standards, The RESNET Code of Ethics and standards of practice.
Accept with modifications to 103.3.3- Ensure HERS Raters under their Providership use the latest version of RESNET-accredited software tools to produce ratings and provide notification within 30 days of any software changes.
Comment #79Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6Paragraph / Figure / Table / Note: 103.3.1Comment Intent: ObjectionComment Type: EditorialComment: As written, this section appears to place two levels of responsibility and cost on Direct Providers but only a single level of responsibility and cost on Third Party Provider. The edit is an attempt to eliminate duplication of effort and cost and level the playing field for direct providers. Proposed Change: 103.3.1 Perform sufficient quality assurance oversight of Home Energy Raters and Rating Field Inspectors (RFI’s) to ensure compliance with these Standards and the minimum quality assurance requirements outlined in Chapter 9. This is in addition to the oversight performed by RESNET and quality assurance performed by Quality Agents of RESNET defined in Chapter 9 of these Standards. Direct providers are not required to duplicate responsibilities assigned to third party QA providers through contract. Response: Reject Proposed change does not offer a substantive improvement
As written, this section appears to place two levels of responsibility and cost on Direct Providers but only a single level of responsibility and cost on Third Party Provider. The edit is an attempt to eliminate duplication of effort and cost and level the playing field for direct providers.
103.3.1 Perform sufficient quality assurance oversight of Home Energy Raters and Rating Field Inspectors (RFI’s) to ensure compliance with these Standards and the minimum quality assurance requirements outlined in Chapter 9. This is in addition to the oversight performed by RESNET and quality assurance performed by Quality Agents of RESNET defined in Chapter 9 of these Standards. Direct providers are not required to duplicate responsibilities assigned to third party QA providers through contract.
Proposed change does not offer a substantive improvement
Comment #80Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 6Paragraph / Figure / Table / Note: 103.3.1Comment Intent: ObjectionComment Type: TechnicalComment: 103.3.1 - Delete the entire section. Our justification is that quality assurance work required by providers needs to be spelled out with technical language within these standards and not general suggestions such as "sufficient quality assurance oversight". Proposed Change: 103.3.1102.1.4.10.2.2 All Quality Assurance controls that are required by National RESNET Standards are met or exceeded for Home Energy Ratings listed in the National RESNET Registry. Perform sufficient quality assurance oversight of Home Energy Raters and Rating Field Inspectors (RFI’s) to ensure compliance with these Standards and the minimum quality assurance requirements outlined in Chapter 9. This is in addition to the oversight performed by RESNET and quality assurance performed by Quality Agents of RESNET defined in Chapter 9 of these Standards. Response: Reject Language in the section refers to the standard and to Chapter 9 specifically which meets the intent commenter.
103.3.1 - Delete the entire section. Our justification is that quality assurance work required by providers needs to be spelled out with technical language within these standards and not general suggestions such as "sufficient quality assurance oversight".
103.3.1102.1.4.10.2.2 All Quality Assurance controls that are required by National RESNET Standards are met or exceeded for Home Energy Ratings listed in the National RESNET Registry. Perform sufficient quality assurance oversight of Home Energy Raters and Rating Field Inspectors (RFI’s) to ensure compliance with these Standards and the minimum quality assurance requirements outlined in Chapter 9. This is in addition to the oversight performed by RESNET and quality assurance performed by Quality Agents of RESNET defined in Chapter 9 of these Standards.
Language in the section refers to the standard and to Chapter 9 specifically which meets the intent commenter.
Comment #81Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6Paragraph / Figure / Table / Note: 103.3.1Comment Intent: Not an ObjectionComment Type: EditorialComment: Home Energy Raters should be changed to HERS Raters for consistency Proposed Change: 103.3.1102.1.4.10.2.2 All Quality Assurance controls that are required by National RESNET Standards are met or exceeded for Home Energy Ratings listed in the National RESNET Registry. Perform sufficient quality assurance oversight of HERS[D1] Raters and Rating Field Inspectors (RFI’s) to ensure compliance with these Standards and the minimum quality assurance requirements outlined in Chapter 9. This is in addition to the oversight performed by RESNET and quality assurance performed by Quality Agents of RESNET defined in Chapter 9 of these Standards. [D1]consistent with other references Response: Accept
Home Energy Raters should be changed to HERS Raters for consistency
103.3.1102.1.4.10.2.2 All Quality Assurance controls that are required by National RESNET Standards are met or exceeded for Home Energy Ratings listed in the National RESNET Registry. Perform sufficient quality assurance oversight of HERS[D1] Raters and Rating Field Inspectors (RFI’s) to ensure compliance with these
Standards and the minimum quality assurance requirements outlined in Chapter 9. This is in addition to the oversight performed by RESNET and quality assurance performed by Quality Agents of RESNET defined in Chapter 9 of these Standards.
[D1]consistent with other references
Comment #82Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-7Paragraph / Figure / Table / Note: 103.3.3Comment Intent: ObjectionComment Type: TechnicalComment: While it is definitely the responsibiliy of Providers to ensure that HERS Raters working with them are using the appropriate software, Providers should not be required to provide that rating software. This creates a potential conflict of interest for Direct and Third-Party Home Energy Rating Quality Assurance Providers and their Raters in terms of conpensation and Financial Interest. Proposed Change: 103.3.3 Provide RESNET accredited rating software to HERS Raters and eEnsure that they HERS Raters are using the latest version of the software to perform ratings. Response: Accept Accept in principle as modified above- Ensure HERS Raters under their Providership use the latest version of RESNET-accredited software tools to produce ratings and provide notification within 30 days of any software changes.
While it is definitely the responsibiliy of Providers to ensure that HERS Raters working with them are using the appropriate software, Providers should not be required to provide that rating software. This creates a potential conflict of interest for Direct and Third-Party Home Energy Rating Quality Assurance Providers and their Raters in terms of conpensation and Financial Interest.
103.3.3 Provide RESNET accredited rating software to HERS Raters and eEnsure that they HERS Raters are using the latest version of the software to perform ratings.
Accept in principle as modified above- Ensure HERS Raters under their Providership use the latest version of RESNET-accredited software tools to produce ratings and provide notification within 30 days of any software changes.
Comment #83Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-7Paragraph / Figure / Table / Note: 103.3.3Comment Intent: ObjectionComment Type: GeneralComment: This section applies to a single RESNET-accredited software tool and their business model. Anything that is so narrowly focused to only apply to one software tool out of several does NOT belong in a Standard. Proposed Change: Strike the following language in its entirety: 103.3.3 Provide RESNET accredited rating software to HERS Raters and ensure that they are using the latest version of the software to perform ratings. Replace with: 103.3.3 Ensure HERS Raters under their Providership use the latest version of RESNET-accredited software tools to produce ratings. Response: Accept accept as modified Ensure HERS Raters under their Providership use the latest version of RESNET-accredited software tools to produce ratings and provide notification within 30 days of any software changes.
This section applies to a single RESNET-accredited software tool and their business model. Anything that is so narrowly focused to only apply to one software tool out of several does NOT belong in a Standard.
103.3.3 Ensure HERS Raters under their Providership use the latest version of RESNET-accredited software tools to produce ratings.
accept as modified Ensure HERS Raters under their Providership use the latest version of RESNET-accredited software tools to produce ratings and provide notification within 30 days of any software changes.
Comment #84Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 7Paragraph / Figure / Table / Note: 103.3.4Comment Intent: ObjectionComment Type: TechnicalComment: I have a huge problem with the highlighted language in this proposed standard: 103.3.4 Ensure that all Home Energy Ratings conducted by their certified HERS Raters are submitted to the National RESNET Registry. Submittal of ratings to the Registry must be completed within 60 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer. If a building file gets lost in the pipeline and resurfaces after 60 days- it can't be uploaded to the Registry? This has the potential to affect people who don't do ratings day-in and day-out, and this sentence should be completely struck from the standards. Besides that, what would stop a Rater or Provider from changing the date of rating to be within 60 days? People can change their records to match what they want, and this language does nothing. While the intent behind it is nice, there needs to be more thought before it gets implemented. Proposed Change: 103.3.4 Ensure that all Home Energy Ratings conducted by their certified HERS Raters are submitted to the National RESNET Registry. Submittal of ratings to the Registry must be completed within 60 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer. Response: Reject The real concern is systematic failure and RESNET will develop a policy to address systematic failure. Modify language as follows: Submittal of ratings to the Registry must shall be completed within 90 60 calendar days of completion of the rating,rating date or certification of the rated home in an EEP, whichever is longer.
I have a huge problem with the highlighted language in this proposed standard:
103.3.4 Ensure that all Home Energy Ratings conducted by their certified HERS Raters are submitted to the National RESNET Registry. Submittal of ratings to the Registry must be completed within 60 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer.
If a building file gets lost in the pipeline and resurfaces after 60 days- it can't be uploaded to the Registry? This has the potential to affect people who don't do ratings day-in and day-out, and this sentence should be completely struck from the standards.
Besides that, what would stop a Rater or Provider from changing the date of rating to be within 60 days? People can change their records to match what they want, and this language does nothing.
While the intent behind it is nice, there needs to be more thought before it gets implemented.
The real concern is systematic failure and RESNET will develop a policy to address systematic failure.
Modify language as follows: Submittal of ratings to the Registry must shall be completed within 90 60 calendar days of completion of the rating,rating date or certification of the rated home in an EEP, whichever is longer.
Comment #85Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-7Paragraph / Figure / Table / Note: 103.3.4Comment Intent: ObjectionComment Type: TechnicalComment: Change to 90 days to align with other QA provisions which use one Quarter (or 90 days) as the standard timing metric. Proposed Change: 103.3.4 Ensure that all Home Energy Ratings conducted by their certified HERS Raters are submitted to the National RESNET Registry. Submittal of ratings to the Registry must be completed within 60 90 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer. Response: Accept Modify language as follows: Submittal of ratings to the Registry must shall be completed within 90 60 calendar days of completion of the rating,rating date or certification of the rated home in an EEP, whichever is longer.
Change to 90 days to align with other QA provisions which use one Quarter (or 90 days) as the standard timing metric.
103.3.4 Ensure that all Home Energy Ratings conducted by their certified HERS Raters are submitted to the National RESNET Registry. Submittal of ratings to the Registry must be completed within 60 90 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer.
Comment #86Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 7Paragraph / Figure / Table / Note: 103.3.4Comment Intent: Not an ObjectionComment Type: GeneralComment: within 60 days of "completing" the rating is unenforceable language. How do you define that? Instead, why not say, within 60 days of the Rating Date, which is an actual date within the software file and within the registry? Proposed Change: 103.3.4: ....Submittal of ratings to the Registry must be completed within 60 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer. 103.3.4: ....Submittal of ratings to the Registry must be completed within 60 calendar days of Rating Date. Response: Accept Accept in principle. Modify language as follows: Submittal of ratings to the Registry must shall be completed within 90 60 calendar days of completion of the rating,rating date or certification of the rated home in an EEP, whichever is longer.
within 60 days of "completing" the rating is unenforceable language. How do you define that? Instead, why not say, within 60 days of the Rating Date, which is an actual date within the software file and within the registry?
103.3.4: ....Submittal of ratings to the Registry must be completed within 60 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer.
103.3.4: ....Submittal of ratings to the Registry must be completed within 60 calendar days of Rating Date.
Accept in principle.
Comment #87Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-7Paragraph / Figure / Table / Note: 103.3.4Comment Intent: ObjectionComment Type: GeneralComment: Requiring Third-party Providers to submit ratings to the registry within 60 days of the completion of the rating is not feasible. Third-party Providers do not have control over when their clients submit completed ratings to them, and therefore cannot be held responsible for delays between the completion of the rating and submittal to the Third-party Provider. The clause in this section is another example of bias and favoritism of one Provider model over another, favoring Direct Providers who have direct control over the Raters in their employ. Proposed Change: Replace with: 103.3.4102.1.4.10.2.1 Ensure that All all Home Energy Ratings conducted by their certified HERS Raters are submitted to the National RESNET Registry. Submittal of ratings to the Registry must be completed within 60 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer. Response: Reject The real concern is systematic failure and RESNET will develop a policy to address systematic failure. Modify language as follows: Submittal of ratings to the Registry must shall be completed within 90 60 calendar days of completion of the rating,rating date or certification of the rated home in an EEP, whichever is longer.
Requiring Third-party Providers to submit ratings to the registry within 60 days of the completion of the rating is not feasible.
Third-party Providers do not have control over when their clients submit completed ratings to them, and therefore cannot be held responsible for delays between the completion of the rating and submittal to the Third-party Provider.
The clause in this section is another example of bias and favoritism of one Provider model over another, favoring Direct Providers who have direct control over the Raters in their employ.
103.3.4102.1.4.10.2.1 Ensure that All all Home Energy Ratings conducted by their certified HERS Raters are submitted to the National RESNET Registry. Submittal of ratings to the Registry must be completed within 60 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer.
Comment #88Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-7Paragraph / Figure / Table / Note: 103.3.4Comment Intent: ObjectionComment Type: GeneralComment: The reality is There are to many things that could go wrong that would allow a rating to slip past a 60 window. either strike this or add language for the process if a rating is found on day 61 for example Proposed Change: 103.3.4102.1.4.10.2.1 Ensure that All all Home Energy Ratings conducted by their certified HERS Raters are submitted to the National RESNET Registry. Submittal of ratings to the Registry must be completed within 60 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer. Response: Reject The real concern is systematic failure and RESNET will develop a policy to address systematic failure. Modify language as follows: Submittal of ratings to the Registry must shall be completed within 90 60 calendar days of completion of the rating,rating date or certification of the rated home in an EEP, whichever is longer.
The reality is There are to many things that could go wrong that would allow a rating to slip past a 60 window. either strike this or add language for the process if a rating is found on day 61 for example
Comment #89Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 7Paragraph / Figure / Table / Note: 103.3.4Comment Intent: Not an ObjectionComment Type: TechnicalComment: Section 103.3.4 should include the terminolgy "Confirmed and Sampled" as the specific rating types that are required to be submitted to the national RESNET Registry. Proposed Change: 103.3.4102.1.4.10.2.1 Ensure that Allall Confirmed and Sampled Home Energy Ratings conducted by their certified HERS Raters are submitted to the National RESNET Registry. Submittal of ratings to the Registry must be completed within 60 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer. Response: Reject Generic reference to Home Energy Ratings captures all defined rating types in the ANSI/RESNET/ICC 301 Standard
Section 103.3.4 should include the terminolgy "Confirmed and Sampled" as the specific rating types that are required to be submitted to the national RESNET Registry.
103.3.4102.1.4.10.2.1 Ensure that Allall Confirmed and Sampled Home Energy Ratings conducted by their certified HERS Raters are submitted to the National RESNET Registry. Submittal of ratings to the Registry must be completed within 60 calendar days of completion of the rating, or certification of the rated home in an EEP, whichever is longer.
Generic reference to Home Energy Ratings captures all defined rating types in the ANSI/RESNET/ICC 301 Standard
Comment #90Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-7Paragraph / Figure / Table / Note: 103.3.5Comment Intent: ObjectionComment Type: GeneralComment: This section requires Quality Assurance Providers to perform a role and task which is completely out of their control, but is in the control of Software Providers. Since the Quality Assurance Providers have no control over this element, it is completely unenforceable and creates an unnecessary burden of impossible compliance. Proposed Change: Strike the following language in its entirety: 103.3.5102.1.4.10.2.3 Ensure that Rated Home Registration ID’s provided by the National RESNET Registry isare prominently displayed on all Rating Certifications. Do NOT replace. Response: Reject Addressing concerned in comment by revised language below. Ensure that the Rating documentation generated by a RESNET Accredited Software Tool includes an ID issued by the National RESNET Registry.
This section requires Quality Assurance Providers to perform a role and task which is completely out of their control, but is in the control of Software Providers.
Since the Quality Assurance Providers have no control over this element, it is completely unenforceable and creates an unnecessary burden of impossible compliance.
103.3.5102.1.4.10.2.3 Ensure that Rated Home Registration ID’s provided by the National RESNET Registry isare prominently displayed on all Rating Certifications.
Addressing concerned in comment by revised language below.
Ensure that the Rating documentation generated by a RESNET Accredited Software Tool includes an ID issued by the National RESNET Registry.
Comment #91Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 7Paragraph / Figure / Table / Note: 103.3.8Comment Intent: Not an ObjectionComment Type: GeneralComment: 103.3.8 Ensure their certified HERS Raters have thorough working knowledge of RESNET standards, code of ethics and standards of practice. Excellent addition...now is there a way to make the professional RESNET website actually useable? Currently it could take me anywhere from two minutes to an hour to find what I need. I'd like to be able to send each Rater client to a page or document, but if I can't find it myself what's the point? Proposed Change: Don't change the standard- just fix the professional RESNET website. Response: Reject The website is under continuous maintenance for improvement. The comment doesn’t provide a standards change.
103.3.8 Ensure their certified HERS Raters have thorough working knowledge of RESNET standards, code of ethics and standards of practice.
Excellent addition...now is there a way to make the professional RESNET website actually useable? Currently it could take me anywhere from two minutes to an hour to find what I need. I'd like to be able to send each Rater client to a page or document, but if I can't find it myself what's the point?
Don't change the standard- just fix the professional RESNET website.
The website is under continuous maintenance for improvement. The comment doesn’t provide a standards change.
Comment #92Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-7Paragraph / Figure / Table / Note: 103.3.8Comment Intent: ObjectionComment Type: GeneralComment: This section places an undue compliance burden on QA Providers by requiring that certified HERS Raters have a thorough working knowledge of RESNET standards, code of ethics, and standards of practice. Isn't that the point of all these bloody exams the Rater candidates have to go through? Why is the Provider now being tasked with ensuring a vague requirement of "thorough working knowledge" beyond the certification exams? Whose definition of "thorough working knowledge"? Stop making things more complicated than they need to be... Proposed Change: Strike the following language in its entirety: 103.3.8 Ensure their certified HERS Raters have thorough working knowledge of RESNET standards, code of ethics and standards of practice. Replace with: 103.3.8 Ensure that HERS Rater and RFI candidates meet the minimum certification requirements of Chapter 2 prior to certification by the Quality Assurance Provider. Response: Accept
This section places an undue compliance burden on QA Providers by requiring that certified HERS Raters have a thorough working knowledge of RESNET standards, code of ethics, and standards of practice. Isn't that the point of all these bloody exams the Rater candidates have to go through? Why is the Provider now being tasked with ensuring a vague requirement of "thorough working knowledge" beyond the certification exams? Whose definition of "thorough working knowledge"?
Stop making things more complicated than they need to be...
103.3.8 Ensure that HERS Rater and RFI candidates meet the minimum certification requirements of Chapter 2 prior to certification by the Quality Assurance Provider.
Comment #93Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-7Paragraph / Figure / Table / Note: 103.3.8Comment Intent: Not an ObjectionComment Type: GeneralComment: This implies that the Provider must take responsiblity for training and grading the results of their Raters in these subjects. Is this correct? Proposed Change: N/A Just a question Response: Reject The comment doesn’t provide a standards change. See comment 92 for improved language
This implies that the Provider must take responsiblity for training and grading the results of their Raters in these subjects. Is this correct?
The comment doesn’t provide a standards change. See comment 92 for improved language
Comment #94Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 34Paragraph / Figure / Table / Note: 103.3.8.Comment Intent: Not an ObjectionComment Type: GeneralComment: to ensure Raters/RFI's have a thorough working knowlege of the Standard etc it would be benifical to have the most current documents easily and readily available. Can we have the links for the standard updated to the most current standard and an easily prinable version should the link be unavailabe? Proposed Change: no change just updated refernces Response: Reject The comment doesn’t provide a standards change. See comment 92 for improved language
to ensure Raters/RFI's have a thorough working knowlege of the Standard etc it would be benifical to have the most current documents easily and readily available. Can we have the links for the standard updated to the most current standard and an easily prinable version should the link be unavailabe?
no change just updated refernces
Comment #95Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-9Paragraph / Figure / Table / Note: 103.4Comment Intent: ObjectionComment Type: EditorialComment: Terms are wrong. No longer a QA designee in Glossary now it is either a Quality Agent or Quality Assurance Contractor. Seems there are several of these issues. Suggest document be closely scrutinized for these type of errors. Proposed Change: 103.4.4 Employ a Quality Agent or contract with a Quality Assurance Designee (QA Designee) Assurance Contractor that to oversee the Provider’s compliance with Chapter 9 of these Standards and any specific QAQuality Assurance requirements for other Provider categories that may apply to a particular organization. Response: Reject The proposed language is correct as written
Terms are wrong. No longer a QA designee in Glossary now it is either a Quality Agent or Quality Assurance Contractor. Seems there are several of these issues. Suggest document be closely scrutinized for these type of errors.
103.4.4 Employ a Quality Agent or contract with a Quality Assurance Designee (QA Designee) Assurance Contractor that to oversee the Provider’s compliance with Chapter 9 of these Standards and any specific QAQuality Assurance requirements for other Provider categories that may apply to a particular organization.
The proposed language is correct as written
Comment #96Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 7Paragraph / Figure / Table / Note: 103.4.1Comment Intent: Not an ObjectionComment Type: GeneralComment: 103.4.1 Prior to submitting an application for accreditation, applicants must participate in a RESNET training which covers, at a minimum, the following: Who is going to develop this training? Will it be up to the Training Providers to create it, or will RESNET commission someone to create it? Or will it be developed internally by RESNET Staff and held live or online? I would like some details on this before I am comfortable with this proposed language. Please contact me directly via email, if possible, with answers. Proposed Change: No change necessary, just answers. Response: Reject The comment doesn’t provide a standards change and the details requested are not a part of standards language.
103.4.1 Prior to submitting an application for accreditation, applicants must participate in a RESNET training which covers, at a minimum, the following:
Who is going to develop this training? Will it be up to the Training Providers to create it, or will RESNET commission someone to create it? Or will it be developed internally by RESNET Staff and held live or online? I would like some details on this before I am comfortable with this proposed language.
Please contact me directly via email, if possible, with answers.
No change necessary, just answers.
The comment doesn’t provide a standards change and the details requested are not a part of standards language.
Comment #97Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-6Paragraph / Figure / Table / Note: 103.4.1Comment Intent: ObjectionComment Type: GeneralComment: This section is numberd out of sequence, sandwiched between 103.2.4 and 103.2.5, and is restrictive and biased against one Provider model over another. Either all of the Providers categories and QA Contractors must demonstrate minimum insurance coverage or none of them must. Proposed Change: Strike the following language in its entirety: 103.4.1 Third-Party Rating Quality Assurance Providers shall demonstrate to RESNET a minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage Do NOT replace. Response: Reject Add language to direct provider requirements. Numbering will be corrected
This section is numberd out of sequence, sandwiched between 103.2.4 and 103.2.5, and is restrictive and biased against one Provider model over another. Either all of the Providers categories and QA Contractors must demonstrate minimum insurance coverage or none of them must.
103.4.1 Third-Party Rating Quality Assurance Providers shall demonstrate to RESNET a minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage
Add language to direct provider requirements. Numbering will be corrected
Comment #98Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-7Paragraph / Figure / Table / Note: 103.4.1Comment Intent: ObjectionComment Type: GeneralComment: This RESNET training is too vague to be included in a Standard. From whom do they receive the training? RESNET Staff? Training Provider? Outside contractor? SDC 900 does NOT have the authority or responsibility to determine training requirements. That falls under the scope of SDC 200, Training and Education. This section is outside the scope of SDC 900 and should have been referred to SDC 200. Stop adding complications! By the way, this proposed amendment repeatedly conflates quality assurance with quality control, two distinctly different elements of quality management systems. I would strongly encourage SDC 900 members to use the appropriate terminology and develop processes that comport with nationally and internationally recognized quality management systems. Proposed Change: Strike the following language in its entirety: 103.4.1 Prior to submitting an application for accreditation, applicants must participate in a RESNET training which covers, at a minimum, the following: 103.4.1.1 Rating Quality Assurance Provider responsibilities; 103.4.1.2 Conflicts of interest; 103.4.1.3 Effective support and communication with HERS Raters; 103.4.1.4 103.4.1.5 Overview of the RESNET ANSI and Non-ANSI Standards; RESNET Quality Assurance requirements and the Rating Quality Assurance Provider’s responsibilities; 103.4.1.6 Requirements and responsibilities for using the National RESNET Registry; 103.4.1.7 RESNET and HERS Index logo use and brand consistency policies. Do NOT replace. Replacement language MUST come from SDC 200. Response: Reject SDC 900 task group will determine if participation of SDC 200 is required to develop or adopt details for training for providers since it is not technical Modify the language as follows- 103.4.1 Prior to submitting an application for accreditation, applicants must participate in a current RESNET training for new providers. Remove sections 103.4.1.1-103.4.1.7
This RESNET training is too vague to be included in a Standard. From whom do they receive the training? RESNET Staff? Training Provider? Outside contractor?
SDC 900 does NOT have the authority or responsibility to determine training requirements. That falls under the scope of SDC 200, Training and Education.
This section is outside the scope of SDC 900 and should have been referred to SDC 200.
Stop adding complications!
By the way, this proposed amendment repeatedly conflates quality assurance with quality control, two distinctly different elements of quality management systems. I would strongly encourage SDC 900 members to use the appropriate terminology and develop processes that comport with nationally and internationally recognized quality management systems.
103.4.1 Prior to submitting an application for accreditation, applicants must participate in a RESNET training which covers, at a minimum, the following: 103.4.1.1 Rating Quality Assurance Provider responsibilities; 103.4.1.2 Conflicts of interest; 103.4.1.3 Effective support and communication with HERS Raters; 103.4.1.4 103.4.1.5 Overview of the RESNET ANSI and Non-ANSI Standards; RESNET Quality Assurance requirements and the Rating Quality Assurance Provider’s responsibilities; 103.4.1.6 Requirements and responsibilities for using the National RESNET Registry; 103.4.1.7 RESNET and HERS Index logo use and brand consistency policies.
Do NOT replace. Replacement language MUST come from SDC 200.
SDC 900 task group will determine if participation of SDC 200 is required to develop or adopt details for training for providers since it is not technical
Modify the language as follows- 103.4.1 Prior to submitting an application for accreditation, applicants must participate in a current RESNET training for new providers.
Remove sections 103.4.1.1-103.4.1.7
Comment #99Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-7Paragraph / Figure / Table / Note: 103.4.1Comment Intent: Not an ObjectionComment Type: GeneralComment: Who will be providing this training? How often? Who specifically must attend? Proposed Change: N/A Just a question Response: Reject The comment doesn’t provide a standards change and the details requested are not a part of standards language.
Who will be providing this training? How often? Who specifically must attend?
Comment #100Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 7Paragraph / Figure / Table / Note: 103.4.1.2Comment Intent: Not an ObjectionComment Type: EditorialComment: I would like to add a line before "Conflicts of interest" to include training on Ethics & Bias in the minimum requirements of the training. Conflicts of interest are obviously an important thing to have training in, but having a broad understand of Ethics and how bias could affect your decision would be integral in becoming a Quality Assurance Provider. Proposed Change: 103.4.1.1 Rating Quality Assurance Provider responsibilities; 103.4.1.2 Ethics and bias; 103.4.1.23 Conflicts of interest; 103.4.1.34 Effective support and communication with HERS Raters; 103.4.1.45 Overview of the RESNET ANSI and Non-ANSI Standards; 103.4.1.56 RESNET Quality Assurance requirements and the Rating Quality Assurance Provider’s responsibilities; 103.4.1.67 Requirements and responsibilities for using the National RESNET Registry; 103.4.1.78 RESNET and HERS Index logo use and brand consistency policies. Response: Reject This language been remove per comment #98
I would like to add a line before "Conflicts of interest" to include training on Ethics & Bias in the minimum requirements of the training. Conflicts of interest are obviously an important thing to have training in, but having a broad understand of Ethics and how bias could affect your decision would be integral in becoming a Quality Assurance Provider.
103.4.1.1 Rating Quality Assurance Provider responsibilities;
103.4.1.2 Ethics and bias;
103.4.1.23 Conflicts of interest;
103.4.1.34 Effective support and communication with HERS Raters;
103.4.1.45 Overview of the RESNET ANSI and Non-ANSI Standards;
103.4.1.56 RESNET Quality Assurance requirements and the Rating Quality Assurance Provider’s responsibilities;
103.4.1.67 Requirements and responsibilities for using the National RESNET Registry;
103.4.1.78 RESNET and HERS Index logo use and brand consistency policies.
This language been remove per comment #98
Comment #101Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 8Paragraph / Figure / Table / Note: 103.4.2Comment Intent: ObjectionComment Type: TechnicalComment: This is what I have an issue with: 103.4.2 To apply for accreditation as a RESNET Rating Quality Assurance Provider, applicants must complete an accreditation application developed by RESNET that will demonstrate their understanding of the responsibilities of being a Direct Provider or Third-party Provider. This seems overly complicated- why don't you just tie being able to apply for accreditation to passing an exam at the end of the training required in proposed standard 103.4.1? I have to apply to be able to apply to get accreditation? It just seems complicated, and anything that can be done to streamline our aging framework would be beneficial. It just makes sense to have an exam rather than an application to be able to fill out an application. Proposed Change: 103.4.2 To apply for accreditation as a RESNET Rating Quality Assurance Provider, applicants must complete an accreditation application developed by RESNET that will demonstrate their understanding of the responsibilities of being a Direct Provider or Third-party Provider. have a certificate of completion from a training program which meets the requirements in Standard 103.4.1. Response: Accept Accept in principle. Modify language as follows- To apply for accreditation as a RESNET Rating Quality Assurance Provider, applicants must complete an accreditation application developed by RESNET and include a certificate of completion from the RESNET training for new Providers referenced in 103.4.1.
This is what I have an issue with:
This seems overly complicated- why don't you just tie being able to apply for accreditation to passing an exam at the end of the training required in proposed standard 103.4.1?
I have to apply to be able to apply to get accreditation? It just seems complicated, and anything that can be done to streamline our aging framework would be beneficial. It just makes sense to have an exam rather than an application to be able to fill out an application.
103.4.2 To apply for accreditation as a RESNET Rating Quality Assurance Provider, applicants must complete an accreditation application developed by RESNET that will demonstrate their understanding of the responsibilities of being a Direct Provider or Third-party Provider. have a certificate of completion from a training program which meets the requirements in Standard 103.4.1.
Modify language as follows- To apply for accreditation as a RESNET Rating Quality Assurance Provider, applicants must complete an accreditation application developed by RESNET and include a certificate of completion from the RESNET training for new Providers referenced in 103.4.1.
Comment #102Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-8Paragraph / Figure / Table / Note: 103.4.3Comment Intent: ObjectionComment Type: GeneralComment: This section is too wordy and confusing. Simply state what is required- if more words are needed to explain what you meant, edit to produce clarity of writing, not quantity. Ratings, by the way, are not going to be "accurate". "Accurate" implies a level of precision that is not defined anywhere in the Standard. Quality management is about producing repeatable ratings. Proposed Change: Strike the following language in its entirety: 103.4.3102.1.1 Submit Aa written Quality Assurance (QA) Process that conforms to Chapter 9 of these Standards and any specific QAQuality Assurance requirements for other Provider categories that may apply to a particular organization. The applicant’s written Quality Assurance Process shall explain how they intend to implement the Quality Assurance requirements outlined in Chapter 9. More specifically, the applicant must explain their process for monitoring the rating work of their HERS Raters, how they intend to ensure their HERS Rater’s are performing accurate ratings, and the applicant’s process for submitting ratings to the National RESNET Registry. Replace with: 103.4.3 Submit a written Quality Assurance Process that conforms to Chapter 9 of these Standards. Response: Accept
This section is too wordy and confusing. Simply state what is required- if more words are needed to explain what you meant, edit to produce clarity of writing, not quantity.
Ratings, by the way, are not going to be "accurate". "Accurate" implies a level of precision that is not defined anywhere in the Standard. Quality management is about producing repeatable ratings.
103.4.3102.1.1 Submit Aa written Quality Assurance (QA) Process that conforms to Chapter 9 of these Standards and any specific QAQuality Assurance requirements for other Provider categories that may apply to a particular organization. The applicant’s written Quality Assurance Process shall explain how they intend to implement the Quality Assurance requirements outlined in Chapter 9. More specifically, the applicant must explain their process for monitoring the rating work of their HERS Raters, how they intend to ensure their HERS Rater’s are performing accurate ratings, and the applicant’s process for submitting ratings to the National RESNET Registry.
103.4.3 Submit a written Quality Assurance Process that conforms to Chapter 9 of these Standards.
Comment #103Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-8Paragraph / Figure / Table / Note: 103.4.3Comment Intent: Not an ObjectionComment Type: EditorialComment: apostophe should be removed Proposed Change: 103.4.3102.1.1 Submit Aa written Quality Assurance (QA) Process that conforms to Chapter 9 of these Standards and any specific QAQuality Assurance requirements for other Provider categories that may apply to a particular organization. The applicant’s written Quality Assurance Process shall explain how they intend to implement the Quality Assurance requirements outlined in Chapter 9. More specifically, the applicant must explain their process for monitoring the rating work of their HERS Raters, how they intend to ensure their HERS Raters[D1] are performing accurate ratings, and the applicant’s process for submitting ratings to the National RESNET Registry. [D1]should not have apostrophe Response: Reject Language removed per comment #102
apostophe should be removed
103.4.3102.1.1 Submit Aa written Quality Assurance (QA) Process that conforms to Chapter 9 of these Standards and any specific QAQuality Assurance requirements for other Provider categories that may apply to a particular organization. The applicant’s written Quality Assurance Process shall explain how they intend to implement the Quality Assurance requirements outlined in Chapter 9. More specifically, the applicant must explain their process for monitoring the rating work of their HERS Raters, how they intend to ensure their HERS Raters[D1] are performing accurate ratings, and the applicant’s process for submitting ratings to the National RESNET Registry.
[D1]should not have apostrophe
Language removed per comment #102
Comment #104Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-8Paragraph / Figure / Table / Note: 103.4.3Comment Intent: ObjectionComment Type: GeneralComment: All of these policies and procedures must be fairly similar between different Providers. In the same way that REALTORS are provided with a template for a sales contract and architects are provided with templates for all of their documents and contracts, I believe that RESNET should provide detailed templates or generic documents that Providers can choose to adopt, modify, or rewrite to suit their needs. With these types of policies and procedures available, the industry will become more standardized and consistent while allowing Providers to address the specific needs and concerns within their markets and within their companies. Proposed Change: 103.4.3 Submit a written Quality Assurance Process that conforms to Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to a particular organization. The applicant’s written Quality Assurance Process shall explain how they intend to implement the Quality Assurance requirements outlined in Chapter 9. More specifically, the applicant must explain their process for monitoring the rating work of their HERS Raters, how they intend to ensure their HERS Rater’s are performing accurate ratings, and the applicant’s process for submitting ratings to the National RESNET Registry. The applicant may elect to use the policies and procedures written by RESNET, may amend the RESNET-created documents, or may submit alternative documents. Response: Reject Language removed per comment #102 and this is a policy recommendation
All of these policies and procedures must be fairly similar between different Providers.
In the same way that REALTORS are provided with a template for a sales contract and architects are provided with templates for all of their documents and contracts, I believe that RESNET should provide detailed templates or generic documents that Providers can choose to adopt, modify, or rewrite to suit their needs. With these types of policies and procedures available, the industry will become more standardized and consistent while allowing Providers to address the specific needs and concerns within their markets and within their companies.
103.4.3 Submit a written Quality Assurance Process that conforms to Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to a particular organization. The applicant’s written Quality Assurance Process shall explain how they intend to implement the Quality Assurance requirements outlined in Chapter 9. More specifically, the applicant must explain their process for monitoring the rating work of their HERS Raters, how they intend to ensure their HERS Rater’s are performing accurate ratings, and the applicant’s process for submitting ratings to the National RESNET Registry. The applicant may elect to use the policies and procedures written by RESNET, may amend the RESNET-created documents, or may submit alternative documents.
Language removed per comment #102 and this is a policy recommendation
Comment #105Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-8Paragraph / Figure / Table / Note: 103.4.5Comment Intent: ObjectionComment Type: EditorialComment: This proposed standard is inconsistent with the use of acronyms. Some acronyms have been edited to be written out (for example, striking "QA" and inserting "Quality Assurance". In this instance, the acronym "RFI" has been inserted and the term "Rating Field Inspector" was stricken. What's up with that? Proposed Change: Strike and replace as follows: 103.4.5 102.1.2.1 A QARating Quality Assurance Providers shall maintain documentation that their certified HERS Raters and Rating Field Inspectors RFI’s meet the certification provisions contained in Chapter Two of these sStandards. Response: Reject The intent was to use RFI through the document. The document will be checked before final release for consistency.
This proposed standard is inconsistent with the use of acronyms. Some acronyms have been edited to be written out (for example, striking "QA" and inserting "Quality Assurance".
In this instance, the acronym "RFI" has been inserted and the term "Rating Field Inspector" was stricken.
What's up with that?
Strike and replace as follows:
103.4.5 102.1.2.1 A QARating Quality Assurance Providers shall maintain documentation that their certified HERS Raters and Rating Field Inspectors RFI’s meet the certification provisions contained in Chapter Two of these sStandards.
The intent was to use RFI through the document. The document will be checked before final release for consistency.
Comment #106Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-10Paragraph / Figure / Table / Note: 103.4.6Comment Intent: ObjectionComment Type: GeneralComment: This section contains unenforceable permissive language. Proposed Change: Strike and replace as follows: 103.4.6 Rating Quality Assurance Provider shall provide a due process for appeals which allows their certified HERS Raters to appeal a probation, suspension, or revocation action taken against them by the Provider. The due process shall should, at a minimum, comply with RESNET procedures contained in Section 910.5 “Probation/Suspension/Revocation Due Process” of these Standards. Response: Accept
This section contains unenforceable permissive language.
103.4.6 Rating Quality Assurance Provider shall provide a due process for appeals which allows their certified HERS Raters to appeal a probation, suspension, or revocation action taken against them by the Provider. The due process shall should, at a minimum, comply with RESNET procedures contained in Section 910.5 “Probation/Suspension/Revocation Due Process” of these Standards.
Comment #107Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-10Paragraph / Figure / Table / Note: 103.4.6Comment Intent: Not an ObjectionComment Type: GeneralComment: Are these Rating Quality Assurance Providers Direct Providers, Third-Party Providers, or both? The language in this section and subsequent sections is unclear. I don't have a strong opinion either way, except that the division of responsibility between all parties be clearly defined. Proposed Change: 103.4.6 Rating Quality Assurance Providers shall provide a due process for appeals which allows their certified HERS Raters to appeal a probation, suspension, or revocation action taken against them by their Provider. The due process shallshould, at a minimum, comply with RESNET procedures contained in Section 910.5 “Probation/Suspension/Revocation Due Process.” of these Standards. Response: Accept
Are these Rating Quality Assurance Providers Direct Providers, Third-Party Providers, or both? The language in this section and subsequent sections is unclear. I don't have a strong opinion either way, except that the division of responsibility between all parties be clearly defined.
103.4.6 Rating Quality Assurance Providers shall provide a due process for appeals which allows their certified HERS Raters to appeal a probation, suspension, or revocation action taken against them by their Provider. The due process shallshould, at a minimum, comply with RESNET procedures contained in Section 910.5 “Probation/Suspension/Revocation Due Process.” of these Standards.
Comment #108Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-10Paragraph / Figure / Table / Note: 103.4.7.1Comment Intent: ObjectionComment Type: TechnicalComment: The RESNET Standards do not cover "diagnostic" services. Proposed Change: Strike and replace as follows: 103.4.7.1 As a condition of HERS Rater certification, each QARating Quality Assurance Provider shall ensure that a certified HERS Rater who has met the requirements of Chapter 2, Rater Training Requirements, has entered into a written agreement with the QARating Quality Assurance Provider to provide home energy rating, field verification, and diagnostic testing services in compliance with these standards. Response: Accept The working group acknowledges that this proposed change is not proposed standard revision and recommends accepting it. This change will go out for public comment
The RESNET Standards do not cover "diagnostic" services.
103.4.7.1 As a condition of HERS Rater certification, each QARating Quality Assurance Provider shall ensure that a certified HERS Rater who has met the requirements of Chapter 2, Rater Training Requirements, has entered into a written agreement with the QARating Quality Assurance Provider to provide home energy rating, field verification, and diagnostic testing services in compliance with these standards.
The working group acknowledges that this proposed change is not proposed standard revision and recommends accepting it. This change will go out for public comment
Comment #109Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-10Paragraph / Figure / Table / Note: 103.4.7.2.1Comment Intent: ObjectionComment Type: TechnicalComment: The use of the terms "accurate" and "fair" are subjective and unenforceable. Proposed Change: Strike and replace as follows: 103.4.7.2.1102.1.2.5.1 Provide accurate and fair ratings, field verification, and testing, and ratings in compliance with these sStandards and RESNET Board of Directors- approved Standards Management Board’s interpretations; Response: Accept Accept in part- 103.4.7.2.1102.1.2.5.1 Provide accurate and fair ratings, field verification and testing in compliance with these sStandards and RESNET Board of Directors-approved Standards Management Board’s interpretations; The working group acknowledges that this proposed change is not proposed standard revision and recommends accepting it. This change will go out for public comment
The use of the terms "accurate" and "fair" are subjective and unenforceable.
103.4.7.2.1102.1.2.5.1 Provide accurate and fair ratings, field verification, and testing, and ratings in compliance with these sStandards and RESNET Board of Directors- approved Standards Management Board’s interpretations;
Accept in part-
103.4.7.2.1102.1.2.5.1 Provide accurate and fair ratings, field verification and testing in compliance with these sStandards and RESNET Board of Directors-approved Standards Management Board’s interpretations; The working group acknowledges that this proposed change is not proposed standard revision and recommends accepting it. This change will go out for public comment
Comment #110Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-10Paragraph / Figure / Table / Note: 103.4.7.2.3Comment Intent: ObjectionComment Type: TechnicalComment: The use of the term "specific" is vague when the "specific" elements are left unidentified. If it is vague, it is generally considered unenforceable. Proposed Change: Strike the following in its entirety: 103.4.7.2.3102.1.2.5.3 Provide specific statistical information about number and type of ratings conducted as when requested by the QARating Quality Assurance Provider, including but not limited to the names of any Rating Field Inspectors (RFI’s) utilized to complete submitted ratings. Replace with: 103.4.7.2.3 Provide the information on ratings conducted when requested by the Rating Quality Assurance Provider. Response: Accept Accept as modified Modify to: Provide any information requested on ratings by the Quality Assurance Provider.
The use of the term "specific" is vague when the "specific" elements are left unidentified. If it is vague, it is generally considered unenforceable.
Strike the following in its entirety:
103.4.7.2.3102.1.2.5.3 Provide specific statistical information about number and type of ratings conducted as when requested by the QARating Quality Assurance Provider, including but not limited to the names of any Rating Field Inspectors (RFI’s) utilized to complete submitted ratings.
103.4.7.2.3 Provide the information on ratings conducted when requested by the Rating Quality Assurance Provider.
Accept as modified Modify to: Provide any information requested on ratings by the Quality Assurance Provider.
Comment #111Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-10Paragraph / Figure / Table / Note: 103.4.7.2.4 (new)Comment Intent: ObjectionComment Type: TechnicalComment: HERS Raters should be required to participate in trainings or webinars when standards are updated. Perhaps the training is a pre-recorded webinar that can be accessed via individual credentials, or perhaps the training is a live webinar that is offered at multiple times of day over the course of a few weeks. Either way, I believe that changes to the standards are not making their way to the individuals who must implement them in the field. It must be the Provider's explicit responsibility to train their HERS Raters on a regular basis since Providers are tasked with assuring the quality of their Raters' work. Proposed Change: 103.4.7.2.4 Participate in annual training activities that address changes to the RESNET Standards. Response: Accept Participate in training activities that address changes to the RESNET Standards when required.
HERS Raters should be required to participate in trainings or webinars when standards are updated. Perhaps the training is a pre-recorded webinar that can be accessed via individual credentials, or perhaps the training is a live webinar that is offered at multiple times of day over the course of a few weeks. Either way, I believe that changes to the standards are not making their way to the individuals who must implement them in the field. It must be the Provider's explicit responsibility to train their HERS Raters on a regular basis since Providers are tasked with assuring the quality of their Raters' work.
103.4.7.2.4 Participate in annual training activities that address changes to the RESNET Standards.
Participate in training activities that address changes to the RESNET Standards when required.
Comment #112Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-10Paragraph / Figure / Table / Note: 103.4.8Comment Intent: Not an ObjectionComment Type: EditorialComment: The way this paragraph is currently written (with the changes proposed) the Rating Provider is required to properly accredit HERS Rating Software. It is not the Rating Provider's job to accredit software. I know we are not supposed to mess with words that are not underlined or struck through, however, the easiest method of making this section say what is intended is to make a small change to a currently untouched word. Proposed Change: A Rating Quality Assurance Provider shall ensure that the HERS Rating Software Program used to produce energy ratings is has been properly accredited by RESNET. The directory of RESNET accredited HERS Rating Software Programs are posted on the RESNET web site. Response: Accept
The way this paragraph is currently written (with the changes proposed) the Rating Provider is required to properly accredit HERS Rating Software. It is not the Rating Provider's job to accredit software. I know we are not supposed to mess with words that are not underlined or struck through, however, the easiest method of making this section say what is intended is to make a small change to a currently untouched word.
A Rating Quality Assurance Provider shall ensure that the HERS Rating Software Program used to produce energy ratings is has been properly accredited by RESNET. The directory of RESNET accredited HERS Rating Software Programs are posted on the RESNET web site.
Comment #113Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 11Paragraph / Figure / Table / Note: 103.4.8.2.1Comment Intent: ObjectionComment Type: GeneralComment: I have an issue with the language highlighted: 103.4.9.2.1 Written conflict of interest provisions prohibit undisclosed conflicts of interest but allows for a waiver with advance disclosure. The RESNET “Home Energy Rating Standard Disclosure” (Standard Disclosure) form shall be completed for each home that receives a home energy rating and that has a conflict to disclose. If none of the conflicts listed on the RESNET Standard Disclosure form apply, then a Standard Disclosure form is not required. Why was this added? To save someone time doing some paperwork? I believe this should be struck to ensure everyone must strongly hold to an ethical framework. Allowing people to not fill out a disclosure form could lead people to game the system because, "Well, it's not really in there, so I don't need to disclose it." Proposed Change: 103.4.9.2.1 Written conflict of interest provisions prohibit undisclosed conflicts of interest but allows for a waiver with advance disclosure. The RESNET “Home Energy Rating Standard Disclosure” (Standard Disclosure) form shall be completed for each home that receives a home energy rating and that has a conflict to disclose. If none of the conflicts listed on the RESNET Standard Disclosure form apply, then a Standard Disclosure form is not required. Response: Accept 103.4.9.2.1 Written conflict of interest provisions prohibit undisclosed conflicts of interest but allows for a waiver with advance disclosure. The RESNET “Home Energy Rating Standard Disclosure” (Standard Disclosure) form shall be completed for each home that receives a home energy rating and that has a conflict to disclose. If none of the conflicts listed on the RESNET Standard Disclosure form apply, then a Standard Disclosure form is not required.
I have an issue with the language highlighted:
103.4.9.2.1 Written conflict of interest provisions prohibit undisclosed conflicts of interest but allows for a waiver with advance disclosure. The RESNET “Home Energy Rating Standard Disclosure” (Standard Disclosure) form shall be completed for each home that receives a home energy rating and that has a conflict to disclose. If none of the conflicts listed on the RESNET Standard Disclosure form apply, then a Standard Disclosure form is not required.
Why was this added? To save someone time doing some paperwork? I believe this should be struck to ensure everyone must strongly hold to an ethical framework. Allowing people to not fill out a disclosure form could lead people to game the system because, "Well, it's not really in there, so I don't need to disclose it."
Comment #114Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 11Paragraph / Figure / Table / Note: 103.4.9.1Comment Intent: Not an ObjectionComment Type: GeneralComment: This should also include the File QA of minimum rated features. Proposed Change: 103.4.9.1 Field and File verification of Minimum Rated Features and labeling of all homes in shall compliance with Chapter 3 and Appendix A of these Standards. Response: Accept
This should also include the File QA of minimum rated features.
103.4.9.1 Field and File verification of Minimum Rated Features and labeling of all homes in shall compliance with Chapter 3 and Appendix A of these Standards.
Comment #115Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 11Paragraph / Figure / Table / Note: 103.4.9.1Comment Intent: Not an ObjectionComment Type: GeneralComment: This should also include the File QA of minimum rated features. Proposed Change: 103.4.9.1 Field and File verification of Minimum Rated Features and labeling of all homes in shall compliance with Chapter 3 and Appendix A of these Standards. Response: Accept
Comment #116Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 103.4.9.2-103.4.9.2.4Comment Intent: ObjectionComment Type: EditorialComment: The initial section is incomplete and should be replaced by the immediate subsequent section with the remaining sub-sections renumbered accordingly. Proposed Change: Strike the following in its entirety: 103.4.9.2102.1.4.6 Written conflict of interest provisions. Replace with the following, renumbered accordingly: 103.4.9.2.1 Written conflict of interest provisions that prohibits undisclosed conflicts of interest but allows for a waiver with advanced disclosure. The RESNET “Home Energy Rating Standard Disclosure” (Standard Disclosure) form adopted by the RESNET Board of Directors shall be completed for each home that receives a home energy rating and that has a conflict to disclose. If none of the conflicts listed on the RESNET Standard Disclosure form apply, then a Standard Disclosure form is not required. Response: Reject Need a section header
The initial section is incomplete and should be replaced by the immediate subsequent section with the remaining sub-sections renumbered accordingly.
103.4.9.2102.1.4.6 Written conflict of interest provisions.
Replace with the following, renumbered accordingly:
103.4.9.2.1 Written conflict of interest provisions that prohibits undisclosed conflicts of interest but allows for a waiver with advanced disclosure. The RESNET “Home Energy Rating Standard Disclosure” (Standard Disclosure) form adopted by the RESNET Board of Directors shall be completed for each home that receives a home energy rating and that has a conflict to disclose. If none of the conflicts listed on the RESNET Standard Disclosure form apply, then a Standard Disclosure form is not required.
Need a section header
Comment #117Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 103.4.9.2.1Comment Intent: ObjectionComment Type: TechnicalComment: The final sentence in this paragraph takes the intent one step too far. Unless RESNET really believes that it can include every possible real and perceived conflict of interest scenario in the new COI form, the final sentence should be removed. Proposed Change: 103.4.9.2.1 Written conflict of interest provisions prohibit undisclosed conflicts of interest but allow for a waiver with advance disclosure. The RESNET “Home Energy Rating Standard Disclosure” (Standard Disclosure) form shall be completed for each home that receives a home energy rating and that has a conflict to disclose. If none of the conflicts listed on the RESNET Standard Disclosure form apply, then a Standard Disclosure form is not required. Response: Accept Accept as modified below 103.4.9.2.1 Written conflict of interest provisions prohibit undisclosed conflicts of interest but allows for a waiver with advance disclosure. The RESNET “Home Energy Rating Standard Disclosure” (Standard Disclosure) form shall be completed for each home that receives a home energy rating and that has a conflict to disclose. If none of the conflicts listed on the RESNET Standard Disclosure form apply, then a Standard Disclosure form is not required.
The final sentence in this paragraph takes the intent one step too far. Unless RESNET really believes that it can include every possible real and perceived conflict of interest scenario in the new COI form, the final sentence should be removed.
103.4.9.2.1 Written conflict of interest provisions prohibit undisclosed conflicts of interest but allow for a waiver with advance disclosure. The RESNET “Home Energy Rating Standard Disclosure” (Standard Disclosure) form shall be completed for each home that receives a home energy rating and that has a conflict to disclose. If none of the conflicts listed on the RESNET Standard Disclosure form apply, then a Standard Disclosure form is not required.
Accept as modified below
Comment #118Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 103.4.9.2.2Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: ObjectionComment Type: GeneralComment: General Objection: If HERS Raters and their companies are prohibited from offering add-on services to their clients (e.g. HVAC work, insulation work, etc.), the cost for the HERS Rating activities will sky-rocket and HERS Ratings will become cost prohibitive. Obviously there is a cap to how much a builder will be willing to pay for these services. It is common to hear in Massachusetts that the fact that HERS Rating companies offer these additional services is a significant component to towns adopting the Stretch Code (which mandates HERS Ratings.) Lastly, it is important to point out the current QA requirements are significant and unparalleled in other industries. It seems that randomly inspecting 1 out of every 10 HERS Ratings done should more than suffice to limit misconduct on behalf of Raters. Has there been sufficient misconduct to require such a significant change in the industry? I, for one, can state unequivically that my company will stop performing HERS Ratings if this amendment is adopted. Proposed Change: Strike "Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations" Include "Home builders are explicitly prevented from conducting ratings on their own homes" (which is exactly the language presented in the Presentation entitled: Enhancing the Quality Assurance Oversight of HERS Ratings on slide 10.) Response: Accept in principle Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
General Objection: If HERS Raters and their companies are prohibited from offering add-on services to their clients (e.g. HVAC work, insulation work, etc.), the cost for the HERS Rating activities will sky-rocket and HERS Ratings will become cost prohibitive. Obviously there is a cap to how much a builder will be willing to pay for these services.
It is common to hear in Massachusetts that the fact that HERS Rating companies offer these additional services is a significant component to towns adopting the Stretch Code (which mandates HERS Ratings.)
Lastly, it is important to point out the current QA requirements are significant and unparalleled in other industries. It seems that randomly inspecting 1 out of every 10 HERS Ratings done should more than suffice to limit misconduct on behalf of Raters.
Has there been sufficient misconduct to require such a significant change in the industry? I, for one, can state unequivically that my company will stop performing HERS Ratings if this amendment is adopted.
Strike "Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations"
Include "Home builders are explicitly prevented from conducting ratings on their own homes" (which is exactly the language presented in the Presentation entitled: Enhancing the Quality Assurance Oversight of HERS Ratings on slide 10.)
Accept in principle
Comment #119Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: ObjectionComment Type: GeneralComment: So long as a disclousure is provided to the customer, a contractor providing services to the residence should be able to have one of their employees issue a HERS rating, so long as they are not the same person who actually installed the material or work in this particular home. Proposed Change: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall be able to conduct ratings so long as they are not the same people who installed the products or services on the home Response: Reject 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
So long as a disclousure is provided to the customer, a contractor providing services to the residence should be able to have one of their employees issue a HERS rating, so long as they are not the same person who actually installed the material or work in this particular home.
103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall be able to conduct ratings so long as they are not the same people who installed the products or services on the home
103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
Comment #120Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: Not an ObjectionComment Type: GeneralComment: The Northeast HERS Alliance takes no position on this issue and proposes no specific language, but requests that RESNET provide clarification as to whether the following entities are included under the restriction from providing HERS ratings under this section: Subcontractors who are engaged in the construction of the home; Vendors who supply products that are installed in the home but provide no services to install these products; Design professionals – architects, engineers and others who provide design services but provide no services to install these products. Response: Reject Only position statement and no proposed language. See comment #118 for revised language
The Northeast HERS Alliance takes no position on this issue and proposes no specific language, but requests that RESNET provide clarification as to whether the following entities are included under the restriction from providing HERS ratings under this section:
Only position statement and no proposed language. See comment #118 for revised language
Comment #121Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: ObjectionComment Type: GeneralComment: I agree that home builders should not be allowed to rate their own homes. The current wording, however, also indicates that ANY contractor involved with the construction of the house (insulator, HVAC, air sealing, etc) will NOT be able to rate that particular house. I object to that. Subcontractors should be allowed to rate homes they work on. The Quality Agent should use their discretion to evaluate if additional QA is required. For example, a Quality Agent may require an insulator provides photos documenting the insulation grade. Proposed Change: As proposed text: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply. New proposed text: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply. Subcontracted companies (including their employees), such as insulators, HVAC, plumbing, and framing, are allowed to conduct ratings on any homes or buildings for which they provide services. Response: Accept in principle Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
I agree that home builders should not be allowed to rate their own homes. The current wording, however, also indicates that ANY contractor involved with the construction of the house (insulator, HVAC, air sealing, etc) will NOT be able to rate that particular house. I object to that. Subcontractors should be allowed to rate homes they work on. The Quality Agent should use their discretion to evaluate if additional QA is required. For example, a Quality Agent may require an insulator provides photos documenting the insulation grade.
As proposed text:
103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply.
New proposed text:
103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply. Subcontracted companies (including their employees), such as insulators, HVAC, plumbing, and framing, are allowed to conduct ratings on any homes or buildings for which they provide services.
Comment #122Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 11 (1-11)Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: ObjectionComment Type: TechnicalComment: Language should be made clearer as to what level of involvement in the construction is allowed for a HERS rater / provideer to provide. Raters / providers should not be allowed if they have an financial interest in the general contractor / primary builder or higher. Raters / providers should be able to contract for any other services to the general contractor / builder of record. Proposed Change: Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or determined to be the general contractor general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply. Response: Accept in principle Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
Language should be made clearer as to what level of involvement in the construction is allowed for a HERS rater / provideer to provide. Raters / providers should not be allowed if they have an financial interest in the general contractor / primary builder or higher. Raters / providers should be able to contract for any other services to the general contractor / builder of record.
Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or determined to be the general contractor general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply.
Comment #123Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: ObjectionComment Type: EditorialComment: 103.4.9.2.2 States: “Companies… who… are directly engaged in… general contracting of services for the construction of homes or buildings for which HERS rating are provided…” • There is not a clear definition for the term “general contracting of services.” • Many HERS Rating companies are involved in the design of HVAC equipment in the homes they conduct HERS Ratings on. In many cases, the HERS Rating company is better equipped, in training and knowledge, to design HVAC systems than is the HVAC contractor performing the installation. It is in the best interest of the industry for HERS Raters to be involved with the design of such aspects of the buildings and homes they are contracted to perform HERS Ratings on. As such, a company installing the HVAC equipment, insulation, or any other Rated feature of a home or building should not be permitted to judge their own work, as this would cause an obvious conflict of interest and is covered by the new standards. But, it is in the industries best interest to allow HERS Raters to continue designing Rated systems and consult on Rated systems in homes and buildings they are performing the rating on. Wording such as “General Contracting of Services” can reasonably be interpreted as receiving compensation for anything other than HERS Ratings, which could lead to the failure of many Rating industry businesses due to the loss of a large percentage of their business. Proposed Change: • Recommend rewriting as follows: 103.4.9.2.2 Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of general contracting of services, or who are directly involved in the installation of any Rated features for the construction of homes or buildings for which HERS rating(s) are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply. Response: Accept in principle Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
103.4.9.2.2 States: “Companies… who… are directly engaged in… general contracting of services for the construction of homes or buildings for which HERS rating are provided…” • There is not a clear definition for the term “general contracting of services.” • Many HERS Rating companies are involved in the design of HVAC equipment in the homes they conduct HERS Ratings on. In many cases, the HERS Rating company is better equipped, in training and knowledge, to design HVAC systems than is the HVAC contractor performing the installation. It is in the best interest of the industry for HERS Raters to be involved with the design of such aspects of the buildings and homes they are contracted to perform HERS Ratings on. As such, a company installing the HVAC equipment, insulation, or any other Rated feature of a home or building should not be permitted to judge their own work, as this would cause an obvious conflict of interest and is covered by the new standards. But, it is in the industries best interest to allow HERS Raters to continue designing Rated systems and consult on Rated systems in homes and buildings they are performing the rating on. Wording such as “General Contracting of Services” can reasonably be interpreted as receiving compensation for anything other than HERS Ratings, which could lead to the failure of many Rating industry businesses due to the loss of a large percentage of their business.
• Recommend rewriting as follows: 103.4.9.2.2 Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of general contracting of services, or who are directly involved in the installation of any Rated features for the construction of homes or buildings for which HERS rating(s) are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply.
Comment #124Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: ObjectionComment Type: TechnicalComment: Subcontracted companies should be allowed to rate homes they work on, as long as they are not the same individual involved with the actual installation. A standard disclosure would definately need to be submtited for a situation like this Proposed Change: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply. Subcontracted companies (including their employees), such as insulators, HVAC, plumbing, and framing, are allowed to conduct ratings on any homes or buildings for which they provide services, so long as they are not the same people who installed the products or services on the home and a standard disclosure is provided Response: Accept in principle Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
Subcontracted companies should be allowed to rate homes they work on, as long as they are not the same individual involved with the actual installation. A standard disclosure would definately need to be submtited for a situation like this
103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply. Subcontracted companies (including their employees), such as insulators, HVAC, plumbing, and framing, are allowed to conduct ratings on any homes or buildings for which they provide services, so long as they are not the same people who installed the products or services on the home and a standard disclosure is provided
Comment #125Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: ObjectionComment Type: GeneralComment: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply. Assuming that Chapter 1, Sec. 103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. is adopted. The policing function is in place. An independent audit will always be conducted by a “Quality Agent”. There is no more or less conflict of interest at the auditor level for either a “Certified HERS Rater working for a sublevel trade or as an independent contractor. They are both working for payment from the builder. A solely dependent rater may be under the same or even greater individual pressure than an organization that has multiple lines of business. Proposed Change: Strike the proposed language in 103.4.9.2.2 and make the related changes. 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or management or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply Response: Accept in principle Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
Assuming that Chapter 1, Sec. 103.1.1 Direct Providers must contract with one or more independent Quality Assurance Contractors who employ one or more Quality Agents certified by RESNET. Quality Assurance Contractors will oversee the Provider’s compliance with Chapter 9 of these Standards and any specific Quality Assurance requirements for other Provider categories that may apply to the organization. is adopted. The policing function is in place. An independent audit will always be conducted by a “Quality Agent”. There is no more or less conflict of interest at the auditor level for either a “Certified HERS Rater working for a sublevel trade or as an independent contractor. They are both working for payment from the builder. A solely dependent rater may be under the same or even greater individual pressure than an organization that has multiple lines of business.
Strike the proposed language in 103.4.9.2.2 and make the related changes.
103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or management or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply
Comment #126Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: ObjectionComment Type: TechnicalComment: This statement is very broad and hard to nail down exactly what is meant. What does "directly engaged in the construction of" mean? Does this include architects and engineers? Does this impact Raters who also perform heat load calcs and provide Manual J, S, & D reports for homes? RESNET is currently encouraging Raters to consider becoming Code Inspectors as well. Would they be included? A home cannot be constructed if inspections are not performed - is this considered "directly engaged"? If an individual owns both an insulation company and a rating company, are the employees of the rating company no longer allowed to perform ratings? Does it affect these types of organizations even if they did not perform any of these services on the home being rated? In areas where only low-volume raters exist the industry has had to adjust to be able to have the ability to perform HERS Ratings. HERS Raters have worked to provide services required by EEPs. The way this paragraph is currently written, these HERS Raters would no longer be allowed to perform Ratings. The paragraph needs to be made much more explicit. I can make an attempt; however, without truly understanding the full intent behind this paragraph, it may not be comprehensive or acceptable. Proposed Change: Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply and for which the individual performing the HERS Rating has conducted the service. The individual performing the HERS Rating is allowed to perform additional inspection and verification services related to the construction of the home, including but not limited to Code Inspections, EEP verification services and other program related testing and verification services for which the individual is properly qualified. In addition, the individual performing the HERS Rating is allowed to perform design-related services on the same home as allowed by the program for which the rating is being performed and when properly disclosed. These design-related services include but are not limited to architectural, engineering and HVAC equipment sizing, design and selection services. Response: Accept in principle Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
This statement is very broad and hard to nail down exactly what is meant. What does "directly engaged in the construction of" mean? Does this include architects and engineers? Does this impact Raters who also perform heat load calcs and provide Manual J, S, & D reports for homes? RESNET is currently encouraging Raters to consider becoming Code Inspectors as well. Would they be included? A home cannot be constructed if inspections are not performed - is this considered "directly engaged"? If an individual owns both an insulation company and a rating company, are the employees of the rating company no longer allowed to perform ratings? Does it affect these types of organizations even if they did not perform any of these services on the home being rated?
In areas where only low-volume raters exist the industry has had to adjust to be able to have the ability to perform HERS Ratings. HERS Raters have worked to provide services required by EEPs. The way this paragraph is currently written, these HERS Raters would no longer be allowed to perform Ratings. The paragraph needs to be made much more explicit. I can make an attempt; however, without truly understanding the full intent behind this paragraph, it may not be comprehensive or acceptable.
Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply and for which the individual performing the HERS Rating has conducted the service. The individual performing the HERS Rating is allowed to perform additional inspection and verification services related to the construction of the home, including but not limited to Code Inspections, EEP verification services and other program related testing and verification services for which the individual is properly qualified. In addition, the individual performing the HERS Rating is allowed to perform design-related services on the same home as allowed by the program for which the rating is being performed and when properly disclosed. These design-related services include but are not limited to architectural, engineering and HVAC equipment sizing, design and selection services.
Comment #127Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: ObjectionComment Type: EditorialComment: Let's not throw out the baby with the bath water ... Or get rid of many of our better rating companies who have worked hard and invested in building real “Rating Systems” with actual Quality Assurance processes in an attempt to appear to improve the perception of RESNET performance. Doing so could reduce the overall quality of Rating Firms, fail to improve transparency and do little to provide improvement for the quality or consistency of ratings. Proposed Change: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply. Exception: Companies engaged in the construction and HERS ratings of homes or buildings that can demonstrate to their Rating Quality Assurance Provider that they have instituted policies and procedures to ensure the necessary separation of their Rating and Construction activities, shall be allowed to conduct ratings. The minimum standards for necessary separation shall be: • Separation of financial statements, • Separation of leadership between the entities controlling the construction and rating activites, • Significant investment in technology, training and/or processes to ensure Quality Assurance provisions are otherwise met. Response: Accept in principle Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
Let's not throw out the baby with the bath water ... Or get rid of many of our better rating companies who have worked hard and invested in building real “Rating Systems” with actual Quality Assurance processes in an attempt to appear to improve the perception of RESNET performance. Doing so could reduce the overall quality of Rating Firms, fail to improve transparency and do little to provide improvement for the quality or consistency of ratings.
Exception: Companies engaged in the construction and HERS ratings of homes or buildings that can demonstrate to their Rating Quality Assurance Provider that they have instituted policies and procedures to ensure the necessary separation of their Rating and Construction activities, shall be allowed to conduct ratings. The minimum standards for necessary separation shall be: • Separation of financial statements, • Separation of leadership between the entities controlling the construction and rating activites, • Significant investment in technology, training and/or processes to ensure Quality Assurance provisions are otherwise met.
Comment #128Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: Not an ObjectionComment Type: TechnicalComment: We interpret this section to include general contractors (aka, home builders), but not subcontractors, trades, architects, engineers or design professionals, and would like to propose clarifying language to ensure that the intent of this section is not misinterpreted to preclude companies who are performing subcontracted services on the project from also performing the HERS rating. Proposed Change: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting the general contractor of services for the construction of homes or buildings for which HERS ratings are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply. Response: Accept in principle Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
We interpret this section to include general contractors (aka, home builders), but not subcontractors, trades, architects, engineers or design professionals, and would like to propose clarifying language to ensure that the intent of this section is not misinterpreted to preclude companies who are performing subcontracted services on the project from also performing the HERS rating.
103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting the general contractor of services for the construction of homes or buildings for which HERS ratings are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply.
Comment #129Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: Not an ObjectionComment Type: GeneralComment: Does this include HVAC & insulation contractors? Proposed Change: N/A Just a question Response: Reject Question only; no proposed language. See comment #118 for revised language
Does this include HVAC & insulation contractors?
Question only; no proposed language. See comment #118 for revised language
Comment #130Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: Not an ObjectionComment Type: TechnicalComment: Construction should be better defined to include any aspects of the design or construction of the homes or buildings for which HERS Ratings are provided. HERS Ratings should be a true third-party evaluation of the home being Rated. This precedent was set in our industry by both LEED and the NGBS. Proposed Change: 103.4.9.2.2 Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply. Rewrite to say: 103.4.9.2.2 Companies and individuals who own, provide funding for, and/or are directly engaged in the design or construction of any homes that receive HERS Ratings shall not participate in the HERS Ratings on those homes. Response: Accept in principle Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
Construction should be better defined to include any aspects of the design or construction of the homes or buildings for which HERS Ratings are provided.
HERS Ratings should be a true third-party evaluation of the home being Rated. This precedent was set in our industry by both LEED and the NGBS.
103.4.9.2.2 Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply.
Rewrite to say:
103.4.9.2.2 Companies and individuals who own, provide funding for, and/or are directly engaged in the design or construction of any homes that receive HERS Ratings shall not participate in the HERS Ratings on those homes.
Comment #131Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: ObjectionComment Type: TechnicalComment: The previous wording left some loopholes that need to be eliminated. I believe my alternate wording leaves nothing to the imagination or interpretation of a person who installs any element into a home or has an interest in the home being rated. Note this was a topic discussed on the webinar call and both Andy and Laurel had some difficulty with interpretation of say ...an insulation contractor being able to provide ratings....I believe my alternate wording covers this. Feel free to editorialize. Proposed Change: 103.4.9.2.2 Home builders and their employees Any person who is engaged in the supply or installation of any element in a home are not allowed to conduct ratings on the homes they build provide products to or installation of any element or for which they have a financial interest in. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the supply or installation of any element of the construction of a home or general contracting of services for the construction of homes or buildings for which a HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply. Response: Accept in principle Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
The previous wording left some loopholes that need to be eliminated. I believe my alternate wording leaves nothing to the imagination or interpretation of a person who installs any element into a home or has an interest in the home being rated. Note this was a topic discussed on the webinar call and both Andy and Laurel had some difficulty with interpretation of say ...an insulation contractor being able to provide ratings....I believe my alternate wording covers this. Feel free to editorialize.
103.4.9.2.2 Home builders and their employees Any person who is engaged in the supply or installation of any element in a home are not allowed to conduct ratings on the homes they build provide products to or installation of any element or for which they have a financial interest in. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the supply or installation of any element of the construction of a home or general contracting of services for the construction of homes or buildings for which a HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply.
Comment #132Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: Not an ObjectionComment Type: GeneralComment: This section needs clarity around exactly who the financial arrangement impacts. We have seen: Very successful HVAC companies also providing Ratings and Verification Companies that provide multiple services and do not provide fair Ratings Designers that utilize REM/Design and give the files to Raters as a preliminary rating file. Are they out? Real Estate Pros who may touch Rating files via EEMs or MLS listings. Are they not allowed to be Raters or merely need to disclose? Considering that the entire Rating industry is moving towards allowing Raters to also be code inspectors (one merely provides a Rating, while the other may impact occupancy) is already opening the doors to folks questioning why a Rater may Rate a home a certain way. We vehemently agree that allowing Verification/Rating to happen when a contractor is deeply involved in the home encourages poor quality Ratings and should not be allowed. The issue is that there are some types of financial or service providing relationships that are different from others. We hope that this discussion may fine a comprimise that allows established companies to modify their current offerings and not have to remove them entirely. If not a full comprimise, at least greater definition is needed for this section. Proposed Change: Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply without signing a disclosure agreement. Companies providing more than one service (HVAC and water heating, or Insulation and windows) are prohibited from providing Ratings, but may collect data as RFIs. Response: Accept in principle Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
This section needs clarity around exactly who the financial arrangement impacts. We have seen:
Considering that the entire Rating industry is moving towards allowing Raters to also be code inspectors (one merely provides a Rating, while the other may impact occupancy) is already opening the doors to folks questioning why a Rater may Rate a home a certain way.
We vehemently agree that allowing Verification/Rating to happen when a contractor is deeply involved in the home encourages poor quality Ratings and should not be allowed. The issue is that there are some types of financial or service providing relationships that are different from others. We hope that this discussion may fine a comprimise that allows established companies to modify their current offerings and not have to remove them entirely. If not a full comprimise, at least greater definition is needed for this section.
Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply without signing a disclosure agreement. Companies providing more than one service (HVAC and water heating, or Insulation and windows) are prohibited from providing Ratings, but may collect data as RFIs.
Comment #133Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: 103.4.9.2.2Comment Intent: ObjectionComment Type: EditorialComment: A broad interpretation of "general contracting services" could include sub-contractor companies such as ours or HVAC companies currently in the testing business. We have gone to great lengths to ensure the intergity and quaity of our rating services,and in many instances exceeding thse of "rating only contractors". The original language is adequate and should remain - no need for change. We agree that there should be parameters that sperate such businesses such as: *Seperation of financial statements *Seperation of leadership between entities *Seperation of employees - product installers at no time can conduct ratings or inspections In this instance we adhere to all of the above conditions and organizations such as ours have shown the ability to provide quality and integrity in all of the services we provide. At face value this appears to just be a method to eliminate legitimate competition. Response: Accept Accept in principle Modify to: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest.
A broad interpretation of "general contracting services" could include sub-contractor companies such as ours or HVAC companies currently in the testing business. We have gone to great lengths to ensure the intergity and quaity of our rating services,and in many instances exceeding thse of "rating only contractors". The original language is adequate and should remain - no need for change. We agree that there should be parameters that sperate such businesses such as:
*Seperation of financial statements
*Seperation of leadership between entities
*Seperation of employees - product installers at no time can conduct ratings or inspections
In this instance we adhere to all of the above conditions and organizations such as ours have shown the ability to provide quality and integrity in all of the services we provide.
At face value this appears to just be a method to eliminate legitimate competition.
Comment #134Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 11Paragraph / Figure / Table / Note: 103.4.9.2.3Comment Intent: ObjectionComment Type: GeneralComment: I have an issue with the highlighted language: 103.4.9.2.3 A RESNET Standard Disclosure form shall be provided to the rating client and shall also be made available to the home owner/buyer upon request by the home owner/buyer. I understand that this may have been added because: "I can't hand this paper to the home buyer/owner because they're not my client!" But that is no excuse. Rating companies can include a provision within their contracts that requires the builder/client to include the standard disclosure form with the paperwork that the home buyer/owner receives when the home closes. A home owner deserves to know as much as they can about the home- that includes knowing whether or not there were any conflict of interests on the HERS side. This language should be struck to provide the new home owner as much information as possible, and it's relatively easy for rating companies to include a provision in their contract that requires the builder/remodeler/client Proposed Change: 103.4.9.2.3 A RESNET Standard Disclosure form shall be provided to the rating client and shall also be made available to the home owner/buyer upon request by the home owner/buyer. Response: Accept as modified below Reason: 103.4.9.2.3 A RESNET Standard Disclosure form shall be provided to the rating client
I have an issue with the highlighted language:
103.4.9.2.3 A RESNET Standard Disclosure form shall be provided to the rating client and shall also be made available to the home owner/buyer upon request by the home owner/buyer.
I understand that this may have been added because: "I can't hand this paper to the home buyer/owner because they're not my client!" But that is no excuse. Rating companies can include a provision within their contracts that requires the builder/client to include the standard disclosure form with the paperwork that the home buyer/owner receives when the home closes.
A home owner deserves to know as much as they can about the home- that includes knowing whether or not there were any conflict of interests on the HERS side. This language should be struck to provide the new home owner as much information as possible, and it's relatively easy for rating companies to include a provision in their contract that requires the builder/remodeler/client
Reason:
103.4.9.2.3 A RESNET Standard Disclosure form shall be provided to the rating client
Comment #135Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 11 (1-11)Paragraph / Figure / Table / Note: 103.4.9.2.3Comment Intent: ObjectionComment Type: EditorialComment: I question the need for a disclosure on any unit where the rater has only provided rating services. Since most raters only do rating services and nothing else on the unit, Assume there is no conflict to disclose and don't send paper to builder / homebuyer. Have a one click on the national registry to confirm no conflict / no nreed to disclose. Obviously, in cases where there is some thing to disclose, such as insulating or air sealing contractor, it is the providers absolute responsibility to disclose to the builder / homeowner per the new standards. Response: Reject Reason: Disclosure forms are important for reinforcing the ethical framework of the rating industry Language modified to: 103.4.9.2.1 Written conflict of interest provisions prohibit undisclosed conflicts of interest but allows for a waiver with advance disclosure. The RESNET “Home Energy Rating Standard Disclosure” (Standard Disclosure) form shall be completed for each home that receives a home energy rating and that has a conflict to disclose. If none of the conflicts listed on the RESNET Standard Disclosure form apply, then a Standard Disclosure form is not required.
I question the need for a disclosure on any unit where the rater has only provided rating services. Since most raters only do rating services and nothing else on the unit, Assume there is no conflict to disclose and don't send paper to builder / homebuyer. Have a one click on the national registry to confirm no conflict / no nreed to disclose. Obviously, in cases where there is some thing to disclose, such as insulating or air sealing contractor, it is the providers absolute responsibility to disclose to the builder / homeowner per the new standards.
Reason: Disclosure forms are important for reinforcing the ethical framework of the rating industry
Language modified to: 103.4.9.2.1 Written conflict of interest provisions prohibit undisclosed conflicts of interest but allows for a waiver with advance disclosure. The RESNET “Home Energy Rating Standard Disclosure” (Standard Disclosure) form shall be completed for each home that receives a home energy rating and that has a conflict to disclose. If none of the conflicts listed on the RESNET Standard Disclosure form apply, then a Standard Disclosure form is not required.
Comment #136Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 12Paragraph / Figure / Table / Note: 103.4.9.2.4Comment Intent: ObjectionComment Type: GeneralComment: I have an issue with the following highlighted language: 103.4.9.2.4 For multi-family projects and production home communities, the RESNET Standard Disclosure form is not required for each home or unit that receives a home energy rating, but instead shall be provided to the rating client prior to the start of construction and list the name of the project or community. For production home communities, each base floor plan covered by the Standard Disclosure form shall also be listed on the form. No. Each home could have a different crew, and with particularly large developments, different sections could have different crews, which could then have HERS Ratings performed by different Raters. There's just too much that might get lost by not requiring a Standard Disclosure form for each home in a production home community. I would move to strike the language regarding production home communities, but leave the multi-family projects in. This proposed standard makes much more sense in regards to multi-family projects. Proposed Change: 103.4.9.2.4 For multi-family projects and production home communities, the RESNET Standard Disclosure form is not required for each home or unit that receives a home energy rating, but instead shall be provided to the rating client prior to the start of construction and list the name of the project or community. For production home communities, each base floor plan covered by the Standard Disclosure form shall also be listed on the form. Response: Reject Reason: Disclosure forms would remain the same even when subcontractors change
I have an issue with the following highlighted language:
103.4.9.2.4 For multi-family projects and production home communities, the RESNET Standard Disclosure form is not required for each home or unit that receives a home energy rating, but instead shall be provided to the rating client prior to the start of construction and list the name of the project or community. For production home communities, each base floor plan covered by the Standard Disclosure form shall also be listed on the form.
No. Each home could have a different crew, and with particularly large developments, different sections could have different crews, which could then have HERS Ratings performed by different Raters. There's just too much that might get lost by not requiring a Standard Disclosure form for each home in a production home community.
I would move to strike the language regarding production home communities, but leave the multi-family projects in.
This proposed standard makes much more sense in regards to multi-family projects.
Reason: Disclosure forms would remain the same even when subcontractors change
Comment #137Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-12Paragraph / Figure / Table / Note: 103.4.9.3Comment Intent: ObjectionComment Type: GeneralComment: 10 days is too short. Suggest 30 days. Proposed Change: 103.4.9.3 Written HERS Rater and RFI dDisciplinarye pProcedures that include provisions for Probation, Suspension, and Revocation of HERS Rater and RFI certification. These provisions at a minimum shall include the defined thresholds for each disciplinary category listed in this Section and be in compliance with 904.4.2.8 and 904.4.3. The Provider shall update the HERS Rater/RFI’s status in the National RESNET Building Registry within ten (10) 30 business days of any change. Response: Accept Reason: Accept in principle. Change 10 to 20 days
10 days is too short. Suggest 30 days.
103.4.9.3 Written HERS Rater and RFI dDisciplinarye pProcedures that include provisions for Probation, Suspension, and Revocation of HERS Rater and RFI certification. These provisions at a minimum shall include the defined thresholds for each disciplinary category listed in this Section and be in compliance with 904.4.2.8 and 904.4.3. The Provider shall update the HERS Rater/RFI’s status in the National RESNET Building Registry within ten (10) 30 business days of any change.
Reason: Accept in principle. Change 10 to 20 days
Comment #138Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-12Paragraph / Figure / Table / Note: 103.4.9.3.1Comment Intent: Not an ObjectionComment Type: EditorialComment: As written, the first sentence in this section is incomplete and no action is indicated. The proposed language is consistent with action required in the suspension section (103.4.9.3.2) that follows. Proposed Change: 103.4.9.3.1 Probation – A HERS Rater/RFI found to have committed one or more Violations violations of RESNET standards discovered by a Rating Quality Assurance Provider’s Quality Assurance Contractor/Quality Agent Designee and or through a Rating Quality Assurance Provider’s complaint resolution process, RESNET quality assurance monitoring, or through the RESNET complaint resolution process may be placed on probation by the Provider. The Provider shall notify the HERS Rater/RFI in writing of the specified deficiencies and shall require that specific corrective action, set forth in the notification, be agreed upon and, if possible implemented, not later than twenty (20) business days after the date set forth in such notification. Violations include, but are not limited to, the following: Response: Accept
As written, the first sentence in this section is incomplete and no action is indicated. The proposed language is consistent with action required in the suspension section (103.4.9.3.2) that follows.
103.4.9.3.1 Probation – A HERS Rater/RFI found to have committed one or more Violations violations of RESNET standards discovered by a Rating Quality Assurance Provider’s Quality Assurance Contractor/Quality Agent Designee and or through a Rating Quality Assurance Provider’s complaint resolution process, RESNET quality assurance monitoring, or through the RESNET complaint resolution process may be placed on probation by the Provider. The Provider shall notify the HERS Rater/RFI in writing of the specified deficiencies and shall require that specific corrective action, set forth in the notification, be agreed upon and, if possible implemented, not later than twenty (20) business days after the date set forth in such notification. Violations include, but are not limited to, the following:
Comment #139Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-12Paragraph / Figure / Table / Note: 103.4.9.3.1Comment Intent: Not an ObjectionComment Type: EditorialComment: The first sentence of this provision is not really a sentence. Alteration suggested for grammatical clarity. Proposed Change: 103.4.9.3.1 Probation. – V Any HERS Rater or RFI may have their certification put on probation for violations of RESNET standards discovered by a Rating Quality Assurance Provider’s Quality Assurance Contractor/Quality Agent Designee and/ or through a Rating Quality Assurance Provider’s complaint resolution process, RESNET quality assurance monitoring, or through the RESNET complaint resolution process. The Provider shall notify the HERS Rater/RFI in writing of the specified deficiencies and shall require that specific corrective action, set forth in the notification, be agreed upon and, if possible implemented, not later than twenty (20) business days after the date set forth in such notification. Violations include, but are not limited to, the following: Response: Accept in principle Reason: see changes made to comment #138
The first sentence of this provision is not really a sentence. Alteration suggested for grammatical clarity.
103.4.9.3.1 Probation. – V Any HERS Rater or RFI may have their certification put on probation for violations of RESNET standards discovered by a Rating Quality Assurance Provider’s Quality Assurance Contractor/Quality Agent Designee and/ or through a Rating Quality Assurance Provider’s complaint resolution process, RESNET quality assurance monitoring, or through the RESNET complaint resolution process. The Provider shall notify the HERS Rater/RFI in writing of the specified deficiencies and shall require that specific corrective action, set forth in the notification, be agreed upon and, if possible implemented, not later than twenty (20) business days after the date set forth in such notification. Violations include, but are not limited to, the following:
Reason: see changes made to comment #138
Comment #140Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 13Paragraph / Figure / Table / Note: 103.4.9.3.2 & subsectionsComment Intent: Not an ObjectionComment Type: GeneralComment: Provisions need to be included in this section for Raters/RFis associated with a Rating Company that when one rater is put on Probation or Suspension, all of their raters/rfis be placed in the same status. If this is not included, then when one rater is suspended, a rating company will be able to simply shift the rating responsibilities to another rater within the company. Provisions need to be included within this section to preclude raters from “provider jumping” while on Probation or Suspension. Without this enforcement provision, raters will continue to jump to a new provider when placed in any sort of disciplinary status, which is one of the most prevalent loopholes from a quality assurance perspective. Providers are discouraged from disciplining raters for quality assurance and adminstrative purposes out of fear that they will lose the rating client to a more lenient provider. If the intent of proposing all of these changes is to improve quality assurance, then this is the first issue that should have been addressed. Response: Reject Reason: this should be left to the discretion of the quality agent
Provisions need to be included in this section for Raters/RFis associated with a Rating Company that when one rater is put on Probation or Suspension, all of their raters/rfis be placed in the same status. If this is not included, then when one rater is suspended, a rating company will be able to simply shift the rating responsibilities to another rater within the company.
Provisions need to be included within this section to preclude raters from “provider jumping” while on Probation or Suspension. Without this enforcement provision, raters will continue to jump to a new provider when placed in any sort of disciplinary status, which is one of the most prevalent loopholes from a quality assurance perspective.
Providers are discouraged from disciplining raters for quality assurance and adminstrative purposes out of fear that they will lose the rating client to a more lenient provider. If the intent of proposing all of these changes is to improve quality assurance, then this is the first issue that should have been addressed.
Reason: this should be left to the discretion of the quality agent
Comment #141Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 13Paragraph / Figure / Table / Note: 103.4.9.3.2.4Comment Intent: ObjectionComment Type: TechnicalComment: Strike section 103.4.9.3.2.4. This is too broad and should be either defined or removed. It is highly unlikely than a Provider will ever put a Rater on suspension for "willful misconduct". Proposed Change: 103.4.9.3.2.4102.1.4.7.2.4 Willful misconduct; Response: Reject Reason: Willful misconduct is a well-defined legal term and generally means a knowing violation of a reasonable and uniformly enforced rule or policy.
Strike section 103.4.9.3.2.4. This is too broad and should be either defined or removed. It is highly unlikely than a Provider will ever put a Rater on suspension for "willful misconduct".
103.4.9.3.2.4102.1.4.7.2.4 Willful misconduct;
Reason: Willful misconduct is a well-defined legal term and generally means a knowing violation of a reasonable and uniformly enforced rule or policy.
Comment #142Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 14Paragraph / Figure / Table / Note: 103.4.9.3.2.7.4Comment Intent: ObjectionComment Type: TechnicalComment: 103.4.9.3.2.7.4 50% is an excessive volume of field ratings for a large rater and would discourage providers from executing suspension as it is impractical. Although increased field review should be part of the suspension period, 50% is extremely excessive. 180 days is being proposed at the duration of suspension. For a rater doing 500 or more ratings per year, this would mean at least 250 field QAs. A Provider would have to hire at least 2 QA Agents to move close to the rater's home town and work full time for the entire duration of the rater's suspension in order to fulfill this requirement. Not only would this not be economically feasible for the rater and provider, it is simply impractical and overkill. We propose 5% field QA during suspension as being more reasonable. Proposed Change: 103.4.9.3.2.7.4102.1.4.7.2.7.4 The Provider shall complete, and the HERS Rater/RFI agrees to be subject to, field QA Field review for 4050 5% of the identified ratings completed under this Section. HERS Rater/RFI agrees to pay any associated Provider fees for the additional required QA Field reviews; Response: Reject Reason: 25% is a reasonable minimum requirement and the quality agent can require more QA at their discretion The Provider shall complete, and the HERS Rater/RFI agrees to be subject to, QA Field review for a minimum 25% of the identified ratings completed under this Section. HERS Rater/RFI agrees to pay any associated Provider fees for the additional required QA Field reviews;
103.4.9.3.2.7.4
50% is an excessive volume of field ratings for a large rater and would discourage providers from executing suspension as it is impractical. Although increased field review should be part of the suspension period, 50% is extremely excessive. 180 days is being proposed at the duration of suspension. For a rater doing 500 or more ratings per year, this would mean at least 250 field QAs. A Provider would have to hire at least 2 QA Agents to move close to the rater's home town and work full time for the entire duration of the rater's suspension in order to fulfill this requirement. Not only would this not be economically feasible for the rater and provider, it is simply impractical and overkill. We propose 5% field QA during suspension as being more reasonable.
103.4.9.3.2.7.4102.1.4.7.2.7.4 The Provider shall complete, and the HERS Rater/RFI agrees to be subject to, field QA Field review for 4050 5% of the identified ratings completed under this Section. HERS Rater/RFI agrees to pay any associated Provider fees for the additional required QA Field reviews;
Reason: 25% is a reasonable minimum requirement and the quality agent can require more QA at their discretion
The Provider shall complete, and the HERS Rater/RFI agrees to be subject to, QA Field review for a minimum 25% of the identified ratings completed under this Section. HERS Rater/RFI agrees to pay any associated Provider fees for the additional required QA Field reviews;
Comment #143Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 14Paragraph / Figure / Table / Note: 103.4.9.3.2.7.5Comment Intent: ObjectionComment Type: GeneralComment: It doesn't make sense to force builders into agreeing to a Rater's term of suspension. The fact that they are informed is sufficient. Proposed Change: 103.4.9.3.2.7.5102.1.4.7.2.7.5 The HERS Rating client is informed and agrees to the terms of completion there by acknowledging the terms and conditions of HERS Rater suspension. Response: Accept
It doesn't make sense to force builders into agreeing to a Rater's term of suspension. The fact that they are informed is sufficient.
103.4.9.3.2.7.5102.1.4.7.2.7.5 The HERS Rating client is informed and agrees to the terms of completion there by acknowledging the terms and conditions of HERS Rater suspension.
Comment #144Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 14Paragraph / Figure / Table / Note: 103.4.9.3.2.8Comment Intent: ObjectionComment Type: TechnicalComment: Please revert the time frame back to the previously proposed 90 days. One quarter of the year is enough time for a rater to successfully comply with terms of suspension, as well as enough discipline to encourage the rater to maintain compliance moving forward. Also, not many raters will have projects scheduled out that far in advance and may not be able to know which homes will be able to indentify ratings to be completed during the term of suspension. For many raters, a 180 day suspension term will be the kiss of death for their rating business. While we understand that a rater shouldnt allow it to get to this point and that discipline should be strict, if the intent is to put them out of business, we should just go straight from probation to termination. Providers will be discouraged from suspending a rater, especially a high volume one, given this provision. Proposed Change: 103.4.9.3.2.8102.1.4.7.2.8 Successful compliance with the terms of suspension will result in the HERS Rater being placed on disciplinary probation. At a minimum, the duration of a suspension isshall be 90 180 days from notification., After successful compliance with the ability forterms of suspension, a HERS Rater/RFI’s shall be eligible to have their certification to be re-instated after 90 days under terms for disciplinary probation agreed upon terms of probation by the Rater/RFI and the Provider. Response: Accept
Please revert the time frame back to the previously proposed 90 days. One quarter of the year is enough time for a rater to successfully comply with terms of suspension, as well as enough discipline to encourage the rater to maintain compliance moving forward. Also, not many raters will have projects scheduled out that far in advance and may not be able to know which homes will be able to indentify ratings to be completed during the term of suspension. For many raters, a 180 day suspension term will be the kiss of death for their rating business. While we understand that a rater shouldnt allow it to get to this point and that discipline should be strict, if the intent is to put them out of business, we should just go straight from probation to termination. Providers will be discouraged from suspending a rater, especially a high volume one, given this provision.
103.4.9.3.2.8102.1.4.7.2.8 Successful compliance with the terms of suspension will result in the HERS Rater being placed on disciplinary probation. At a minimum, the duration of a suspension isshall be 90 180 days from notification., After successful compliance with the ability forterms of suspension, a HERS Rater/RFI’s shall be eligible to have their certification to be re-instated after 90 days under terms for disciplinary probation agreed upon terms of probation by the Rater/RFI and the Provider.
Comment #145Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-12-13Paragraph / Figure / Table / Note: 103.4.9.3.3Comment Intent: ObjectionComment Type: EditorialComment: The language after "calendar year" is unnecessary. If someone doesn't know what a calendar year is, they probably can't read this document to begin with. Proposed Change: Strike the following the following: 103.4.9.3.1.3102.1.4.7.1.3 Discovered violations of one or more provisions of the RESNET Standards that result in four or more non-compliant ratings as defined in section 904.4.2.8 for a calendar year, i.e. the twelve month period from January 1st through December 31st; Response: Reject Language further clarifies this section
The language after "calendar year" is unnecessary. If someone doesn't know what a calendar year is, they probably can't read this document to begin with.
Strike the following the following:
103.4.9.3.1.3102.1.4.7.1.3 Discovered violations of one or more provisions of the RESNET Standards that result in four or more non-compliant ratings as defined in section 904.4.2.8 for a calendar year, i.e. the twelve month period from January 1st through December 31st;
Language further clarifies this section
Comment #146Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 14Paragraph / Figure / Table / Note: 103.4.9.3.3Comment Intent: ObjectionComment Type: GeneralComment: • 103.4.9.3.3 – Revocation This section should also include not meeting recertification requirements such as CAZ training and any future RESNET required training. Currently the standards do not reflect what the process of reinstatement must be for Raters who failed to meet the ResCAZ or other future RESNET mandated testing requirements should be Proposed Change: 103.4.9.3.3102.1.4.7.3 Revocation – Any HERS Rater/RFI certified by a Provider shall have their certification revoked for circumstances including, but not limited to, any of the following: Response: Accept Reason: Add to section Failure to complete additional training required by the most recent version of the RESNET Standards
• 103.4.9.3.3 – Revocation
This section should also include not meeting recertification requirements such as CAZ training and any future RESNET required training.
Currently the standards do not reflect what the process of reinstatement must be for Raters who failed to meet the ResCAZ or other future RESNET mandated testing requirements should be
103.4.9.3.3102.1.4.7.3 Revocation – Any HERS Rater/RFI certified by a Provider shall have their certification revoked for circumstances including, but not limited to, any of the following:
Reason: Add to section Failure to complete additional training required by the most recent version of the RESNET Standards
Comment #147Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 15Paragraph / Figure / Table / Note: 103.4.9.3.3.6Comment Intent: ObjectionComment Type: GeneralComment: 103.4.9.3.3.6 Conviction or admission to a felony or is listed on any state or federal sex offenders list, when deemed to impact performance or industry reputation. I would argue that just by having a conviction for a felony or being listed on the federal sex offenders list would be grounds to affecting the industry’s reputation. Admittedly, some people who have more "understandable" defenses of the charges could be affected, but I believe the proposed standard should simply say, “Conviction of admission to a felony or is listed on any state of federal sex offenders list.” Proposed Change: 103.4.9.3.3.6 Conviction or admission to a felony or is listed on any state or federal sex offenders list, when deemed to impact performance or industry reputation. Response: Accept Reason: Accept in principle; delete entire section
103.4.9.3.3.6 Conviction or admission to a felony or is listed on any state or federal sex offenders list, when deemed to impact performance or industry reputation.
I would argue that just by having a conviction for a felony or being listed on the federal sex offenders list would be grounds to affecting the industry’s reputation. Admittedly, some people who have more "understandable" defenses of the charges could be affected, but I believe the proposed standard should simply say, “Conviction of admission to a felony or is listed on any state of federal sex offenders list.”
Reason: Accept in principle; delete entire section
Comment #148Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-15Paragraph / Figure / Table / Note: 103.4.9.3.3.6Comment Intent: ObjectionComment Type: GeneralComment: The language in this section is unenforceable due to the phrase "when deemed to impact performance or industry reputation." Who deems that? How is the impact to performance measured? How is the impact of a felony conviction on industry reputation measured? If you want to continue to punish former criminals, then state so; but I'm not sure RESNET should be dictating company employment policies with an unnecessary and impossible compliance burden, unless RESNET is willing to pay for the discrimination litigation that a company that enforces this may be hit with. Proposed Change: Strike the following in its entirety: 103.4.9.3.3.6 Conviction or admission to a felony or is listed on any state or federal sex offenders list, when deemed to impact performance or industry reputation. Do NOT replace. Response: Accept
The language in this section is unenforceable due to the phrase "when deemed to impact performance or industry reputation."
Who deems that? How is the impact to performance measured? How is the impact of a felony conviction on industry reputation measured?
If you want to continue to punish former criminals, then state so; but I'm not sure RESNET should be dictating company employment policies with an unnecessary and impossible compliance burden, unless RESNET is willing to pay for the discrimination litigation that a company that enforces this may be hit with.
Comment #149Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-15Paragraph / Figure / Table / Note: 103.4.9.3.3.6Comment Intent: ObjectionComment Type: TechnicalComment: This has nothing to do with enhancing quality oversight or rating consistency and can place RESNET in a position to be liable in lawsuits claiming discrimination. This may violate Title VII/EEOC. The use of blanket screening policies is against the law in many states. States have differing laws when it comes to this type of screening practice and a Rating Company or Provider may find themselves being put out of business simply for following RESNET's Standard if this is included. There is nothing in the certification or accreditation process that denies certification or accreditation in these instances. So an individual or company can go to all the time, effort and expense to attain certification or accreditation just to have it revoked. There is no consideration given to the length of time since the conviction/admission. Is a Provider expected to review all 50 state's lists and court records for every Rater in the Providership? Depending on the state, a person can be convicted of a felony for shoplifting as a teenager or throwing a beer bottle at someone during a fraternity party, does that mean that they cannot perform quality HERS Ratings 20, 30, 40 years later? I met a young man who is in an advanced architectural program at KU and is extremely interested and excited about energy efficiency and green building. In this highly competitive program, the selected students design, build, and sell a home. They have been doing this each year for many years now and the students build Passivhaus, ENERGY STAR, and LEED Platinum homes so I have become very involved in the program and have worked with the instructor and students for several years. This young man is listed on the Kansas Sex Offender list. He is there because whenever he was out drinking with his college friends, he chose to walk home rather than drive. He showed poor judgement in stopping to relieve himself in some bushes behind an empty house one too many times and he was caught. He was convicted of public indecency and sentenced to public service. However, due to the nature of the crime, he was also placed on the sex offender list. So this very bright young man is now barred from the HERS Rater, Green Rater career he is interested in? I know that Kansas has an over-reaching law when it comes to their registry. They require that a person who has ever been listed as a sex offender must be on their list if they live in the state, no matter if the "home" state of the crime has expunged the records and does not require registration. So, with this addition to the Standards, RESNET would allow a person in this situation to work as a Rater as long as they don't move to Kansas? I agree that anyone working in the role of HERS Rater or RESNET Provider is the face of RESNET to the world and perhaps it is logical for RESNET to have a morality clause. However, this should be based on actions while certified or accredited and be specific to the type of work performed, not a lifetime of review. I suggest that this clause be totally stricken from this submission, which was to be focused on consistency in ratings, and the totality of impacts considered if a morality clause or blanket screening clause is planned for the Standards. That should really have its own separate consideration and review period. If not stricken, then it needs to be made more specific and needs to be the Provider's call for Raters working under their Providership. That way, the Provider is knowingly and willingly taking on the potential legal liabilities inherent in this clause. Proposed Change: 103.4.9.3.3.6 Conviction or admission to a felony or is listed on any state or federal sex offenders list, when deemed to impact performance or industry reputation. OR 103.4.9.3.3.6 Conviction or admission to a felony or is listed on any state or federal sex offenders list, when deemed by the Rater's Provider to impact performance or industry reputation. Response: Accept Reason: Accept first proposed option
This has nothing to do with enhancing quality oversight or rating consistency and can place RESNET in a position to be liable in lawsuits claiming discrimination. This may violate Title VII/EEOC. The use of blanket screening policies is against the law in many states. States have differing laws when it comes to this type of screening practice and a Rating Company or Provider may find themselves being put out of business simply for following RESNET's Standard if this is included.
There is nothing in the certification or accreditation process that denies certification or accreditation in these instances. So an individual or company can go to all the time, effort and expense to attain certification or accreditation just to have it revoked. There is no consideration given to the length of time since the conviction/admission. Is a Provider expected to review all 50 state's lists and court records for every Rater in the Providership?
Depending on the state, a person can be convicted of a felony for shoplifting as a teenager or throwing a beer bottle at someone during a fraternity party, does that mean that they cannot perform quality HERS Ratings 20, 30, 40 years later? I met a young man who is in an advanced architectural program at KU and is extremely interested and excited about energy efficiency and green building. In this highly competitive program, the selected students design, build, and sell a home. They have been doing this each year for many years now and the students build Passivhaus, ENERGY STAR, and LEED Platinum homes so I have become very involved in the program and have worked with the instructor and students for several years. This young man is listed on the Kansas Sex Offender list. He is there because whenever he was out drinking with his college friends, he chose to walk home rather than drive. He showed poor judgement in stopping to relieve himself in some bushes behind an empty house one too many times and he was caught. He was convicted of public indecency and sentenced to public service. However, due to the nature of the crime, he was also placed on the sex offender list. So this very bright young man is now barred from the HERS Rater, Green Rater career he is interested in?
I know that Kansas has an over-reaching law when it comes to their registry. They require that a person who has ever been listed as a sex offender must be on their list if they live in the state, no matter if the "home" state of the crime has expunged the records and does not require registration. So, with this addition to the Standards, RESNET would allow a person in this situation to work as a Rater as long as they don't move to Kansas?
I agree that anyone working in the role of HERS Rater or RESNET Provider is the face of RESNET to the world and perhaps it is logical for RESNET to have a morality clause. However, this should be based on actions while certified or accredited and be specific to the type of work performed, not a lifetime of review.
I suggest that this clause be totally stricken from this submission, which was to be focused on consistency in ratings, and the totality of impacts considered if a morality clause or blanket screening clause is planned for the Standards. That should really have its own separate consideration and review period.
If not stricken, then it needs to be made more specific and needs to be the Provider's call for Raters working under their Providership. That way, the Provider is knowingly and willingly taking on the potential legal liabilities inherent in this clause.
OR
103.4.9.3.3.6 Conviction or admission to a felony or is listed on any state or federal sex offenders list, when deemed by the Rater's Provider to impact performance or industry reputation.
Reason: Accept first proposed option
Comment #150Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 15Paragraph / Figure / Table / Note: 103.4.9.3.3.6Comment Intent: ObjectionComment Type: GeneralComment: • 103.4.9.3.3.6 Felons and Sex Offenders It is not RESNET’s role to deny someone the ability to be a Rater or RFI for any reason that falls outside the scope of the RESNET Standards for conducting ratings. Will Providers be required to perform background checks? Is this in violation of the Civil Rights Act of 1964 and can Raters pursue legal action if we discriminate against them? Recommend deleting this section in its entirety. Proposed Change: 103.4.9.3.3.6 Conviction or admission to a felony or is listed on any state or federal sex offenders list, when deemed to impact performance or industry reputation. Response: Accept
• 103.4.9.3.3.6 Felons and Sex Offenders
It is not RESNET’s role to deny someone the ability to be a Rater or RFI for any reason that falls outside the scope of the RESNET Standards for conducting ratings.
Will Providers be required to perform background checks?
Is this in violation of the Civil Rights Act of 1964 and can Raters pursue legal action if we discriminate against them?
Recommend deleting this section in its entirety.
Comment #151Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-15Paragraph / Figure / Table / Note: 103.4.9.3.3.6Comment Intent: ObjectionComment Type: GeneralComment: This section should be struck from the standard. It is not reasonable to expect a provider to track the actions of independent raters beyond what they do related to ratings. And, what is that line where the provider "deems" their action is detrimental to the HERS industry. This should not be the responsibility of a rating provider. Response: Accept
This section should be struck from the standard.
It is not reasonable to expect a provider to track the actions of independent raters beyond what they do related to ratings. And, what is that line where the provider "deems" their action is detrimental to the HERS industry. This should not be the responsibility of a rating provider.
Comment #152Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-15Paragraph / Figure / Table / Note: 103.4.9.3.5Comment Intent: ObjectionComment Type: TechnicalComment: We feel this should be 24 months instead of 12. Big companies that make a busines decision to skirt the rules can sit out for 12 monts and try again. 24 months will make them try somewhere else. Proposed Change: 103.4.9.3.5102.1.4.7.5 HERS Rater/RFI’s who have their certification revoked may at their initiative re-apply for certification to any QARating Quality Assurance Provider as a HERS Rater or RFI candidate after a period of no less than 24 months[D1] 180 days from the date of revocation provided the following conditions are met: [D1]24 months clears out the dead wood. Big companies that make a business decision to skirt the rules can sit out for 12 months and try again. 24 months will make them try somewhere else. Response: Reject Reason: Revised section back to original language of 90 days. See comment #144
We feel this should be 24 months instead of 12. Big companies that make a busines decision to skirt the rules can sit out for 12 monts and try again. 24 months will make them try somewhere else.
103.4.9.3.5102.1.4.7.5 HERS Rater/RFI’s who have their certification revoked may at their initiative re-apply for certification to any QARating Quality Assurance Provider as a HERS Rater or RFI candidate after a period of no less than 24 months[D1] 180 days from the date of revocation provided the following conditions are met:
[D1]24 months clears out the dead wood. Big companies that make a business decision to skirt the rules can sit out for 12 months and try again. 24 months will make them try somewhere else.
Reason: Revised section back to original language of 90 days. See comment #144
Comment #153Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-15-16Paragraph / Figure / Table / Note: 103.4.9.3.5-103.4.9.3.5.5Comment Intent: ObjectionComment Type: GeneralComment: This section is too long and unncessary. Please keep things simple and not complicated. Proposed Change: Strike the following in its entirety: 103.4.9.3.5102.1.4.7.5 HERS Rater/RFI’s who have their certification revoked may at their initiative re-apply for certification to any QARating Quality Assurance Provider as a HERS Rater or RFI candidate after a period of no less than 12 months 180 days from the date of revocation provided the following conditions are met: 103.4.9.3.5.1102.1.4.7.5.1 The HERS Rater completes a minimum of three (3) probationary ratings, deemed acceptable in demonstrating the HERS Rater’s technical and administrative skills in completing accurate ratings, under the supervision of a Provider’s QAQuality Assurance DesigneeContractor/Quality Agent; 103.4.9.3.5.2 The RFI completes a minimum of three (3) rating field inspections observed by a certified HERS Rater or a RESNET Candidate Field Assessor using the RESNET JobWerks RFI Mentoring Tool to document results; 103.4.9.3.5.3102.1.4.7.5.2 The HERS Rater agrees to fFile QA by the Provider’s QAQuality Assurance Contractor/Quality Agent Designee of a minimum of 20% for twelve (12) months from the date of re-instatement; 103.4.9.3.5.4 The HERS Rater/RFI agrees to fField QA by the Providers QAQuality Assurance Contractor/Quality Agent of a minimum of 5% for twelve (12) months from the date of re-instatement. 103.4.9.3.5.5102.1.4.7.5.3 The HERS Rater/RFI meets all other certification requirements. Replace with: 103.4.9.3.5 HERS Raters and Rating Field Inspectors who have their certification revoked may re-apply for certification to any Rating Quality Assurance Provider as a candidate after a period of no less than 12 months from the date of revocation provided they meet all of the certification requirements in Chapter 2 for their designation. Response: Reject Reason: Modifications and comments that were already accepted and this section needs to include more requirements for recertification after revocation that what is included in chapter 2
This section is too long and unncessary. Please keep things simple and not complicated.
103.4.9.3.5102.1.4.7.5 HERS Rater/RFI’s who have their certification revoked may at their initiative re-apply for certification to any QARating Quality Assurance Provider as a HERS Rater or RFI candidate after a period of no less than 12 months 180 days from the date of revocation provided the following conditions are met: 103.4.9.3.5.1102.1.4.7.5.1 The HERS Rater completes a minimum of three (3) probationary ratings, deemed acceptable in demonstrating the HERS Rater’s technical and administrative skills in completing accurate ratings, under the supervision of a Provider’s QAQuality Assurance DesigneeContractor/Quality Agent;
103.4.9.3.5.2 The RFI completes a minimum of three (3) rating field inspections observed by a certified HERS Rater or a RESNET Candidate Field Assessor using the RESNET JobWerks RFI Mentoring Tool to document results; 103.4.9.3.5.3102.1.4.7.5.2 The HERS Rater agrees to fFile QA by the Provider’s QAQuality Assurance Contractor/Quality Agent Designee of a minimum of 20% for twelve (12) months from the date of re-instatement; 103.4.9.3.5.4 The HERS Rater/RFI agrees to fField QA by the Providers QAQuality Assurance Contractor/Quality Agent of a minimum of 5% for twelve (12) months from the date of re-instatement. 103.4.9.3.5.5102.1.4.7.5.3 The HERS Rater/RFI meets all other certification requirements.
103.4.9.3.5 HERS Raters and Rating Field Inspectors who have their certification revoked may re-apply for certification to any Rating Quality Assurance Provider as a candidate after a period of no less than 12 months from the date of revocation provided they meet all of the certification requirements in Chapter 2 for their designation.
Reason: Modifications and comments that were already accepted and this section needs to include more requirements for recertification after revocation that what is included in chapter 2
Comment #154Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 16Paragraph / Figure / Table / Note: 103.4.9.3.5.2Comment Intent: ObjectionComment Type: TechnicalComment: I have an issue with the highlighted text: 103.4.9.3.5.2 The RFI completes a minimum of three (3) rating field inspections observed by a certified HERS Rater or a RESNET Candidate Field Assessor using the RESNET JobWerks RFI Mentoring Tool to document results; This could give some Rating Companies a no-oversight way to get a RFI fully certified. These reviews should either be done through JobWerks or by a Quality Agent. Proposed Change: 103.4.9.3.5.2 The RFI completes a minimum of three (3) rating field inspections observed by a certified HERS Rater Quality Agent or a RESNET Candidate Field Assessor using the RESNET JobWerks RFI Mentoring Tool to document results; Response: Accept as modified Reason: The term Jobwerks needs to be removed since it is no longer in use. As modified The RFI completes a minimum of three (3) rating field inspections observed by a certified HERS Rater or Quality Agent, or a RESNET Candidate Field Assessor using the RESNET JobWerks RFI Mentoring Toolgraded field evaluation to document results;
I have an issue with the highlighted text:
103.4.9.3.5.2 The RFI completes a minimum of three (3) rating field inspections observed by a certified HERS Rater or a RESNET Candidate Field Assessor using the RESNET JobWerks RFI Mentoring Tool to document results;
This could give some Rating Companies a no-oversight way to get a RFI fully certified. These reviews should either be done through JobWerks or by a Quality Agent.
103.4.9.3.5.2 The RFI completes a minimum of three (3) rating field inspections observed by a certified HERS Rater Quality Agent or a RESNET Candidate Field Assessor using the RESNET JobWerks RFI Mentoring Tool to document results;
Accept as modified
Reason: The term Jobwerks needs to be removed since it is no longer in use. As modified The RFI completes a minimum of three (3) rating field inspections observed by a certified HERS Rater or Quality Agent, or a RESNET Candidate Field Assessor using the RESNET JobWerks RFI Mentoring Toolgraded field evaluation to document results;
Comment #155Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 16Paragraph / Figure / Table / Note: 103.4.9.3.5.4Comment Intent: ObjectionComment Type: TechnicalComment: If the standards are requiring double file QA for raters under under suspension (10%--> 20%), then I believe it would be most consistent if Field QA followed suit under suspension (1%-->2%) Proposed Change: 103.4.9.3.5.4 The HERS Rater/RFI agrees to f Field QA by the Providers QAQuality Assurance Contractor/Quality Agent of a minimum of 2% 5% for twelve (12) months from the date of re-instatement. Response: Reject Reason: There needs to be a level of rigor for a revoked rater to become certified again and 5% is not an unreasonable percentage
If the standards are requiring double file QA for raters under under suspension (10%--> 20%), then I believe it would be most consistent if Field QA followed suit under suspension (1%-->2%)
103.4.9.3.5.4 The HERS Rater/RFI agrees to f Field QA by the Providers QAQuality Assurance Contractor/Quality Agent of a minimum of 2% 5% for twelve (12) months from the date of re-instatement.
Reason: There needs to be a level of rigor for a revoked rater to become certified again and 5% is not an unreasonable percentage
Comment #156Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 16Paragraph / Figure / Table / Note: 103.4.9.4Comment Intent: ObjectionComment Type: GeneralComment: I take issue with the language highlighted below: 103.4.9.4 Rating, IECC Energy Rating Index Compliance, and Tax Credit Verification recordkeeping. Rating Quality Assurance Providers and/or their certified HERS Raters shall maintain the Quality Assurance Data File for each rating, IECC inspection, and tax credit verification for a minimum of three (3) years. A HERS Rater would obviously be able to keep these records, after-all, they are the ones doing the inspections. But how can a Rating Quality Assurance Provider (RQAP) know about them? There's nothing in the software for a simple check-off to say, yeah, this is exactly what I'm going to use this file for. All the reports are just there, so if a file gets approved, how are RQAP to know what Raters are using them for? Heck, how is RESNET supposed to know? I move to strike the language until Software Providers have proven their software can accurately capture the intent of the rating. It's really as simple as adding a checkbox, but if it doesn't happen how can RQAP and RESNET accurately express the amount of homes undergoing the ERI path of code compliance? Proposed Change: 103.4.9.4 Rating, IECC Energy Rating Index Compliance, and Tax Credit Verification recordkeeping. Rating Quality Assurance Providers and/or their certified HERS Raters shall maintain the Quality Assurance Data File for each rating, IECC inspection, and tax credit verification for a minimum of three (3) years. Response: Accepted as modified Reason: Rating, IECC Energy Rating Index Compliance, and Tax Credit Verification recordkeeping. Rating Quality Assurance Providers and/or their certified HERS Raters shall maintain the Quality Assurance Data File for each Registered rRating, IECC inspection, and tax credit verification for a minimum of three (3) years.
I take issue with the language highlighted below:
103.4.9.4 Rating, IECC Energy Rating Index Compliance, and Tax Credit Verification recordkeeping. Rating Quality Assurance Providers and/or their certified HERS Raters shall maintain the Quality Assurance Data File for each rating, IECC inspection, and tax credit verification for a minimum of three (3) years.
A HERS Rater would obviously be able to keep these records, after-all, they are the ones doing the inspections.
But how can a Rating Quality Assurance Provider (RQAP) know about them? There's nothing in the software for a simple check-off to say, yeah, this is exactly what I'm going to use this file for. All the reports are just there, so if a file gets approved, how are RQAP to know what Raters are using them for? Heck, how is RESNET supposed to know?
I move to strike the language until Software Providers have proven their software can accurately capture the intent of the rating. It's really as simple as adding a checkbox, but if it doesn't happen how can RQAP and RESNET accurately express the amount of homes undergoing the ERI path of code compliance?
Accepted as modified
Reason: Rating, IECC Energy Rating Index Compliance, and Tax Credit Verification recordkeeping. Rating Quality Assurance Providers and/or their certified HERS Raters shall maintain the Quality Assurance Data File for each Registered rRating, IECC inspection, and tax credit verification for a minimum of three (3) years.
Comment #157Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-16Paragraph / Figure / Table / Note: 103.4.9.4Comment Intent: ObjectionComment Type: TechnicalComment: In Texas where the 2015 IECC has been adopted there are now multiple ERI calculators other than the HERS Index entering the market, one of which is sanctioned by the State and hence should see wide-spread adoption. As a result many Non-HERS Raters are adopting these ERI calculators and providing ERI testing and inspection services for Code compliance. These non-HERS Raters do not operate under the RESNET Quality Assurance umbrella. (While this may change with the adoption of ANSI/RESNET 301 into the 2018 IECC, due to State law the 2018 IECC can't be considered for adoption until 2022 making that change a non-factor in Texas). By requiring that HERS Raters submit all IECC Energy Rating Index Compliance through the RESNET Quality Assurance process, RESNET is putting all HERS Raters at a competive disadvantage in the State of Texas. I proposed that IECC Energ Rating Index Compliance should be struck from the RESNET Quality Assurance Standards until the 2018 IECC starts to be adopted on a national basis. Under the 2018 IECC HERS Raters and non-HERS Raters will be playing under similar rules. Under the 2015 IECC this is unfortunately not the case. Proposed Change: 103.4.9.4 Rating, IECC Energy Rating Index Compliance, and Tax Credit Verification recordkeeping. Rating Quality Assurance Providers and/or their certified HERS Raters shall maintain the Quality Assurance Data File for each rating, IECC inspection, and tax credit verification for a minimum of three (3) years. Response: Reject Reason: Language replaced per comment #367
In Texas where the 2015 IECC has been adopted there are now multiple ERI calculators other than the HERS Index entering the market, one of which is sanctioned by the State and hence should see wide-spread adoption. As a result many Non-HERS Raters are adopting these ERI calculators and providing ERI testing and inspection services for Code compliance. These non-HERS Raters do not operate under the RESNET Quality Assurance umbrella. (While this may change with the adoption of ANSI/RESNET 301 into the 2018 IECC, due to State law the 2018 IECC can't be considered for adoption until 2022 making that change a non-factor in Texas). By requiring that HERS Raters submit all IECC Energy Rating Index Compliance through the RESNET Quality Assurance process, RESNET is putting all HERS Raters at a competive disadvantage in the State of Texas.
I proposed that IECC Energ Rating Index Compliance should be struck from the RESNET Quality Assurance Standards until the 2018 IECC starts to be adopted on a national basis. Under the 2018 IECC HERS Raters and non-HERS Raters will be playing under similar rules. Under the 2015 IECC this is unfortunately not the case.
Reason: Language replaced per comment #367
Comment #158Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-16Paragraph / Figure / Table / Note: 103.4.9.4Comment Intent: ObjectionComment Type: EditorialComment: The first sentence in this section is unnecessary and incomplete. Proposed Change: Strike and insert as indicated: 103.4.9.4102.1.4.9 Rating, IECC Energy Rating Index Compliance, and Tax Credit Verification recordkeeping. QARating Quality Assurance Providers and/or their certified HERS Raters shall maintain the Quality Assurance Dataee File for each rating, IECC Energy Rating Index Compliance inspection, and tax credit verification for the time frame specified in Section 905.8.8.3 a minimum of three (3) years. Response: Reject Reason: Section modified per accepted comments #157 & 156 and the title for the section is useful
The first sentence in this section is unnecessary and incomplete.
Strike and insert as indicated:
103.4.9.4102.1.4.9 Rating, IECC Energy Rating Index Compliance, and Tax Credit Verification recordkeeping. QARating Quality Assurance Providers and/or their certified HERS Raters shall maintain the Quality Assurance Dataee File for each rating, IECC Energy Rating Index Compliance inspection, and tax credit verification for the time frame specified in Section 905.8.8.3 a minimum of three (3) years.
Reason: Section modified per accepted comments #157 & 156 and the title for the section is useful
Comment #159Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-16Paragraph / Figure / Table / Note: 103.4.9.4Comment Intent: ObjectionComment Type: TechnicalComment: Remove the qualifiers and require that Providers and HERS Raters retain records for all Confirmed Ratings and their associated EEPs for at least three years. Also, is the Provider referred to here meant to be a Direct Provider or a Third-Party Provider? Do we really need three sets of this data saved for three years? Proposed Change: 103.4.9.4 HERS Rating, IECC Energy Rating Index Compliance, and Tax Credit Verification recordkeeping. QARating Quality Assurance Providers and/or their certified HERS Raters shall maintain the Quality Assurance Data File for each Confirmed Rrating, IECC inspection, and tax credit verification for the time frame specified in Section 905.8.8.3 a minimum of three (3) years. Response: Reject Reason: Changes to the section made per comments #156 & 157. Addition of HERS is not needed since just rating is sufficient in the title of the section. Tax credit verification records need to be maintained
Remove the qualifiers and require that Providers and HERS Raters retain records for all Confirmed Ratings and their associated EEPs for at least three years.
Also, is the Provider referred to here meant to be a Direct Provider or a Third-Party Provider? Do we really need three sets of this data saved for three years?
103.4.9.4 HERS Rating, IECC Energy Rating Index Compliance, and Tax Credit Verification recordkeeping. QARating Quality Assurance Providers and/or their certified HERS Raters shall maintain the Quality Assurance Data File for each Confirmed Rrating, IECC inspection, and tax credit verification for the time frame specified in Section 905.8.8.3 a minimum of three (3) years.
Reason: Changes to the section made per comments #156 & 157. Addition of HERS is not needed since just rating is sufficient in the title of the section. Tax credit verification records need to be maintained
Comment #160Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-16Paragraph / Figure / Table / Note: 103.4.9.5Comment Intent: ObjectionComment Type: EditorialComment: The first sentence in this section is unnecessary and incomplete. Proposed Change: Strike as indicated: 103.4.9.5102.1.4.11 Complaint Response System. Each QARating Quality Assurance Provider shall have a system for receiving complaints. The QARating Quality Assurance Provider shall respond to and resolve complaints related to ratings, field verification, diagnostic testing services, and reports. QARating Quality Assurance Providers shall ensure that HERS Raters inform purchasers and recipients of ratings and field verifications about the complaint system. Each QARating Quality Assurance Provider shall retain records of complaints received and responses to complaints for a minimum of three years after the date of the complaint. Response: Reject Reason: Titles for each section maintains consistency with the other chapters in the standards and provide useful context
Strike as indicated:
103.4.9.5102.1.4.11 Complaint Response System. Each QARating Quality Assurance Provider shall have a system for receiving complaints. The QARating Quality Assurance Provider shall respond to and resolve complaints related to ratings, field verification, diagnostic testing services, and reports. QARating Quality Assurance Providers shall ensure that HERS Raters inform purchasers and recipients of ratings and field verifications about the complaint system. Each QARating Quality Assurance Provider shall retain records of complaints received and responses to complaints for a minimum of three years after the date of the complaint.
Reason: Titles for each section maintains consistency with the other chapters in the standards and provide useful context
Comment #161Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-16Paragraph / Figure / Table / Note: 103.4.9.6Comment Intent: ObjectionComment Type: EditorialComment: The first sentence in this section is unnecessary and incomplete. Proposed Change: Strike and insert as indicated: 103.4.9.6102.1.4.13 Site data collection manual. All QARating Quality Assurance Providers shall provide their certified HERS Raters with a manual containing procedures for the on-site collection of data that at a minimum shall include the on-site inspection procedures for minimum rated features for new and existing homes provided in aAppendix A. Response: Reject Reason: Titles for each section maintains consistency with the other chapters in the standards and provide useful context
103.4.9.6102.1.4.13 Site data collection manual. All QARating Quality Assurance Providers shall provide their certified HERS Raters with a manual containing procedures for the on-site collection of data that at a minimum shall include the on-site inspection procedures for minimum rated features for new and existing homes provided in aAppendix A.
Comment #162Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-17-18Paragraph / Figure / Table / Note: 104.3Comment Intent: ObjectionComment Type: GeneralComment: This section and following sub-sections belong to Software Providers and RESNET, not Quality Assurance Providers. For example, why are Providers suddenly required to maintain the National RESNET Registry? Isn't that the very function of RESNET? For heaven's sake, please stop making this more complicated. Using more words does not produce clarity. The Rater/RFI registry was covered under earlier sections, and everything called out as part of the Rated Home characteristics are put in the National Registry by the software tools, not the QA Provider. Proposed Change: Strike the following in its entirety: 104.3 102.1.4.12 All QA Providers shall collect and register the Energy Simulation File for each home rated (confirmed or sampled) by each Certified Rater with RESNET using the RESNET Buildings Registry. The QARating Quality Assurance Provider will register ratings and maintain theis National RESNET Registry in accordance with the policies and procedures established by RESNET related to the RESNET Buildings Registry. Information required for each rated home entered into the National RESNET Registry shall include, at a minimum, the following: Replace with: 104.3 The Rating Quality Assurance Provider shall register ratings in accordance with these Standards. Response: Reject Reason: Language as it stands provides useful detail. Proposed change is not sufficient to define the requirements for quality assurance providers
This section and following sub-sections belong to Software Providers and RESNET, not Quality Assurance Providers. For example, why are Providers suddenly required to maintain the National RESNET Registry? Isn't that the very function of RESNET?
For heaven's sake, please stop making this more complicated. Using more words does not produce clarity.
The Rater/RFI registry was covered under earlier sections, and everything called out as part of the Rated Home characteristics are put in the National Registry by the software tools, not the QA Provider.
104.3 102.1.4.12 All QA Providers shall collect and register the Energy Simulation File for each home rated (confirmed or sampled) by each Certified Rater with RESNET using the RESNET Buildings Registry. The QARating Quality Assurance Provider will register ratings and maintain theis National RESNET Registry in accordance with the policies and procedures established by RESNET related to the RESNET Buildings Registry. Information required for each rated home entered into the National RESNET Registry shall include, at a minimum, the following:
104.3 The Rating Quality Assurance Provider shall register ratings in accordance with these Standards.
Reason: Language as it stands provides useful detail. Proposed change is not sufficient to define the requirements for quality assurance providers
Comment #163Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-17-18Paragraph / Figure / Table / Note: 104.3-104.3.3Comment Intent: ObjectionComment Type: GeneralComment: This section and following sub-sections belong to Software Providers and RESNET, not Quality Assurance Providers. For example, why are Providers suddenly required to maintain the National RESNET Registry? Isn't that the very function of RESNET? For heaven's sake, please stop making this more complicated. Using more words does not produce clarity. The Rater/RFI registry was covered under earlier sections, and everything called out as part of the Rated Home characteristics are put in the National Registry by the software tools, not the QA Provider. Proposed Change: Strike the following in its entirety: 104.3 102.1.4.12 All QA Providers shall collect and register the Energy Simulation File for each home rated (confirmed or sampled) by each Certified Rater with RESNET using the RESNET Buildings Registry. The QARating Quality Assurance Provider will register ratings and maintain theis National RESNET Registry in accordance with the policies and procedures established by RESNET related to the RESNET Buildings Registry. Information required for each rated home entered into the National RESNET Registry shall include, at a minimum, the following: 102.1.4.10.1 Minimum Requirements. At a minimum, the National RESNET Registry shall include: 104.3.1102.1.4.10.1.1 The Rated Home characteristics, including but not limited to the following: 104.3.1.1102.1.4.10.1.1.1 Physical location of the home, including street address, city, state and zip code 104.3.1.2102.1.4.10.1.1.2 IECC climate zone of the home 104.3.1.3102.1.4.10.1.1.3 Certified HERS Rater ID and RFI RESNET assigned identification numbers. 104.3.1.4102.1.4.10.1.1.4 Accredited Rating Quality Assurance Provider ID 104.3.1.5102.1.4.10.1.1.5 Date of the Rating 104.3.1.6102.1.4.10.1.1.6 Status of the Rated Home (new or existing) 104.3.1.7102.1.4.10.1.1.7 Rating Type for the home (confirmed or sampled as defined in ANSI/RESNET 301-2014) 104.3.1.8102.1.4.10.1.1.8 Home Type (single-family, duplex, low-rise Multi-family) 104.3.1.9102.1.4.10.1.1.9 Conditioned Floor Area of the home 104.3.1.10102.1.4.10.1.1.10 Number of bedrooms in the home 104.3.1.11102.1.4.10.1.1.11 The name and version number of the accredited software rating tool that created the Rating 104.3.2102.1.4.10.1.2 The Rating results, including but not limited to the following: 104.3.2.1102.1.4.10.1.2.1 Registration ID (provided by the National RESNET Registry) 104.3.2.2102.1.4.10.1.2.2 HERS Index Score 104.3.2.3102.1.4.10.1.2.3 Annual Rated Home energy end uses for heating, cooling, hot water and lighting and appliance energy end uses by fuel type 104.3.2.4102.1.4.10.1.2.4 Annual Rated Home on-site power production 104.3.2.5102.1.4.10.1.2.5 Energy prices used to calculate costs by fuel type 104.3.2.6102.1.4.10.1.2.6 Annual total cost to operate the Rated home 104.3.2.7102.1.4.10.1.2.7 Annual Rated Home normalized Modified End Use Loads 104.3.2.8102.1.4.10.1.2.8 Annual HERS Reference Home End Use Loads 104.3.2.9102.1.4.10.1.2.9 Annual HERS Reference Home energy end uses for heating, cooling, hot water and lighting and appliance energy end uses by fuel type 104.3.3102.1.4.10.1.3 An executable copy of the building input file used by the accredited software rating tool to generate the Home Energy Rating. Insert into Section 105 and strike, insert and renumber the following: 105.4 102.1.4.12 All QA Providers shall collect and register the Energy Simulation File for each home rated (confirmed or sampled) by each Certified Rater with RESNET using the RESNET Buildings Registry. The QARating Quality Assurance Provider will register ratings and maintain theis National RESNET Registry in accordance with the policies and procedures established by RESNET related to the RESNET Buildings Registry. a All Software Providers shall ensure their software tool exports into the Information required for each rated home entered into the National RESNET Registry shall include, at a minimum, the following: 102.1.4.10.1 Minimum Requirements. At a minimum, the National RESNET Registry shall include: 105.4.1102.1.4.10.1.1 The Rated Home characteristics, including but not limited to the following: 105.4.1.1102.1.4.10.1.1.1 Physical location of the home, including street address, city, state and zip code 105.4.1.2102.1.4.10.1.1.2 IECC climate zone of the home 105.4.1.3102.1.4.10.1.1.3 Certified HERS Rater ID and RFI RESNET assigned identification numbers. 105.4.1.4102.1.4.10.1.1.4 Accredited Rating Quality Assurance Provider ID 105.4.1.5102.1.4.10.1.1.5 Date of the Rating 105.4.1.6102.1.4.10.1.1.6 Status of the Rated Home (new or existing) 105.4.1.7102.1.4.10.1.1.7 Rating Type for the home (confirmed or sampledas defined in ANSI/RESNET 301-2014) 105.4.1.8102.1.4.10.1.1.8 Home Type (single-family, duplex, low-rise Multi-family) 105.4.1.9102.1.4.10.1.1.9 Conditioned Floor Area of the home 105.4.1.10102.1.4.10.1.1.10 Number of bedrooms in the home 105.4.1.11102.1.4.10.1.1.11 The name and version number of the accredited software rating tool that created the Rating 105.4.2102.1.4.10.1.2 The Rating results, including but not limited to the following: 105.4.2.1102.1.4.10.1.2.1 Registration ID (provided by the National RESNET Registry) 105.4.2.2102.1.4.10.1.2.2 HERS Index Score 105.4.2.3102.1.4.10.1.2.3 Annual Rated Home energy end uses for heating, cooling, hot water and lighting and appliance energy end uses by fuel type 105.4.2.4102.1.4.10.1.2.4 Annual Rated Home on-site power production 105.4.2.5102.1.4.10.1.2.5 Energy prices used to calculate costs by fuel type 105.4.2.6102.1.4.10.1.2.6 Annual total cost to operate the Rated home 105.4.2.7102.1.4.10.1.2.7 Annual Rated Home normalized Modified End Use Loads 105.4.2.8102.1.4.10.1.2.8 Annual HERS Reference Home End Use Loads 105.4.2.9102.1.4.10.1.2.9 Annual HERS Reference Home energy end uses for heating, cooling, hot water and lighting and appliance energy end uses by fuel type 105.5.3102.1.4.10.1.3 An executable copy of the building input file used by the accredited software rating tool to generate the Home Energy Rating. Response: Reject Reason: Section was maintained in comment #162 and renumbering is not needed.
104.3 102.1.4.12 All QA Providers shall collect and register the Energy Simulation File for each home rated (confirmed or sampled) by each Certified Rater with RESNET using the RESNET Buildings Registry. The QARating Quality Assurance Provider will register ratings and maintain theis National RESNET Registry in accordance with the policies and procedures established by RESNET related to the RESNET Buildings Registry. Information required for each rated home entered into the National RESNET Registry shall include, at a minimum, the following: 102.1.4.10.1 Minimum Requirements. At a minimum, the National RESNET Registry shall include: 104.3.1102.1.4.10.1.1 The Rated Home characteristics, including but not limited to the following: 104.3.1.1102.1.4.10.1.1.1 Physical location of the home, including street address, city, state and zip code 104.3.1.2102.1.4.10.1.1.2 IECC climate zone of the home 104.3.1.3102.1.4.10.1.1.3 Certified HERS Rater ID and RFI RESNET assigned identification numbers. 104.3.1.4102.1.4.10.1.1.4 Accredited Rating Quality Assurance Provider ID 104.3.1.5102.1.4.10.1.1.5 Date of the Rating 104.3.1.6102.1.4.10.1.1.6 Status of the Rated Home (new or existing)
104.3.1.7102.1.4.10.1.1.7 Rating Type for the home (confirmed or sampled as defined in ANSI/RESNET 301-2014) 104.3.1.8102.1.4.10.1.1.8 Home Type (single-family, duplex, low-rise Multi-family) 104.3.1.9102.1.4.10.1.1.9 Conditioned Floor Area of the home 104.3.1.10102.1.4.10.1.1.10 Number of bedrooms in the home 104.3.1.11102.1.4.10.1.1.11 The name and version number of the accredited software rating tool that created the Rating 104.3.2102.1.4.10.1.2 The Rating results, including but not limited to the following: 104.3.2.1102.1.4.10.1.2.1 Registration ID (provided by the National RESNET Registry) 104.3.2.2102.1.4.10.1.2.2 HERS Index Score 104.3.2.3102.1.4.10.1.2.3 Annual Rated Home energy end uses for heating, cooling, hot water and lighting and appliance energy end uses by fuel type 104.3.2.4102.1.4.10.1.2.4 Annual Rated Home on-site power production 104.3.2.5102.1.4.10.1.2.5 Energy prices used to calculate costs by fuel type 104.3.2.6102.1.4.10.1.2.6 Annual total cost to operate the Rated home 104.3.2.7102.1.4.10.1.2.7 Annual Rated Home normalized Modified End Use Loads 104.3.2.8102.1.4.10.1.2.8 Annual HERS Reference Home End Use Loads 104.3.2.9102.1.4.10.1.2.9 Annual HERS Reference Home energy end uses for heating, cooling, hot water and lighting and appliance energy end uses by fuel type 104.3.3102.1.4.10.1.3 An executable copy of the building input file used by the accredited software rating tool to generate the Home Energy Rating.
Insert into Section 105 and strike, insert and renumber the following:
105.4 102.1.4.12 All QA Providers shall collect and register the Energy Simulation File for each home rated (confirmed or sampled) by each Certified Rater with RESNET using the RESNET Buildings Registry. The QARating Quality Assurance Provider will register ratings and maintain theis National RESNET Registry in accordance with the policies and procedures established by RESNET related to the RESNET Buildings Registry. a All Software Providers shall ensure their software tool exports into the Information required for each rated home entered into the National RESNET Registry shall include, at a minimum, the following: 102.1.4.10.1 Minimum Requirements. At a minimum, the National RESNET Registry shall include: 105.4.1102.1.4.10.1.1 The Rated Home characteristics, including but not limited to the following: 105.4.1.1102.1.4.10.1.1.1 Physical location of the home, including street address, city, state and zip code 105.4.1.2102.1.4.10.1.1.2 IECC climate zone of the home 105.4.1.3102.1.4.10.1.1.3 Certified HERS Rater ID and RFI RESNET assigned identification numbers. 105.4.1.4102.1.4.10.1.1.4 Accredited Rating Quality Assurance Provider ID 105.4.1.5102.1.4.10.1.1.5 Date of the Rating 105.4.1.6102.1.4.10.1.1.6 Status of the Rated Home (new or existing)
105.4.1.7102.1.4.10.1.1.7 Rating Type for the home (confirmed or sampledas defined in ANSI/RESNET 301-2014) 105.4.1.8102.1.4.10.1.1.8 Home Type (single-family, duplex, low-rise Multi-family) 105.4.1.9102.1.4.10.1.1.9 Conditioned Floor Area of the home 105.4.1.10102.1.4.10.1.1.10 Number of bedrooms in the home 105.4.1.11102.1.4.10.1.1.11 The name and version number of the accredited software rating tool that created the Rating 105.4.2102.1.4.10.1.2 The Rating results, including but not limited to the following: 105.4.2.1102.1.4.10.1.2.1 Registration ID (provided by the National RESNET Registry) 105.4.2.2102.1.4.10.1.2.2 HERS Index Score 105.4.2.3102.1.4.10.1.2.3 Annual Rated Home energy end uses for heating, cooling, hot water and lighting and appliance energy end uses by fuel type 105.4.2.4102.1.4.10.1.2.4 Annual Rated Home on-site power production 105.4.2.5102.1.4.10.1.2.5 Energy prices used to calculate costs by fuel type 105.4.2.6102.1.4.10.1.2.6 Annual total cost to operate the Rated home 105.4.2.7102.1.4.10.1.2.7 Annual Rated Home normalized Modified End Use Loads 105.4.2.8102.1.4.10.1.2.8 Annual HERS Reference Home End Use Loads 105.4.2.9102.1.4.10.1.2.9 Annual HERS Reference Home energy end uses for heating, cooling, hot water and lighting and appliance energy end uses by fuel type 105.5.3102.1.4.10.1.3 An executable copy of the building input file used by the accredited software rating tool to generate the Home Energy Rating.
Reason: Section was maintained in comment #162 and renumbering is not needed.
Comment #164Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-17Paragraph / Figure / Table / Note: 104.3.1.3Comment Intent: ObjectionComment Type: TechnicalComment: There is not currently a field in the National RESNET Registry provided for a Provider to include the RFI RESNET assigned identification number. Until this is made available, this requirement should not be added to the standards. Proposed Change: 104.3.1.3 Certified HERS Rater and RFI RESNET assigned identification numbers. Response: Reject Reason: Most recent version of accredited software tools include a field for RFIIN and other raters involved in the inspections for the rating
There is not currently a field in the National RESNET Registry provided for a Provider to include the RFI RESNET assigned identification number. Until this is made available, this requirement should not be added to the standards.
104.3.1.3 Certified HERS Rater and RFI RESNET assigned identification numbers.
Reason: Most recent version of accredited software tools include a field for RFIIN and other raters involved in the inspections for the rating
Comment #165Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 19Paragraph / Figure / Table / Note: 105.2.3Comment Intent: Not an ObjectionComment Type: GeneralComment: Persistence is also hard to document/track. Projected ratings are not recorded anywhere. It is challenging to verify whether a rating was started prior to the expiration of the tranisition. A sunset date would be easier to document/track. Response: Reject Reason: Another amendment has been proposed on the issue of persistence and public comments are being considered
Persistence is also hard to document/track. Projected ratings are not recorded anywhere. It is challenging to verify whether a rating was started prior to the expiration of the tranisition. A sunset date would be easier to document/track.
Reason: Another amendment has been proposed on the issue of persistence and public comments are being considered
Comment #166Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-19Paragraph / Figure / Table / Note: 106.2Comment Intent: Not an ObjectionComment Type: EditorialComment: Home Energy Raters should be changed to HERS Raters for consistency Proposed Change: 106.2104.2 When working with EEP’s, HERS[D1] Raters may be required to perform tests, inspections, verifications and reporting that require skills related to energy efficiency not specific to Home Energy Ratings as defined in these Standards and/or are required to become a Certified HERS[D2] Rater. However, it is the responsibility of Certified Home Energy Raters to perform all of the stipulated tests, inspections, verifications and reporting related to energy efficiency required by the EEP when agreeing to work with their program, including proper completion of any and all checklists, certificates, or other documentation. Where a HERS Rater does not possess the proper skill or knowledge of a particular test, inspection, verification or reporting requirement, they shall be responsible for obtaining sufficient training from the EEP, or trainer approved by the EEP, to properly fulfill the requirement. An exception may be made in cases where portions of an EEP’s testing, inspection, verification or reporting process are completed by another company or individual who holds the required training or certifications. [D1]consistency [D2]consistency Response: Accept in principle Reason: RESNET Staff will review for consistency of language
106.2104.2 When working with EEP’s, HERS[D1] Raters may be required to perform
tests, inspections, verifications and reporting that require skills related to energy efficiency not specific to Home Energy Ratings as defined in these Standards and/or are required to become a Certified HERS[D2] Rater. However, it is the responsibility of Certified Home Energy Raters to perform all of the stipulated tests, inspections, verifications and reporting related to energy efficiency required by the EEP when agreeing to work with their program, including proper completion of any and all checklists, certificates, or other documentation. Where a HERS Rater does not possess the proper skill or knowledge of a particular test, inspection, verification or reporting requirement, they shall be responsible for obtaining sufficient training from the EEP, or trainer approved by the EEP, to properly fulfill the requirement. An exception may be made in cases where portions of an EEP’s testing, inspection, verification or reporting process are completed by another company or individual who holds the required training or certifications.
[D1]consistency
[D2]consistency
Reason: RESNET Staff will review for consistency of language
Comment #167Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-19Paragraph / Figure / Table / Note: 106.2Comment Intent: Not an ObjectionComment Type: EditorialComment: Home Energy Raters should be changed to HERS Raters for consistency Proposed Change: 106.2104.2 When working with EEP’s, HERS[D1] Raters may be required to perform tests, inspections, verifications and reporting that require skills related to energy efficiency not specific to Home Energy Ratings as defined in these Standards and/or are required to become a Certified HERS[D2] Rater. However, it is the responsibility of Certified Home Energy Raters to perform all of the stipulated tests, inspections, verifications and reporting related to energy efficiency required by the EEP when agreeing to work with their program, including proper completion of any and all checklists, certificates, or other documentation. Where a HERS Rater does not possess the proper skill or knowledge of a particular test, inspection, verification or reporting requirement, they shall be responsible for obtaining sufficient training from the EEP, or trainer approved by the EEP, to properly fulfill the requirement. An exception may be made in cases where portions of an EEP’s testing, inspection, verification or reporting process are completed by another company or individual who holds the required training or certifications. [D1]consistency [D2]consistency Response: Accept in principle Reason: RESNET Staff will review for consistency of language
Comment #168Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 907.4.3.4.2Paragraph / Figure / Table / Note: 9-28Comment Intent: ObjectionComment Type: TechnicalComment: Same corrections as 904.3.5.1 I previously submitted. Sorry could not go back and confirm. Changes dealt with Priority evaluation. Found this same wording in 907.4.3.4.2 Proposed Change: 907.4.3.4.2 The QA Designee’s results must be no more than three percent (3%) (+/-) variation in the HERS Index from the HERS Index result as determined by the QA Designee. Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores for each energy simulation file. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable cumulative variance never less than four (4) HERS Index points. For example, if an energy simulation file shows an initial HERS Index of 75, the allowable cumulative variance in the HERS Index score is 75 x 5% = 3.75, or an allowable cumulative variance of no more than the 4 HERS Index minimum. If during the QA review, the QA determines that corrections to the energy simulation file were necessary which moved the HERS Index down 2 points and up 3 point, for a cumulative move of 5 HERS Index points, then the rating shall be deemed “noncompliant.” Response: Reject Reason: this section will be replaced with the new QA review checklist under development
Same corrections as 904.3.5.1 I previously submitted. Sorry could not go back and confirm. Changes dealt with Priority evaluation. Found this same wording in 907.4.3.4.2
907.4.3.4.2 The QA Designee’s results must be no more than three percent (3%) (+/-) variation in the HERS Index from the HERS Index result as determined by the QA Designee. Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores for each energy simulation file. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable cumulative variance never less than four (4) HERS Index points. For example, if an energy simulation file shows an initial HERS Index of 75, the allowable cumulative variance in the HERS Index score is 75 x 5% = 3.75, or an allowable cumulative variance of no more than the 4 HERS Index minimum. If during the QA review, the QA determines that corrections to the energy simulation file were necessary which moved the HERS Index down 2 points and up 3 point, for a cumulative move of 5 HERS Index points, then the rating shall be deemed “noncompliant.”
Reason: this section will be replaced with the new QA review checklist under development
Comment #169Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-1Paragraph / Figure / Table / Note: 901.1Comment Intent: ObjectionComment Type: GeneralComment: The purpose of this Chapter is NOT to replicate the accreditation requirements located in Chapter 1, but to outline the quality management tasks of the parties involved. Please do not repeat the same elements that were placed into Chapter 1- it only creates confusion and opportunities for conflicting (and therefore unenforceable) standards. Proposed Change: Strike the following in its entirety: 901.1 Purpose RESNET has the responsibility of accrediting Rating Quality Assurance Providers. This chapter outlines the quality assurance responsibilities of RESNET and Providers, the role and responsibility of the Quality Assurance Committee, the role and responsibility of the Accreditation Committee, the RESNET Accreditation Process for all Providers, the RESNET policies and procedures for Probation, Suspension and Revocation of Provider Accreditation, and the Appeals process for each of these disciplinary actions. Replace with: 901.1 Purpose This chapter outlines the responsibilities of RESNET and Quality Assurance Providers and minimum tasks associated with quality management systems used to comply with these Standards. Response: Accept
The purpose of this Chapter is NOT to replicate the accreditation requirements located in Chapter 1, but to outline the quality management tasks of the parties involved.
Please do not repeat the same elements that were placed into Chapter 1- it only creates confusion and opportunities for conflicting (and therefore unenforceable) standards.
901.1 Purpose RESNET has the responsibility of accrediting Rating Quality Assurance Providers. This chapter outlines the quality assurance responsibilities of RESNET and Providers, the role and responsibility of the Quality Assurance Committee, the role and responsibility of the Accreditation Committee, the RESNET Accreditation Process for all Providers, the RESNET policies and procedures for Probation, Suspension and Revocation of Provider Accreditation, and the Appeals process for each of these disciplinary actions.
901.1 Purpose
This chapter outlines the responsibilities of RESNET and Quality Assurance Providers and minimum tasks associated with quality management systems used to comply with these Standards.
Comment #170Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-2-3Paragraph / Figure / Table / Note: 901.1Comment Intent: ObjectionComment Type: EditorialComment: The incorrect term "oversite" is used in place of the correct term "oversight". Homophones will get you every time. Proposed Change: Strike and replace the following: 903 RESNET OVERSITE OVERSIGHT OF QUALITY ASSURANCE PROCESS 903.1 RESNET Oversight of Quality Assurance Contractors and Quality Agents RESNET will be responsible for oversite oversight of the work performed under these Standards by approved Quality Assurance Contractors and the RESNET certified Quality Agents they employ. Response: Accept
The incorrect term "oversite" is used in place of the correct term "oversight". Homophones will get you every time.
Strike and replace the following:
903 RESNET OVERSITE OVERSIGHT OF QUALITY ASSURANCE PROCESS 903.1 RESNET Oversight of Quality Assurance Contractors and Quality Agents
RESNET will be responsible for oversite oversight of the work performed under these Standards by approved Quality Assurance Contractors and the RESNET certified Quality Agents they employ.
Comment #171Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-2 and 9-3Paragraph / Figure / Table / Note: 903, 903.1Comment Intent: ObjectionComment Type: EditorialComment: Oversite is not a word. Also, the formatting of the section headings is different in this chapter than it was in chapter two. It should be consistent throughout the entire Standard. Proposed Change: 903 RESNET OVERSITEOVERSIGHT OF QUALITY ASSURANCE PROCESS 903.1 RESNET Oversight of Quality Assurance Contractors and Quality Agents. RESNET shallwill be responsible for oversiteoversight of the work performed under these Standards by approved Quality Assurance Contractors and the RESNET certified Quality Agents they employ. Response: Accept
Oversite is not a word.
Also, the formatting of the section headings is different in this chapter than it was in chapter two. It should be consistent throughout the entire Standard.
903 RESNET OVERSITEOVERSIGHT OF QUALITY ASSURANCE PROCESS
903.1 RESNET Oversight of Quality Assurance Contractors and Quality Agents. RESNET shallwill be responsible for oversiteoversight of the work performed under these Standards by approved Quality Assurance Contractors and the RESNET certified Quality Agents they employ.
Comment #172Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-2-3Paragraph / Figure / Table / Note: 903.1-903.4Comment Intent: ObjectionComment Type: GeneralComment: There is absolutely no need for a "Quality Assurance Contractor" when there are Third-party Providers that are already considered "Quality Assurance Contractors". These sections are duplicative and unnecessary. Proposed Change: Strike the following in its entirety: 903.1 RESNET Oversight of Quality Assurance Contractors and Quality Agents RESNET will be responsible for oversite of the work performed under these Standards by approved Quality Assurance Contractors and the RESNET certified Quality Agents they employ. 903.2 Review of Rating Quality Assurance Provider Quality Assurance Reviews RESNET shall review 100% of the annual Rating Quality Assurance Provider Quality Assurance Reports submitted by Quality Agents. 903.3 Quality Assurance File Review RESNET will centrally administer quality assurance review of ratings using data in the National RESNET Registry. 903.4 Challenging Quality Assurance Findings An accredited Rating Quality Assurance Provider has the right to challenge the findings of a RESNET Quality Assurance Contractor. The Appeals Procedures in Section 911 shall apply to the submission and consideration of a Provider’s challenge to Quality Assurance findings. Do NOT replace. Response: Reject Reason: The RESNET Board of Directors policy is to eliminate the employee/employer relationship between Quality Agents and Rating Providers. For this reason “Quality Assurance Contractors” were designated as a business entity that rating providers will contract with for Quality Assurance services.
There is absolutely no need for a "Quality Assurance Contractor" when there are Third-party Providers that are already considered "Quality Assurance Contractors". These sections are duplicative and unnecessary.
903.1 RESNET Oversight of Quality Assurance Contractors and Quality Agents
RESNET will be responsible for oversite of the work performed under these Standards by approved Quality Assurance Contractors and the RESNET certified Quality Agents they employ. 903.2 Review of Rating Quality Assurance Provider Quality Assurance Reviews RESNET shall review 100% of the annual Rating Quality Assurance Provider Quality Assurance Reports submitted by Quality Agents. 903.3 Quality Assurance File Review RESNET will centrally administer quality assurance review of ratings using data in the National RESNET Registry. 903.4 Challenging Quality Assurance Findings An accredited Rating Quality Assurance Provider has the right to challenge the findings of a RESNET Quality Assurance Contractor. The Appeals Procedures in Section 911 shall apply to the submission and consideration of a Provider’s challenge to Quality Assurance findings.
Reason: The RESNET Board of Directors policy is to eliminate the employee/employer relationship between Quality Agents and Rating Providers. For this reason “Quality Assurance Contractors” were designated as a business entity that rating providers will contract with for Quality Assurance services.
Comment #173Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-3Paragraph / Figure / Table / Note: 903.3Comment Intent: Not an ObjectionComment Type: EditorialComment: RESNET's central administration of QA of ratings using error checking of data in the National RESNET Registry can provide a powerful tool to improve the quality of ratings. Although no language is proposed, this comment is a request that any automated error checking consider the inherent differences in data submitted for multi-family dwelling units and not unnecessarily flag items that may be anomalous in single family homes, but common in multifamily dwellings. Response: Reject Reason: No proposed change suggested. Comment duly noted.
RESNET's central administration of QA of ratings using error checking of data in the National RESNET Registry can provide a powerful tool to improve the quality of ratings.
Although no language is proposed, this comment is a request that any automated error checking consider the inherent differences in data submitted for multi-family dwelling units and not unnecessarily flag items that may be anomalous in single family homes, but common in multifamily dwellings.
Reason: No proposed change suggested. Comment duly noted.
Comment #174Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-3Paragraph / Figure / Table / Note: 904.1Comment Intent: ObjectionComment Type: GeneralComment: Section 904.1 states "Unless otherwise noted, the quality assurance process specified in this Section shall only be carried out by a RESNET certified Quality Agent." Are there any exceptions to this process? I did not find any. Is this language being used to reserve the right to insert and exception at a future date? If there are indeed exceptions it would be much more plain to enumerate them or make refference to the sections involved. Suggest the words "Unless otherwise noted" be deleted. Proposed Change: Unless otherwise noted, The quality assurance process specified in this Section shall only be carried out by a RESNET certified Quality Agent. Response: Accept
Section 904.1 states "Unless otherwise noted, the quality assurance process specified in this Section shall only be carried out by a RESNET certified Quality Agent."
Are there any exceptions to this process? I did not find any. Is this language being used to reserve the right to insert and exception at a future date? If there are indeed exceptions it would be much more plain to enumerate them or make refference to the sections involved.
Suggest the words "Unless otherwise noted" be deleted.
Unless otherwise noted, The quality assurance process specified in this Section shall only be carried out by a RESNET certified Quality Agent.
Comment #175Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-3Paragraph / Figure / Table / Note: 904.2.1Comment Intent: ObjectionComment Type: EditorialComment: There is no need to define a calendar year...if they don't know that by now, they will likely never, never know it. And probably can't read this document. Proposed Change: Strike the following and insert: 904.2.1 904.2 QARating Quality Assurance Providers are responsible for completing an annual submission of their Quality Assurance QA results to RESNET. RESNET shall annually notify Rating Quality Assurance Providers ofdesignate the date submissions are due, and the content of each submission. , and tThe time frame for which data shall beis provided for the annual submissions shall be the calendar year, e.g. i.e. the twelve month period from January 1st through December 31st. QARating Quality Assurance Providers will have at least thirty (30) days from notification from RESNET of the annual submission due date until the submissions isare due. Response: Reject Reason: Example provides more clarification rather than less
There is no need to define a calendar year...if they don't know that by now, they will likely never, never know it. And probably can't read this document.
Strike the following and insert:
904.2.1 904.2 QARating Quality Assurance Providers are responsible for completing an annual submission of their Quality Assurance QA results to RESNET. RESNET shall annually notify Rating Quality Assurance Providers ofdesignate the date submissions are due, and the content of each submission. , and tThe time frame for which data shall beis provided for the annual submissions shall be the calendar year, e.g. i.e. the twelve month period from January 1st through December 31st. QARating Quality Assurance Providers will have at least thirty (30) days from notification from RESNET of the annual submission due date until the submissions isare due.
Reason: Example provides more clarification rather than less
Comment #176Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.1.1Comment Intent: ObjectionComment Type: EditorialComment: "Date submitted" should be changed to "date registered" per the guidance to Provider sent out by RESNET earlier this year. Proposed Change: 904.3.1.1 For QA File and QA Field reviews, the HERS Rater's “annual total of ratings” shall mean all ratings entered into the National RESNET Registry (based on “date submittedregistered”) for a calendar year, i.e. the twelve month period from January 1st through December 31st. Response: Accept
"Date submitted" should be changed to "date registered" per the guidance to Provider sent out by RESNET earlier this year.
904.3.1.1 For QA File and QA Field reviews, the HERS Rater's “annual total of ratings” shall mean all ratings entered into the National RESNET Registry (based on “date submittedregistered”) for a calendar year, i.e. the twelve month period from January 1st through December 31st.
Comment #177Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.1.1Comment Intent: ObjectionComment Type: EditorialComment: There is no need to define a calendar year...if they don't know that by now, they will likely never, never know it. And probably can't read this document. And seriously, you just defined it on the previous page...more words are not better! Proposed Change: Strike the following: 904.3.1.1 For QA File and QA Field reviews, the HERS Rater's “annual total of ratings” shall mean all ratings entered into the National RESNET Registry (based on “date submitted”) for a calendar year, i.e. the twelve month period from January 1st through December 31st. Response: Reject Reason: Example provides more clarification rather than less
And seriously, you just defined it on the previous page...more words are not better!
Strike the following:
904.3.1.1 For QA File and QA Field reviews, the HERS Rater's “annual total of ratings” shall mean all ratings entered into the National RESNET Registry (based on “date submitted”) for a calendar year, i.e. the twelve month period from January 1st through December 31st.
Comment #178Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-1 through 9-39Paragraph / Figure / Table / Note: 904.3.1.1Comment Intent: ObjectionComment Type: TechnicalComment: This proposed amendment conflates two distinct elements of quality management, quality control and quality assurance. Quality management is a set of distinct processes that involves quality planning, quality assurance, quality control, and quality improvement. The purpose of quality assurance is to ensure the process used to produce a product or service will, in fact, produce a product or service that meets the standard specifications. This is different from quality control. The purpose of quality control is to ensure the product or service produced fits within standard specifications. This is an important distinction. Quality assurance is about preventing failures of quality, while quality control is about detecting failures that have occurred. You perform quality assurance during production; you perform quality control after production. Both must include an important feedback loop to produce quality improvements. RESNET cannot afford to be sloppy in the use of these terms, or in the language of the Standards developed. Proposed Change: Refer to the overall process as "Quality Management" throughout these Standards, Refer to the file reviews as "Quality Control". Refer to the field reviews as "Quality Assurance". Refer to software data validation checks and behavioral pattern detection as "Quality Assurance". Refer to the disciplinary actions as "Quality Improvement". Response: Reject Reason: The distinction between Quality Assurance and Quality Control is a good one. However, for simplicity RESNET defines all quality assurance as “quality assurance” and the standards clearly define RESNET’s meaning of “quality assurance”
This proposed amendment conflates two distinct elements of quality management, quality control and quality assurance.
Quality management is a set of distinct processes that involves quality planning, quality assurance, quality control, and quality improvement.
The purpose of quality assurance is to ensure the process used to produce a product or service will, in fact, produce a product or service that meets the standard specifications. This is different from quality control.
The purpose of quality control is to ensure the product or service produced fits within standard specifications.
This is an important distinction. Quality assurance is about preventing failures of quality, while quality control is about detecting failures that have occurred. You perform quality assurance during production; you perform quality control after production. Both must include an important feedback loop to produce quality improvements.
RESNET cannot afford to be sloppy in the use of these terms, or in the language of the Standards developed.
Refer to the overall process as "Quality Management" throughout these Standards,
Refer to the file reviews as "Quality Control".
Refer to the field reviews as "Quality Assurance".
Refer to software data validation checks and behavioral pattern detection as "Quality Assurance".
Refer to the disciplinary actions as "Quality Improvement".
Reason: The distinction between Quality Assurance and Quality Control is a good one. However, for simplicity RESNET defines all quality assurance as “quality assurance” and the standards clearly define RESNET’s meaning of “quality assurance”
Comment #179Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.1.1Comment Intent: Not an ObjectionComment Type: EditorialComment: The National RESNET Registry does not have a "date submitted" field. I believe the field being referred to is the "Date Registered" field. Proposed Change: 904.3.1.1 For QA File and QA Field reviews, the HERS Rater's “annual total of ratings” shall mean all ratings entered into the National RESNET Registry (based on “date submittedDate Registered”) for a calendar year, i.e. the twelve month period from January 1st through December 31st . Response: Accept
The National RESNET Registry does not have a "date submitted" field. I believe the field being referred to is the "Date Registered" field.
904.3.1.1 For QA File and QA Field reviews, the HERS Rater's “annual total of ratings” shall mean all ratings entered into the National RESNET Registry (based on “date submittedDate Registered”) for a calendar year, i.e. the twelve month period from January 1st through December 31st .
Comment #180Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 26Paragraph / Figure / Table / Note: 904.3.1.1Comment Intent: Not an ObjectionComment Type: EditorialComment: Language needs to be consistent. Change to date "registered". Proposed Change: 904.3.1.1 For QA File and QA Field reviews, the HERS Rater's “annual total of ratings” shall mean all ratings entered into the National RESNET Registry (based on “date submitted registered”) for a calendar year, i.e. the twelve month period from January 1st through December 31st. Response: Accept
Language needs to be consistent. Change to date "registered".
904.3.1.1 For QA File and QA Field reviews, the HERS Rater's “annual total of ratings” shall mean all ratings entered into the National RESNET Registry (based on “date submitted registered”) for a calendar year, i.e. the twelve month period from January 1st through December 31st.
Comment #181Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 26Paragraph / Figure / Table / Note: 904.3.1.1Comment Intent: ObjectionComment Type: GeneralComment: 904.3.1.1 This section should be more specific on date registered as this is more in line with the verbiage of RESNET Registry. Proposed Change: 904.3.1.1 For QA File and QA Field reviews, the HERS Rater's “annual total of ratings” shall mean all ratings entered into the National RESNET Registry (based on “date submitted”) (based on file registered date) for a calendar year, i.e. the twelve month period from January 1 st through December 31st Response: Accept
904.3.1.1
This section should be more specific on date registered as this is more in line with the verbiage of RESNET Registry.
904.3.1.1 For QA File and QA Field reviews, the HERS Rater's “annual total of ratings” shall mean all ratings entered into the National RESNET Registry (based on “date submitted”) (based on file registered date) for a calendar year, i.e. the twelve month period from January 1 st through December 31st
Comment #182Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.1.2Comment Intent: ObjectionComment Type: TechnicalComment: “Ratings selected for QA file and field review must be from the same twelve month time period used for the “annual total of ratings”. 4th Quarter is the crazy time; builders are pushing to have homes completed, holidays, bad weather. Even with current in house QA, trying to meet this would be difficult, having to schedule a 3rd party trip takes it to a different level – setting yourself up for failure – springs to mind. ”. What happens if homes are occupied? Getting back into the homes will be at a minimum a major inconvenience to all. Having the opportunity to catch 4th Quarter rating numbers in the next 1st Quarter is a great help. i reccomend aligning this with the language in 904.3.3.1.7 Proposed Change: 904.3.1.2 Ratings selected for QA file and field review must should be from the same twelve month time period used for the “annual total of ratings ” however homes available in the following first quarter can be used to meet the total Response: Reject Reason: There is no prohibition in the standards preventing the QA of homes registered to the Registry in the previous calendar year
“Ratings selected for QA file and field review must be from the same twelve month time period used for the “annual total of ratings”. 4th Quarter is the crazy time; builders are pushing to have homes completed, holidays, bad weather. Even with current in house QA, trying to meet this would be difficult, having to schedule a 3rd party trip takes it to a different level – setting yourself up for failure – springs to mind. ”. What happens if homes are occupied? Getting back into the homes will be at a minimum a major inconvenience to all. Having the opportunity to catch 4th Quarter rating numbers in the next 1st Quarter is a great help.
i reccomend aligning this with the language in 904.3.3.1.7
904.3.1.2 Ratings selected for QA file and field review must should be from the same twelve month time period used for the “annual total of ratings ” however homes available in the following first quarter can be used to meet the total
Reason: There is no prohibition in the standards preventing the QA of homes registered to the Registry in the previous calendar year
Comment #183Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.1.2Comment Intent: ObjectionComment Type: TechnicalComment: 904.3.1.2 seems to restrict Quality Agents to selecting homes for QA for a HERS Rater/RFI for a calendar year to the specific homes that were uploaded as part of their "annual total of ratings". While this makes sense conceptually, this greatly limits the ability of a Quality Agent to schedule QA Inspections in Q1 and Q4 of each year. It also contradicts 904.3.3.1.7 which directs Quality Agents to complete QA Field Reviews "based on the total number of ratings registed by the Provider in the previous quarter. Under 904.3.3.1.7 a Quality Agent should conduct QA Field Reviews for Q4 during Q1 of the subsequent year. These Q1 homes will not be from the same "annual total of ratings" however and therefore would not be valid QA reviews. Thus Q4 QA Field Reviews must cover both Q3 (the previous quarter) and Q4 (homes that are part of the same "annual total of ratings). Proposed Change: 904.3.1.2 Ratings selected for QA File and QA Field review must be from the same twelve month time period used for the “annual total of ratings.” Response: Accept in principle
904.3.1.2 seems to restrict Quality Agents to selecting homes for QA for a HERS Rater/RFI for a calendar year to the specific homes that were uploaded as part of their "annual total of ratings". While this makes sense conceptually, this greatly limits the ability of a Quality Agent to schedule QA Inspections in Q1 and Q4 of each year. It also contradicts 904.3.3.1.7 which directs Quality Agents to complete QA Field Reviews "based on the total number of ratings registed by the Provider in the previous quarter. Under 904.3.3.1.7 a Quality Agent should conduct QA Field Reviews for Q4 during Q1 of the subsequent year. These Q1 homes will not be from the same "annual total of ratings" however and therefore would not be valid QA reviews. Thus Q4 QA Field Reviews must cover both Q3 (the previous quarter) and Q4 (homes that are part of the same "annual total of ratings).
904.3.1.2 Ratings selected for QA File and QA Field review must be from the same twelve month time period used for the “annual total of ratings.”
Comment #184Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.1.2Comment Intent: ObjectionComment Type: TechnicalComment: I find 904.3.2.2 problematic from both a technical and philosophical standpoint and believe it should be struck completely. It creates inequity in the marketplace and incentivizes non-reporting of errors to manage QA workload. Proposed Change: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Response: Accept
I find 904.3.2.2 problematic from both a technical and philosophical standpoint and believe it should be struck completely. It creates inequity in the marketplace and incentivizes non-reporting of errors to manage QA workload.
904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated.
Comment #185Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 30Paragraph / Figure / Table / Note: 904.3.1.5Comment Intent: ObjectionComment Type: GeneralComment: I take issue with the following highlighted text: 904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtual” QA Field review methodology specified by RESNET. Here's my thinking: 1) Before any virtual QA is used, the methodology should receive public comments and be inserted into the standards. The reasoning here is that undoubtedly there are stakeholders who will not know about virtual QA being in the standards, and their comments are important. What happens when the methodology simply cannot work for them? What if it could've been easily rectified, if they had a chance to speak on the methodology? 2) I have a lot of concerns over the amount of "Betas" performed. While the working group has undoubtedly attempted more, the fact they only had 4 Betas is incredibly unsatisfying. In other fields like videogames, a Beta indicates you have hundreds, maybe thousands of players trying to navigate your game and find problems. In this case, there were literally only 4 tests. Not a full beta like in other industries, just 4 inspections. So now I ask: How can you create a methodology that actually works with only 4 test runs? Short answer: you can't. 3) Furthermore, it seems the working group (from the presentation I saw at the RESNET 2016 Conference) wants to run a pilot program, after this proposed language gets accepted into the standard. So, they're only going to do a real Beta, after it gets accepted. So this stuff will be in the standards, but because the methodology wouldn't be specified by RESNET until after that Pilot program, no one would be able to use virtual QA for another two or three years, if we're lucky. Why are you incorporating something into the standards that couldn't actually be used immediately? It does nothing for the Industry. 4) I find the lack of communication between the working group and individuals who have experience with video streaming and Remote field reviews to be disturbing. How long has JobWerks been active? It's a known program in the RESNET domain, but they haven't communicated with Rob Moody about any potential ideas (at least that's what it seems like from the Q&A portion of the RESNET 2016 Conference session). Additionally, none of the working group at the presentation had actual experience with video streaming, outside of "GoToMeeting" and typical video conferencing stuff. Make no mistake, this is something that a streaming media expert is needed on. It would have cut the development time down, and open the door for a lot more functionality in the proposed methodology. 5) Now to the methodology: It's overly complicated and puts a lot of onus on the HERS Rater. There's an obvious "carrot" for people to take up virtual QA- it'll cut down the costs for field reviews. Quality Agents won't have to fly or drive to a location, and it can be as cheap as having a smartphone with a 4G or LTE connection. I love that. But, and yes, there's always a but, the methodology left a lot to be desired. From what I saw, it falls down flat on the following points: 5A) It creates a new certification of "Virtual QA Assistant". In one path of performing a virtual QA, a Quality Agent can send a Virtual QA Assistant to the field. Now it's not as simple as "You're a certified HERS Rater, put this phone on your chest and video call me." They have to go through the same virtual QA training that Quality Agents have to go through. So, here's a new certification that's a pseudo-Quality Agent (further watering down RESNET's certifications), and you have to pay this person to go out in the field...which defeats the best thing about virtual QA because you have to pay this person and include travel costs. 5B) Because all paths of the proposed methodology require the HERS Rater to send a completed building file to the Quality Agent, it could seriously screw up HERS Raters with builders who have short closing windows. In Texas, it's not unheard for builders to have a final inspection, get a certification the next day, and close on the third. If a Rater hasn't already done all of the inspections they need to, how will they get a completed building file to the Quality Agent? It really messes up how things get scheduled for the HERS Rater, because they'd have to do a final inspection on a home, twice. So now their time is being wasted a second time, instead of just having the final inspection be a "full" inspection (duct blaster, blower door, measurements, etc) that gets virtual QA'ed. Overall, it seems that the current proposed methodology is continuously shoots itself in it's foot. On all fronts it seems to not save enough time (and make no mistake, time does equal money), and waters down our current certifications. There's a huge lack of actual testing on the proposed methodology, and a lack of communication between stakeholders. I move to completely strike virtual QA from the proposed standards until a serious pilot program with stringent testing takes place using proposed methodologies to find the best solution for virtual QA. Additionally, I call for the proposed methodology (post-pilot program) to receive a public comment session to give all stakeholders a chance to speak their minds. Finally, I ask that the proposed methodology be included into the Standards when that time comes. Proposed Change: 904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtual” QA Field review methodology specified by RESNET. 904.3.3.2.5 Virtual QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET. Response: Reject Reason: The committee supports the proposed methodology on remote QA being publicly vetted but see no reason to remove this section because the methodology is still being developed
I take issue with the following highlighted text:
904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtual” QA Field review methodology specified by RESNET.
Here's my thinking:
1) Before any virtual QA is used, the methodology should receive public comments and be inserted into the standards. The reasoning here is that undoubtedly there are stakeholders who will not know about virtual QA being in the standards, and their comments are important. What happens when the methodology simply cannot work for them? What if it could've been easily rectified, if they had a chance to speak on the methodology?
2) I have a lot of concerns over the amount of "Betas" performed. While the working group has undoubtedly attempted more, the fact they only had 4 Betas is incredibly unsatisfying. In other fields like videogames, a Beta indicates you have hundreds, maybe thousands of players trying to navigate your game and find problems. In this case, there were literally only 4 tests. Not a full beta like in other industries, just 4 inspections. So now I ask: How can you create a methodology that actually works with only 4 test runs? Short answer: you can't.
3) Furthermore, it seems the working group (from the presentation I saw at the RESNET 2016 Conference) wants to run a pilot program, after this proposed language gets accepted into the standard. So, they're only going to do a real Beta, after it gets accepted. So this stuff will be in the standards, but because the methodology wouldn't be specified by RESNET until after that Pilot program, no one would be able to use virtual QA for another two or three years, if we're lucky. Why are you incorporating something into the standards that couldn't actually be used immediately? It does nothing for the Industry.
4) I find the lack of communication between the working group and individuals who have experience with video streaming and Remote field reviews to be disturbing. How long has JobWerks been active? It's a known program in the RESNET domain, but they haven't communicated with Rob Moody about any potential ideas (at least that's what it seems like from the Q&A portion of the RESNET 2016 Conference session). Additionally, none of the working group at the presentation had actual experience with video streaming, outside of "GoToMeeting" and typical video conferencing stuff. Make no mistake, this is something that a streaming media expert is needed on. It would have cut the development time down, and open the door for a lot more functionality in the proposed methodology.
5) Now to the methodology: It's overly complicated and puts a lot of onus on the HERS Rater. There's an obvious "carrot" for people to take up virtual QA- it'll cut down the costs for field reviews. Quality Agents won't have to fly or drive to a location, and it can be as cheap as having a smartphone with a 4G or LTE connection. I love that. But, and yes, there's always a but, the methodology left a lot to be desired. From what I saw, it falls down flat on the following points:
5A) It creates a new certification of "Virtual QA Assistant". In one path of performing a virtual QA, a Quality Agent can send a Virtual QA Assistant to the field. Now it's not as simple as "You're a certified HERS Rater, put this phone on your chest and video call me." They have to go through the same virtual QA training that Quality Agents have to go through. So, here's a new certification that's a pseudo-Quality Agent (further watering down RESNET's certifications), and you have to pay this person to go out in the field...which defeats the best thing about virtual QA because you have to pay this person and include travel costs.
5B) Because all paths of the proposed methodology require the HERS Rater to send a completed building file to the Quality Agent, it could seriously screw up HERS Raters with builders who have short closing windows. In Texas, it's not unheard for builders to have a final inspection, get a certification the next day, and close on the third. If a Rater hasn't already done all of the inspections they need to, how will they get a completed building file to the Quality Agent? It really messes up how things get scheduled for the HERS Rater, because they'd have to do a final inspection on a home, twice. So now their time is being wasted a second time, instead of just having the final inspection be a "full" inspection (duct blaster, blower door, measurements, etc) that gets virtual QA'ed.
Overall, it seems that the current proposed methodology is continuously shoots itself in it's foot. On all fronts it seems to not save enough time (and make no mistake, time does equal money), and waters down our current certifications. There's a huge lack of actual testing on the proposed methodology, and a lack of communication between stakeholders.
I move to completely strike virtual QA from the proposed standards until a serious pilot program with stringent testing takes place using proposed methodologies to find the best solution for virtual QA. Additionally, I call for the proposed methodology (post-pilot program) to receive a public comment session to give all stakeholders a chance to speak their minds. Finally, I ask that the proposed methodology be included into the Standards when that time comes.
904.3.3.2.5 Virtual QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET.
Reason: The committee supports the proposed methodology on remote QA being publicly vetted but see no reason to remove this section because the methodology is still being developed
Comment #186Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 26Paragraph / Figure / Table / Note: 904.3.2.1Comment Intent: ObjectionComment Type: EditorialComment: I take issue with the highlighted text below: 904.3.2.1 QA File review of RESNET Flagged Files. Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the errors. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater. There shouldn't be a "may require". If there are significant errors impacting the rating, it should be required that there be an increase QA File and/or Field reviews. How else are you supposed to correct it? This is a loophole- I can see a Quality Agent calling up a HERS Rater, "Hey, Bob, I noticed you had some serious issues with this last file. Could you make sure not to do X, Y, and Z anymore?" "Sure thing, John!" "Great to hear, I'll call you if there are anymore issues." Obviously the conversations would probably be longer, but by simply having "may" in the language could let Quality Agents let it off with a simple phone call. I move to strike "may" from the propose amendment. Proposed Change: 904.3.2.1 QA File review of RESNET Flagged Files. Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the errors. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater. Response: Reject Reason: QA agents should use their own discretion in applying the requirement of additional QA
I take issue with the highlighted text below:
904.3.2.1 QA File review of RESNET Flagged Files. Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the errors. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater.
There shouldn't be a "may require". If there are significant errors impacting the rating, it should be required that there be an increase QA File and/or Field reviews. How else are you supposed to correct it?
This is a loophole- I can see a Quality Agent calling up a HERS Rater, "Hey, Bob, I noticed you had some serious issues with this last file. Could you make sure not to do X, Y, and Z anymore?" "Sure thing, John!" "Great to hear, I'll call you if there are anymore issues."
Obviously the conversations would probably be longer, but by simply having "may" in the language could let Quality Agents let it off with a simple phone call.
I move to strike "may" from the propose amendment.
Reason: QA agents should use their own discretion in applying the requirement of additional QA
Comment #187Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.1Comment Intent: Not an ObjectionComment Type: EditorialComment: Rating files flagged by RESNET may or may not contained errors. The language in this section is such that an error is assumed. The proposed language change removes this presumption of error. Proposed Change: 904.3.2.1 QA File review of RESNET Flagged Files. Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the errors, if any. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater. Response: Accept Reason: Accept in principle Edit to Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the any errors
Rating files flagged by RESNET may or may not contained errors. The language in this section is such that an error is assumed. The proposed language change removes this presumption of error.
904.3.2.1 QA File review of RESNET Flagged Files. Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the errors, if any. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater.
Reason: Accept in principle Edit to Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the any errors
Comment #188Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.1Comment Intent: ObjectionComment Type: TechnicalComment: What is the definition of a "RESNET Flagged File"? If this is referring to the flags in the registry then close to 100% of files would require review due to building address not being recognized. Even if these flags are exempted (which they are not in this version of the standard) some of the other flags need to be refined, such as the dryer having low usage whenever an ENERGY STAR washer is installed or foundation walls that are equal to or less than 6" above grade causing a flag (which is extremely common in the areas in which my Raters perform ratings and any home with a full basement foundation wall next to a garage slab.) This also conflicts with 904.3.2.4.1 because reviewing every flagged file would more than make up the percentage needed for file review. If this is not referring to the registry flags, then more definition is needed before making this a requirement. Proposed Change: 904.3.2.1 QA File review of RESNET Flagged Files. Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the errors. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater. Response: Accept Reason: Accept in principle Quality Agents shall review ratings with apparent errors flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the any errors
What is the definition of a "RESNET Flagged File"? If this is referring to the flags in the registry then close to 100% of files would require review due to building address not being recognized. Even if these flags are exempted (which they are not in this version of the standard) some of the other flags need to be refined, such as the dryer having low usage whenever an ENERGY STAR washer is installed or foundation walls that are equal to or less than 6" above grade causing a flag (which is extremely common in the areas in which my Raters perform ratings and any home with a full basement foundation wall next to a garage slab.) This also conflicts with 904.3.2.4.1 because reviewing every flagged file would more than make up the percentage needed for file review. If this is not referring to the registry flags, then more definition is needed before making this a requirement.
Reason: Accept in principle Quality Agents shall review ratings with apparent errors flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the any errors
Comment #189Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 26Paragraph / Figure / Table / Note: 904.3.2.1Comment Intent: ObjectionComment Type: GeneralComment: • This should be BETA tested by Rating Providers and QADs before it is implemented and the results of the BETA tests should be made available for Public Comment prior to including this in the Standard. • There isn’t a definition of significant errors and we don’t know what will be flagged. Proposed Change: 904.3.2.1 QA File review of RESNET Flagged Files. Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the errors. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater. Response: Accept Reason: Accept in principle Quality Agents shall review ratings with apparent errors flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the any errors
• This should be BETA tested by Rating Providers and QADs before it is implemented and the results of the BETA tests should be made available for Public Comment prior to including this in the Standard. • There isn’t a definition of significant errors and we don’t know what will be flagged.
Comment #190Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.1Comment Intent: ObjectionComment Type: TechnicalComment: I like the intent of this section, but I think it needs much more definition and context. For instance, what is a "RESNET Flag"? What rate should these flags be reviewed? Say if 80% of files get even just one flag, then is the expectation that QA Agents review 80% of that rater's files. How in depth are those flagged files to be reviewed? Is this a full 1 in 10 review or just review of the flag and all related inputs? Even if every flag required review by the QA Agent, there could be a lot of time wasted on just a few flags that don't have an impact. What if the flag is actually true and the rater is accurate, but the flag is too strict? For instance, REM Rate gives a warning that the system sizing is less than the load on the house. This warning is almost never accurate and comes up a lot on high performance homes. I think errors needs further definition. I thought you can't process ratings in the software with "errors" (REM Rate errors don't allow you to calculate, print reports, or register). How do errors differ from flags? What is a "significant errors"? Again I ask, because I don't see these defined anywhere. Last but not least why use "may require". That just takes the teeth out of the whole thing. I propose this section be removed until RESNET can further define these variables, otherwise it just causes more confusion. Proposed Change: 904.3.2.1 QA File review of RESNET Flagged Files. Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the errors. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater. Response: Accept Reason: Accept in principle Quality Agents shall review ratings with apparent errors flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the any errors.
I like the intent of this section, but I think it needs much more definition and context. For instance, what is a "RESNET Flag"?
What rate should these flags be reviewed? Say if 80% of files get even just one flag, then is the expectation that QA Agents review 80% of that rater's files. How in depth are those flagged files to be reviewed? Is this a full 1 in 10 review or just review of the flag and all related inputs? Even if every flag required review by the QA Agent, there could be a lot of time wasted on just a few flags that don't have an impact. What if the flag is actually true and the rater is accurate, but the flag is too strict? For instance, REM Rate gives a warning that the system sizing is less than the load on the house. This warning is almost never accurate and comes up a lot on high performance homes.
I think errors needs further definition. I thought you can't process ratings in the software with "errors" (REM Rate errors don't allow you to calculate, print reports, or register). How do errors differ from flags? What is a "significant errors"? Again I ask, because I don't see these defined anywhere.
Last but not least why use "may require". That just takes the teeth out of the whole thing. I propose this section be removed until RESNET can further define these variables, otherwise it just causes more confusion.
Reason: Accept in principle Quality Agents shall review ratings with apparent errors flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the any errors.
Comment #191Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.1Comment Intent: Not an ObjectionComment Type: GeneralComment: The term significant error needs to be defined. I suggest a significant error be one that produces the five point index swing that also causes a rating to fail QA review. change the text from: Significant errors impacting the rating may require increased QA file or field reviews for the HERS rater. to: Significant errors that cause the rating to vary by 5 index points or more from the index score calculated by the QA Agent shall require increased QA file or field reviews for the HERS rater. Response: Accept Reason: Accept in principle The determination of significant error will be determined based on information based on the pilot and testing of new spreadsheet QA tool
The term significant error needs to be defined.
I suggest a significant error be one that produces the five point index swing that also causes a rating to fail QA review.
change the text from: Significant errors impacting the rating may require increased QA file or field reviews for the HERS rater.
to: Significant errors that cause the rating to vary by 5 index points or more from the index score calculated by the QA Agent shall require increased QA file or field reviews for the HERS rater.
Reason: Accept in principle The determination of significant error will be determined based on information based on the pilot and testing of new spreadsheet QA tool
Comment #192Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 26Paragraph / Figure / Table / Note: 904.3.2.1Comment Intent: Not an ObjectionComment Type: GeneralComment: In the section below,what happens if flagged files exceed the 10% threshold for file QA? What happens if the items on the minimum rated features, plus flagged files exceed the 10% threshold for file QA? Does the QA agent get to prioritize what to focus on? Some clarity about how flagged items impact QA minimum thresholds as well as impacting the section of "no errors" qualifying a Rater for less QA would be welcome. Proposed Change: QA File review of RESNET Flagged Files. Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the errors. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater. Response: Accept in principle Reason: Quality Agents shall review ratings with apparent errors flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the any errors.
In the section below,what happens if flagged files exceed the 10% threshold for file QA? What happens if the items on the minimum rated features, plus flagged files exceed the 10% threshold for file QA? Does the QA agent get to prioritize what to focus on?
Some clarity about how flagged items impact QA minimum thresholds as well as impacting the section of "no errors" qualifying a Rater for less QA would be welcome.
QA File review of RESNET Flagged Files. Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the errors. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater.
Reason: Quality Agents shall review ratings with apparent errors flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the any errors.
Comment #193Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 26Paragraph / Figure / Table / Note: 904.3.2.1Comment Intent: Not an ObjectionComment Type: TechnicalComment: The flagging system should address QA issues and nothing other than that. For example, the system currently flags ratings because it cannot confirm the address. Proposed Change: 904.3.2.1 QA File review of RESNET Flagged Files. Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating issues related to quality assurance and working with the HERS Rater and Rating Quality Assurance Provider to correct the errors. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater. Response: Accept in principle Reason: Quality Agents shall review ratings with apparent errors flagged by the RESNET QA File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct the any errors.
The flagging system should address QA issues and nothing other than that. For example, the system currently flags ratings because it cannot confirm the address.
904.3.2.1 QA File review of RESNET Flagged Files. Quality Agents shall review ratings flagged by the RESNET QA File review for further Quality Assurance review, investigating issues related to quality assurance and working with the HERS Rater and Rating Quality Assurance Provider to correct the errors. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater.
Comment #194Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4-5Paragraph / Figure / Table / Note: 904.3.2.1, 904.3.2.4.1-904.3.2.4.3Comment Intent: ObjectionComment Type: GeneralComment: This section contains permissive language which is unenforceable and, therefore, does not belong in the Standards. Also, there are currently available software tools (Energy Gauge USA, QA Genie, for example) that are capable of performing data reasonability checks on every software file OR behavioral pattern detection that indicates the potential for mischievousness. This technology should not be ignored when it can dramatically reduce compliance costs. There is zero evidence that 10% file reviews are a reasonable number. With software validation checks on 100% of the simulation files in real time, prior to job completion, there is no need for a human “quality assurance” agent to do 10% file reviews after the project is done. It’s too late at that point to prevent failures, which is the whole point of quality assurance. Forcing all Raters to undergo 10% file reviews places an undue compliance cost and burden on the Raters who are doing good work compared to the risk undertaken by Raters who are not doing such good work. Raters are already required (in Chapter 1) to provide the information requested by the QA Provider in order to perform quality management. It is redundant to detail that again, plus it may lead to conflicting standards over time with the same or similar requirements in two locations. Proposed Change: Strike the following in its entirety: 904.3.2.2904.4.1.1 For each HERS Rater, the Provider’s Quality Assurance Contractor/Quality Agent Designee shall be responsible for an annual QA fFile review of the greater of one (1) home rating or ten percent (10%) of the HERS Rater's annual total of homes for which Confirmed or Sampled Ratings were provided. When determining the number of homesratings to review for a HERS Rater, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 homesratings x 10% = 10.1 means that 11 homesratings shall be reviewed. 904.3.2.3904.4.1.2 A QA fFile reviews shall be conducted on an ongoing basis as appropriate for the volume of ratings being completed and submitted to the National RESNET Registry, and at a minimum quarterly. 904.3.2.4.1904.4.1.3.11 HomesRatings shall be selected using a nonbiased selection process from the entire pool of homesratings available at the time of the review for each HERS Rater. It may be necessary to first select homesratings that represent any particular area of concern in either the rating or construction process. Once it is ensured that homesratings from these areas of interest will be included in the QAquality assurance process, a nonbiased selection process can then be applied such as random selection. Special effort should be taken to make certain that the selected homesratings are as representative as possible of the homesratings being ratedcompleted, i.e. new and existing homes, geographic location, builder, trade contractor, variety of floor plans, etc., which, in some instances, may require more than the minimum (1) home rating or ten percent (10%). 904.3.2.4.2904.4.1.3.2 While Section 102.1.4.11 and 303.3.7 require that HERS Raters submit energy simulation files for every rated home to their Providers, the QA file review does not require that Raters submit quality assurance data files, as defined in Appendix B, to their Provider and/or QA Designee for every home that is rated. Only quality assurance data files for the homesratings selected for QAquality assurance shall be required to be submitted for review by the Provider’s to theQuality Assurance Contractor/ Quality Agent Designee. 904.3.2.4.3904.4.1.3.3 For of each Confirmed Rating, confirm that the values entered into the HERS Rating Software for all Minimum Rated Features are supported by actual on-site field-verified test data; Replace with: 904.3.2.2 For each HERS Rater, the Provider's Quality Agent shall be responsible for a quarterly quality assurance file review prior to registering the quality assurance file review ratings with the National RESNET Registry. The energy simulation files selected for quality assurance file reviews shall be determined by errors detected during data reasonability checks. 904.3.2.4.1 Every energy simulation file shall undergo a minimum of 50 data reasonability checks consisting of inputs related to the minimum rated features or behavioral pattern detection based on the inputs. This quality assurance shall be performed by either a Quality Agent or a software program approved by RESNET. 904.2.2.4.1.1 When errors are detected, the rating must undergo a quality control file review that confirms the data entered into the Rating Software is supported by actual on-site, field-verified test and measurement data. Response: Reject Reason: Committee does not feel that an automated QA tool should replace the current model of 10% file QA reviews
This section contains permissive language which is unenforceable and, therefore, does not belong in the Standards.
Also, there are currently available software tools (Energy Gauge USA, QA Genie, for example) that are capable of performing data reasonability checks on every software file OR behavioral pattern detection that indicates the potential for mischievousness. This technology should not be ignored when it can dramatically reduce compliance costs.
There is zero evidence that 10% file reviews are a reasonable number. With software validation checks on 100% of the simulation files in real time, prior to job completion, there is no need for a human “quality assurance” agent to do 10% file reviews after the project is done. It’s too late at that point to prevent failures, which is the whole point of quality assurance.
Forcing all Raters to undergo 10% file reviews places an undue compliance cost and burden on the Raters who are doing good work compared to the risk undertaken by Raters who are not doing such good work.
Raters are already required (in Chapter 1) to provide the information requested by the QA Provider in order to perform quality management. It is redundant to detail that again, plus it may lead to conflicting standards over time with the same or similar requirements in two locations.
904.3.2.2904.4.1.1 For each HERS Rater, the Provider’s Quality Assurance Contractor/Quality Agent Designee shall be responsible for an annual QA fFile review of the greater of one (1) home rating or ten percent (10%) of the HERS Rater's annual total of homes for which Confirmed or Sampled Ratings were provided. When determining the number of homesratings to review for a HERS Rater, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 homesratings x 10% = 10.1 means that 11 homesratings shall be reviewed.
904.3.2.3904.4.1.2 A QA fFile reviews shall be conducted on an ongoing basis as appropriate for the volume of ratings being completed and submitted to the National RESNET Registry, and at a minimum quarterly.
904.3.2.4.1904.4.1.3.11 HomesRatings shall be selected using a nonbiased selection process from the entire pool of homesratings available at the time of the review for each HERS Rater. It may be necessary to first select homesratings that represent any particular area of concern in either the rating or construction process. Once it is ensured that homesratings from these areas of interest will be included in the QAquality assurance process, a nonbiased selection process can then be applied such as random selection. Special effort should be taken to make certain that the selected homesratings are as representative as possible of the homesratings being ratedcompleted, i.e. new and existing homes, geographic location, builder, trade contractor, variety of floor plans, etc., which, in some instances, may require more than the minimum (1) home rating or ten percent (10%).
904.3.2.4.2904.4.1.3.2 While Section 102.1.4.11 and 303.3.7 require that HERS Raters submit energy simulation files for every rated home to their Providers, the QA file review does not require that Raters submit quality assurance data files, as defined in Appendix B, to their Provider and/or QA Designee for every home that is rated. Only quality assurance data files for the homesratings selected for QAquality assurance shall be required to be submitted for review by the Provider’s to theQuality Assurance Contractor/ Quality Agent Designee.
904.3.2.4.3904.4.1.3.3 For of each Confirmed Rating, confirm that the values entered into the HERS Rating Software for all Minimum Rated Features are supported by actual on-site field-verified test data;
904.3.2.2 For each HERS Rater, the Provider's Quality Agent shall be responsible for a quarterly quality assurance file review prior to registering the quality assurance file review ratings with the National RESNET Registry. The energy simulation files selected for quality assurance file reviews shall be determined by errors detected during data reasonability checks.
904.3.2.4.1 Every energy simulation file shall undergo a minimum of 50 data reasonability checks consisting of inputs related to the minimum rated features or behavioral pattern detection based on the inputs. This quality assurance shall be performed by either a Quality Agent or a software program approved by RESNET.
904.2.2.4.1.1 When errors are detected, the rating must undergo a quality control file review that confirms the data entered into the Rating Software is supported by actual on-site, field-verified test and measurement data.
Reason: Committee does not feel that an automated QA tool should replace the current model of 10% file QA reviews
Comment #195Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.2Comment Intent: ObjectionComment Type: GeneralComment: The use of the term "Contractor" is redundant, as is the explanation of rounding up to the next whole number. Proposed Change: Strike the following in its entirety: 904.3.2.2904.4.1.1 For each HERS Rater, the Provider’s Quality Assurance Contractor/Quality Agent Designee shall be responsible for an annual QA fFile review of the greater of one (1) home rating or ten percent (10%) of the HERS Rater's annual total of homes for which Confirmed or Sampled Ratings were provided. When determining the number of homesratings to review for a HERS Rater, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 homesratings x 10% = 10.1 means that 11 homesratings shall be reviewed. Replace with: 904.3.2.2 For each HERS Rater, the Provider's Quality Agents shall be responsible for annual quality control file review of the greater of one (1) home or ten percent (10%) of the HERS Rater's annual total of Confirmed and Sampled Ratings. When determining the number of ratings to review per HERS Rater, round up to the next whole number. Response: Reject Reason: The original language provides clarity that the proposed replacement language does not
The use of the term "Contractor" is redundant, as is the explanation of rounding up to the next whole number.
904.3.2.2 For each HERS Rater, the Provider's Quality Agents shall be responsible for annual quality control file review of the greater of one (1) home or ten percent (10%) of the HERS Rater's annual total of Confirmed and Sampled Ratings. When determining the number of ratings to review per HERS Rater, round up to the next whole number.
Reason: The original language provides clarity that the proposed replacement language does not
Comment #196Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.2Comment Intent: ObjectionComment Type: GeneralComment: Who is responsible for what? Also, can the definition of how to count the number of Ratings required for annual QA be provided ONCE in the Standard, then simply referenced? There is no need to define QA rates so many times throughout this document. Proposed Change: It's difficult to implement the changes that have already been proposed when copying and pasting text into this box. Response: Reject Reason: Redundancy has value as to reduce confusion
Who is responsible for what?
Also, can the definition of how to count the number of Ratings required for annual QA be provided ONCE in the Standard, then simply referenced? There is no need to define QA rates so many times throughout this document.
It's difficult to implement the changes that have already been proposed when copying and pasting text into this box.
Reason: Redundancy has value as to reduce confusion
Comment #197Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 26Paragraph / Figure / Table / Note: 904.3.2.2.1Comment Intent: ObjectionComment Type: TechnicalComment: I take issue with the highlighted text below: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Yeah, I have a problem with the whole thing. Two problems: 1) This is incredibly biased towards large rating companies, and it goes directly against holding everyone accountable to the same level. It shouldn't matter how many ratings someone does- they still run the same risk of messing up or lying. Doing more in this case just means they have an easier chance to skip out on having their files reviewed. 2) This proposed language would have a huge affect on rating companies that do mostly sampling. Literally, it's right there in the first line, "...who conduct over 500 confirmed ratings..." If you're mostly doing sampling you're going to be hit at a higher rate for QA reviews than someone doing the bare minimum of 500 confirmed ratings. I move to completely strike the language from the proposed standards. Proposed Change: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Response: Accept Reason: Entire section will be deleted
Yeah, I have a problem with the whole thing. Two problems:
1) This is incredibly biased towards large rating companies, and it goes directly against holding everyone accountable to the same level. It shouldn't matter how many ratings someone does- they still run the same risk of messing up or lying. Doing more in this case just means they have an easier chance to skip out on having their files reviewed.
2) This proposed language would have a huge affect on rating companies that do mostly sampling. Literally, it's right there in the first line, "...who conduct over 500 confirmed ratings..." If you're mostly doing sampling you're going to be hit at a higher rate for QA reviews than someone doing the bare minimum of 500 confirmed ratings.
I move to completely strike the language from the proposed standards.
Reason: Entire section will be deleted
Comment #198Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.2.1Comment Intent: ObjectionComment Type: TechnicalComment: It is being proposed that Home Energy Raters that conduct over 500 confirmed ratings in one year and do not have errors found for over a two (2) year period will have a reduction in the required quality assurance reviews. I have a number of concerns with this proposed change. First, this Section references Section 904.3.5.1 for a definition of “error.” That Section, however, does not even use the term “error” and the term is not adequately defined within the proposed Standard. Additionally, I believe there is a distinction that needs to be made between an “error” and QA File or Field review “failure.” I believe an error is simply any QA finding (i.e. anything that is incorrect in the HERS Rating). These include incorrect home orientation, missing a window, incorrect insulation grade, and other common mistakes. The proposed Standards allow the errors to “cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores.” Thus, there are errors that many QADs deem insignificant enough that Ratings are not being updated to the Registry. Furthermore, I believe QADs also commonly make distinctions between “significant” and “insignificant” errors. For example, many QADs require building files are updated and re-uploaded to the Registry if there is an error that impacts the HERC. For example, the number of bedrooms may not alter the Index enough to be deemed a “failure,” but this is something that a consumer is likely to see and should be corrected. Section 904.3.2.1 used the terms “error” and “significant error” without clear definitions. Clear definitions of “error” and “significant error” are necessary. Using my proposed definition of an error (anything that is incorrect in the HERS Rating), I believe it is nearly impossible to perform 500 Ratings without error. I would go so far as to add this is probably worthy of being “flagged” by the QA Genie as grounds to investigate a QAD/Quality Agent for performing inadequate QA. Second, there is a strong feeling within the industry that the proposed QA changes favor larger Rating companies. While I do not wish to debate the accuracy of this sentiment, I do want to point out that this proposed amendment clearly favors larger Rating companies. Third, for a Rater to perform 500 Ratings in one year they will likely need one or more RFIs. To perform this many Ratings without error requires robust systems and processes to ensure accuracy, but there are also increased opportunities for errors to occur due to the added personnel. I view this has further reason to reject this amendment. In conclusion, I object to this amendment. Defitions for "error" and "significant error" need to be added to the proposed Standards. I also would suggest a counter amendment to incorporate checks within QA Genie to flag any QAD/Quality Agent that does not find errors on a given number of Ratings. There should be a new metric for an anticipated number of errors per Ratings. Perhaps something like 1 error per 100 Ratings. Proposed Change: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. 904.3.5.1 An error is defined as any inaccuracy within a energy simulation file. Significant errors are errors that appear on the Home Energy Rating Certificate or move the HERS Index score for the home QA Field reviewed more than one percent (1%) (+/-) of the original HERS Index score for the energy simulation file. Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores for each energy simulation file. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable cumulative variance never less than four (4) HERS Index points. For example, if an energy simulation file shows an initial HERS Index of 75, the allowable cumulative variance in the HERS Index score is 75 x 5% = 3.75, or an allowable cumulative variance of no more than the 4 HERS Index minimum. If during the QA review, the QA determines that corrections to the energy simulation file were necessary which moved the HERS Index down 2 points and up 3 point, for a cumulative move of 5 HERS Index points, then the rating shall be deemed “non-compliant.” 904.4.1.4 RESNET shall review the performance of Quality Agents. Any Quality Agent that does not find errors on a given number of Ratings shall be flagged for possible noncompliance. A new error per Rating metric will be developed and used for Quality Assurance checks. Quality Agents are expected to identify a minimum of 1 error per 100 Ratings per Rater. The error metric will be used to identify possible noncompliance by Quality Agents and is not in and of itself a failure or noncompliance issue. Response: Accept Reason: Accept in principle. Entire section will be removed
It is being proposed that Home Energy Raters that conduct over 500 confirmed ratings in one year and do not have errors found for over a two (2) year period will have a reduction in the required quality assurance reviews. I have a number of concerns with this proposed change.
First, this Section references Section 904.3.5.1 for a definition of “error.” That Section, however, does not even use the term “error” and the term is not adequately defined within the proposed Standard. Additionally, I believe there is a distinction that needs to be made between an “error” and QA File or Field review “failure.” I believe an error is simply any QA finding (i.e. anything that is incorrect in the HERS Rating). These include incorrect home orientation, missing a window, incorrect insulation grade, and other common mistakes.
The proposed Standards allow the errors to “cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores.” Thus, there are errors that many QADs deem insignificant enough that Ratings are not being updated to the Registry. Furthermore, I believe QADs also commonly make distinctions between “significant” and “insignificant” errors. For example, many QADs require building files are updated and re-uploaded to the Registry if there is an error that impacts the HERC. For example, the number of bedrooms may not alter the Index enough to be deemed a “failure,” but this is something that a consumer is likely to see and should be corrected. Section 904.3.2.1 used the terms “error” and “significant error” without clear definitions. Clear definitions of “error” and “significant error” are necessary.
Using my proposed definition of an error (anything that is incorrect in the HERS Rating), I believe it is nearly impossible to perform 500 Ratings without error. I would go so far as to add this is probably worthy of being “flagged” by the QA Genie as grounds to investigate a QAD/Quality Agent for performing inadequate QA.
Second, there is a strong feeling within the industry that the proposed QA changes favor larger Rating companies. While I do not wish to debate the accuracy of this sentiment, I do want to point out that this proposed amendment clearly favors larger Rating companies.
Third, for a Rater to perform 500 Ratings in one year they will likely need one or more RFIs. To perform this many Ratings without error requires robust systems and processes to ensure accuracy, but there are also increased opportunities for errors to occur due to the added personnel. I view this has further reason to reject this amendment.
In conclusion, I object to this amendment. Defitions for "error" and "significant error" need to be added to the proposed Standards. I also would suggest a counter amendment to incorporate checks within QA Genie to flag any QAD/Quality Agent that does not find errors on a given number of Ratings. There should be a new metric for an anticipated number of errors per Ratings. Perhaps something like 1 error per 100 Ratings.
904.3.5.1 An error is defined as any inaccuracy within a energy simulation file. Significant errors are errors that appear on the Home Energy Rating Certificate or move the HERS Index score for the home QA Field reviewed more than one percent (1%) (+/-) of the original HERS Index score for the energy simulation file.
Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores for each energy simulation file. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable cumulative variance never less than four (4) HERS Index points.
For example, if an energy simulation file shows an initial HERS Index of 75, the allowable cumulative variance in the HERS Index score is 75 x 5% = 3.75, or an allowable cumulative variance of no more than the 4 HERS Index minimum. If during the QA review, the QA determines that corrections to the energy simulation file were necessary which moved the HERS Index down 2 points and up 3 point, for a cumulative move of 5 HERS Index points, then the rating shall be deemed “non-compliant.”
904.4.1.4 RESNET shall review the performance of Quality Agents. Any Quality Agent that does not find errors on a given number of Ratings shall be flagged for possible noncompliance. A new error per Rating metric will be developed and used for Quality Assurance checks. Quality Agents are expected to identify a minimum of 1 error per 100 Ratings per Rater. The error metric will be used to identify possible noncompliance by Quality Agents and is not in and of itself a failure or noncompliance issue.
Reason: Accept in principle. Entire section will be removed
Comment #199Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.2.1Comment Intent: ObjectionComment Type: GeneralComment: This section is confusing and opens up an unintended(?) consequence. In 2017, Joe Schmuckatelli performs 550 ratings without errors in file reviews. In 2018, Joe performs 200 ratings without errors in file reviews. Now his file reviews SHALL be reduced 25%. According to this section, he only has to have 15 file reviews for the year instead of 20. In year 2019, Joe does 150 ratings without errors in file reviews and in year 2020, he does 100 ratings without file reviews. Now his review rate drops to 5 file reviews for the year instead of 10. According to this section, all Joe has to do to earn a 50% reduction in file reviews is to hit 500 homes in one year then coast for the next 3 years (as long as he doesn't have any file review errors). I don't think that is what was intended. Proposed Change: Strike the following in its entirety: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Do NOT replace. Response: Accept
This section is confusing and opens up an unintended(?) consequence.
In 2017, Joe Schmuckatelli performs 550 ratings without errors in file reviews. In 2018, Joe performs 200 ratings without errors in file reviews. Now his file reviews SHALL be reduced 25%. According to this section, he only has to have 15 file reviews for the year instead of 20.
In year 2019, Joe does 150 ratings without errors in file reviews and in year 2020, he does 100 ratings without file reviews. Now his review rate drops to 5 file reviews for the year instead of 10.
According to this section, all Joe has to do to earn a 50% reduction in file reviews is to hit 500 homes in one year then coast for the next 3 years (as long as he doesn't have any file review errors).
I don't think that is what was intended.
Comment #200Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.2.1Comment Intent: ObjectionComment Type: EditorialComment: 904.3.2.2.1 change 500 to 300, so more Raters will be eligible. Proposed Change: • 904.3.2.2.1 Home Energy Raters who conduct over 500 300 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Response: Reject Reason: Entire section will be removed
904.3.2.2.1 change 500 to 300, so more Raters will be eligible.
• 904.3.2.2.1 Home Energy Raters who conduct over 500 300 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated.
Reason: Entire section will be removed
Comment #201Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 26Paragraph / Figure / Table / Note: 904.3.2.2.1Comment Intent: ObjectionComment Type: TechnicalComment: Based on my File QA experience with large volume raters, this is unreachable, however I think the intent is good. I think it should be changed to 1 year period to make it more obtainable. I also believe some clarification is necessary for "reduced by 25%." Does this mean that the number of files reviewed goes from 10% to 7.5%? (logic: 25% of 10% is 7.5%) If so, I think the standards should just state 7.5% instead of "reduced by 25%" and similar comment for "reduced by 50%" Proposed Change: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) one (1) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced to 7.5%by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced to 5% by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Response: Reject Reason: Entire section will be removed
Based on my File QA experience with large volume raters, this is unreachable, however I think the intent is good. I think it should be changed to 1 year period to make it more obtainable.
I also believe some clarification is necessary for "reduced by 25%." Does this mean that the number of files reviewed goes from 10% to 7.5%? (logic: 25% of 10% is 7.5%) If so, I think the standards should just state 7.5% instead of "reduced by 25%" and similar comment for "reduced by 50%"
904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) one (1) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced to 7.5%by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced to 5% by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated.
Comment #202Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.2.1Comment Intent: ObjectionComment Type: TechnicalComment: RESNET has always stated that Rating Providers may have more strict requirements than the minimums set forth in RESNET standards. However, the use of the word, "shall" in this paragraph removes that ability from the Provider. Proposed Change: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review may shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews may shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Response: Reject Reason: Entire section will be removed
RESNET has always stated that Rating Providers may have more strict requirements than the minimums set forth in RESNET standards. However, the use of the word, "shall" in this paragraph removes that ability from the Provider.
904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review may shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews may shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated.
Comment #203Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.2.1Comment Intent: ObjectionComment Type: TechnicalComment: 904.3.2.2.1 There is no reason to reduce the frequency of quality assurance checks. Ongoing quality assurance is key to consistency. Proposed Change: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Response: Accept
904.3.2.2.1
There is no reason to reduce the frequency of quality assurance checks. Ongoing quality assurance is key to consistency.
Comment #204Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.2.1Comment Intent: ObjectionComment Type: TechnicalComment: Raters who only conduct one Rating per year are effectively required to have 100% Field QA. The quality of that Rating is pretty well assured. The extent of the damage they can do to consumers and the industry's reputation is pretty limited. Raters who conduct many hundreds of Ratings each year have a much broader reach in terms of the consumers, builders, and other stakeholders they interact with; the extent of the damage they can do to the industry's reputation is orders of magnitude larger. With this in mind, it almost makes sense to do more QA on Raters who conduct more Ratings per year, but the balance is that they are also more practiced and less likely to make mistakes. I believe that a comfortable balance is to retain the current QA ratios. I am also in favor of predicting the number of ratings to be conducted per quarter or every six months and distributing QA requirements throughout the year. If the Rater who conducted 500 ratings last year assessed one critical minimum rated feature incorrectly consistently, all 500 of those homes would have flawed HERS Ratings. And the Rater's Provider may not even learn of the flaw until the first quarter of the following year. Due to a variety of reasons, it would be impossible to rescind or alter those Ratings. In order to "improve the national consistency of the HERS Index score," it is even more critical to evaluate the ratings performed by large-scale Raters. I conduct more than a hundred Ratings every year, so I am not coming from a position of small-Rater bias. I believe that QA is important to our industry, that we shouldn't value-engineer it out of our standard, and that our Standard should be written in such a way that it can be understood by all HERS Raters and RFIs. Proposed Change: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Response: Accept Reason: Entire section will be removed
Raters who only conduct one Rating per year are effectively required to have 100% Field QA. The quality of that Rating is pretty well assured. The extent of the damage they can do to consumers and the industry's reputation is pretty limited.
Raters who conduct many hundreds of Ratings each year have a much broader reach in terms of the consumers, builders, and other stakeholders they interact with; the extent of the damage they can do to the industry's reputation is orders of magnitude larger.
With this in mind, it almost makes sense to do more QA on Raters who conduct more Ratings per year, but the balance is that they are also more practiced and less likely to make mistakes.
I believe that a comfortable balance is to retain the current QA ratios. I am also in favor of predicting the number of ratings to be conducted per quarter or every six months and distributing QA requirements throughout the year. If the Rater who conducted 500 ratings last year assessed one critical minimum rated feature incorrectly consistently, all 500 of those homes would have flawed HERS Ratings. And the Rater's Provider may not even learn of the flaw until the first quarter of the following year. Due to a variety of reasons, it would be impossible to rescind or alter those Ratings. In order to "improve the national consistency of the HERS Index score," it is even more critical to evaluate the ratings performed by large-scale Raters.
I conduct more than a hundred Ratings every year, so I am not coming from a position of small-Rater bias. I believe that QA is important to our industry, that we shouldn't value-engineer it out of our standard, and that our Standard should be written in such a way that it can be understood by all HERS Raters and RFIs.
Comment #205Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.2.1Comment Intent: ObjectionComment Type: TechnicalComment: Raters who only conduct one Rating per year are effectively required to have 100% Field QA. The quality of that Rating is pretty well assured. The extent of the damage they can do to consumers and the industry's reputation is pretty limited. Raters who conduct many hundreds of Ratings each year have a much broader reach in terms of the consumers, builders, and other stakeholders they interact with; the extent of the damage they can do to the industry's reputation is orders of magnitude larger. With this in mind, it almost makes sense to do more QA on Raters who conduct more Ratings per year, but the balance is that they are also more practiced and less likely to make mistakes. I believe that a comfortable balance is to retain the current QA ratios. I am also in favor of predicting the number of ratings to be conducted per quarter or every six months and distributing QA requirements throughout the year. If the Rater who conducted 500 ratings last year assessed one critical minimum rated feature incorrectly consistently, all 500 of those homes would have flawed HERS Ratings. And the Rater's Provider may not even learn of the flaw until the first quarter of the following year. Due to a variety of reasons, it would be impossible to rescind or alter those Ratings. In order to "improve the national consistency of the HERS Index score," it is even more critical to evaluate the ratings performed by large-scale Raters. I conduct more than a hundred Ratings every year, so I am not coming from a position of small-Rater bias. I believe that QA is important to our industry, that we shouldn't value-engineer it out of our standard, and that our Standard should be written in such a way that it can be understood by all HERS Raters and RFIs. Proposed Change: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Response: Accept Reason: Entire section will be removed
Comment #206Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.2.1Comment Intent: ObjectionComment Type: GeneralComment: Big companies make significant errors. Reduction by 25% is good enough. Proposed Change: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Response: Reject Reason: Entire section will be removed
Big companies make significant errors. Reduction by 25% is good enough.
Comment #207Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 26Paragraph / Figure / Table / Note: 904.3.2.2.1Comment Intent: Not an ObjectionComment Type: GeneralComment: The idea is sound, but we feel asking for 500 continuous projects in such a short time is not feasible for many companies. In addition, lower volume Raters with excellent track records should also be able to reduce their QA over time. In addition, the language needs claritiy (similar to our previous comment about cumulative %s of delta). We humbly submit the following: Proposed Change: Home Energy Raters who conduct over 500 350 confirmed ratings in one year and if over a two (2) year period do not have any serious errors as defined in section 904.3.5.1 (move HERs by more than 5% or consumption by more than 10% cumulative) during file QA reviews, their file QA review shall be reduced by 25%. If no serious errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Home Energy Raters who conduct over 20 confirmed ratings in one year and meet the same quality thresholds shall qualify for reduced file QA by 10%. If no serious errors are found in the subsequent two (2) years then the file QA reviews shall be reduce by 20% in the following years. Response: Reject Reason: Entire section will be removed
The idea is sound, but we feel asking for 500 continuous projects in such a short time is not feasible for many companies. In addition, lower volume Raters with excellent track records should also be able to reduce their QA over time.
In addition, the language needs claritiy (similar to our previous comment about cumulative %s of delta).
We humbly submit the following:
Home Energy Raters who conduct over 500 350 confirmed ratings in one year and if over a two (2) year period do not have any serious errors as defined in section 904.3.5.1 (move HERs by more than 5% or consumption by more than 10% cumulative) during file QA reviews, their file QA review shall be reduced by 25%. If no serious errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Home Energy Raters who conduct over 20 confirmed ratings in one year and meet the same quality thresholds shall qualify for reduced file QA by 10%. If no serious errors are found in the subsequent two (2) years then the file QA reviews shall be reduce by 20% in the following years.
Comment #208Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 26Paragraph / Figure / Table / Note: 904.3.2.2.1Comment Intent: ObjectionComment Type: TechnicalComment: This section is biased toward a rater that produces arbitrary number of ratings and does not enhance the quality assurance of ratings. Propose striking this section. Proposed Change: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Response: Accept
This section is biased toward a rater that produces arbitrary number of ratings and does not enhance the quality assurance of ratings. Propose striking this section.
Comment #209Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 26Paragraph / Figure / Table / Note: 904.3.2.2.1Comment Intent: ObjectionComment Type: GeneralComment: • 904.3.2.2.1 strike out the entire section as this is biased toward a rater that produces an arbitrary number of ratings with no real relevance to the standards. Proposed Change: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Response: Accept
• 904.3.2.2.1
strike out the entire section as this is biased toward a rater that produces an arbitrary number of ratings with no real relevance to the standards.
Comment #210Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4 & 9-6Paragraph / Figure / Table / Note: 904.3.2.2.1 & 904.3.3.1.1.1Comment Intent: ObjectionComment Type: TechnicalComment: This would be a hugh advantage to a large Rater. I don't feel tha QA should be lessened because of the number of ratings a rater does. They can still make mistakes - especially if they do that many in one year. They might start "cutting corners" to get them done more quickly. Proposed Change: Both of these sections should be struck completely 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated[D1] . [D1]Advantage large raters (& 904.3.3.1.1.1) 904.3.3.1.1.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the field QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated. Response: Accept
This would be a hugh advantage to a large Rater. I don't feel tha QA should be lessened because of the number of ratings a rater does. They can still make mistakes - especially if they do that many in one year. They might start "cutting corners" to get them done more quickly.
Both of these sections should be struck completely
904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section
904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated[D1] .
[D1]Advantage large raters (& 904.3.3.1.1.1)
904.3.3.1.1.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the field QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated.
Comment #211Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 26Paragraph / Figure / Table / Note: 904.3.2.3Comment Intent: ObjectionComment Type: TechnicalComment: I take issue with the highlighted language below: 904.3.2.3 QAFile reviews shall be conducted on an ongoing basis as appropriate for the volume of ratings being completed and submitted to the National RESNET Registry, and at a minimum quarterly. I don't necessarily have a problem with the text, but moreso the functionality of it. Right now if you try to upload a file with the same address as one in the registry, you will get blocked from uploading it. There will be a warning asking about "Whoa, are you sure this isn't a duplicate?" So unless there is a separate upload function for Providers offered by the Software Providers in their tools, this language should be struck. Once that functionality gets included, (actually) tested, and approved, then this should be added in. Proposed Change: 904.3.2.3 QAFile reviews shall be conducted on an ongoing basis as appropriate for the volume of ratings being completed and submitted to the National RESNET Registry, and at a minimum quarterly. Response: Reject Reason: File QA review volume is based on submission date to the RESNET registry
I take issue with the highlighted language below:
904.3.2.3 QAFile reviews shall be conducted on an ongoing basis as appropriate for the volume of ratings being completed and submitted to the National RESNET Registry, and at a minimum quarterly.
I don't necessarily have a problem with the text, but moreso the functionality of it. Right now if you try to upload a file with the same address as one in the registry, you will get blocked from uploading it. There will be a warning asking about "Whoa, are you sure this isn't a duplicate?"
So unless there is a separate upload function for Providers offered by the Software Providers in their tools, this language should be struck. Once that functionality gets included, (actually) tested, and approved, then this should be added in.
Reason: File QA review volume is based on submission date to the RESNET registry
Comment #212Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.2.3Comment Intent: ObjectionComment Type: TechnicalComment: The instruction in this provision is scarce and may be difficult to implement without additional guidance. If a Rater is only required to have a few QA File reviews each year, they should be exempt from this provision. As a Rater and not a Provider, I'm not sure where completed QA File reviews are currently submitted. Proposed Change: 904.3.2.3 When Raters conduct over 40 Ratings per year, QA File reviews shall be conducted on an ongoing basis, in proportion to as appropriate for the volume of Confirmed Rratings being completed and submitted to the NationalRESNET Registry, and at a minimum quarterly every quarter. Each quarter, the number of QA File reviews that must be completed shall be determined by calculating 10% of the total Confirmed Ratings submitted in the most recent past quarter. The number of Ratings reviewed each quarter shall be rounded down. At the end of the fourth quarter of the year, the total number of required QA File reviews shall be compared to the number of quarterly QA File reviews that were completed. Any additional QA File reviews required as a result of rounding must be completed in the fourth quarter. Response: Accept Reason: Low volume exceptions for raters was removed several years ago
The instruction in this provision is scarce and may be difficult to implement without additional guidance.
If a Rater is only required to have a few QA File reviews each year, they should be exempt from this provision.
As a Rater and not a Provider, I'm not sure where completed QA File reviews are currently submitted.
904.3.2.3 When Raters conduct over 40 Ratings per year, QA File reviews shall be conducted on an ongoing basis, in proportion to as appropriate for the volume of Confirmed Rratings being completed and submitted to the NationalRESNET Registry, and at a minimum quarterly every quarter.
Each quarter, the number of QA File reviews that must be completed shall be determined by calculating 10% of the total Confirmed Ratings submitted in the most recent past quarter. The number of Ratings reviewed each quarter shall be rounded down. At the end of the fourth quarter of the year, the total number of required QA File reviews shall be compared to the number of quarterly QA File reviews that were completed. Any additional QA File reviews required as a result of rounding must be completed in the fourth quarter.
Reason: Low volume exceptions for raters was removed several years ago
Comment #213Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-5Paragraph / Figure / Table / Note: 904.3.2.4.1Comment Intent: ObjectionComment Type: TechnicalComment: "...which, in some instances, may require more than the minimum (1) rating or ten percent (10%)." Where did that come from? What are the parameters by which Providers are required to determine this increased rate of QA? When will this determination ever be in everybody's best interest? How can this phrase be implemented consistently and fairly? If a small-scale Rater does five Ratings in a year on very different home types: a few townhomes, a single family home or two, a gut-rehab, and an existing single family home, is the Provider required to do QA on all five of those Ratings, or can the Provider do the typical 10% or 1 QA File review? I agree with the sentiment of the rest of this provision, except this last phrase is a curve ball with which I disagree. Proposed Change: 904.3.2.4.1 Ratings shall be selected using a nonbiased selection process from the entire pool of Rratings available at the time of the review for each HERS Rater. It may be necessary to first select Rratings that represent any particular area of concern in either the rating or construction process. Once it is ensured that Rratings from these areas of interest will be included in the quality assurance process, a nonbiased selection process can then be applied such as random selection. Special effort should be taken to make certain that the selected homesratings are as representative as possible of the Rrating being completed, i.e. new and existing homes, geographic location, builder, trade contractor, variety of floor plans, etc., which, in some instances, may require more than the minimum (1) home rating or ten percent (10%). Response: Reject Reason: Strike of the last line should not be removed- language provides additional clarity Defer to staff on proper capitalization of “rating”
"...which, in some instances, may require more than the minimum (1) rating or ten percent (10%)."
Where did that come from? What are the parameters by which Providers are required to determine this increased rate of QA? When will this determination ever be in everybody's best interest? How can this phrase be implemented consistently and fairly?
If a small-scale Rater does five Ratings in a year on very different home types: a few townhomes, a single family home or two, a gut-rehab, and an existing single family home, is the Provider required to do QA on all five of those Ratings, or can the Provider do the typical 10% or 1 QA File review?
I agree with the sentiment of the rest of this provision, except this last phrase is a curve ball with which I disagree.
904.3.2.4.1 Ratings shall be selected using a nonbiased selection process from the entire pool of Rratings available at the time of the review for each HERS Rater. It may be necessary to first select Rratings that represent any particular area of concern in either the rating or construction process. Once it is ensured that Rratings from these areas of interest will be included in the quality assurance process, a nonbiased selection process can then be applied such as random selection. Special effort should be taken to make certain that the selected homesratings are as representative as possible of the Rrating being completed, i.e. new and existing homes, geographic location, builder, trade contractor, variety of floor plans, etc., which, in some instances, may require more than the minimum (1) home rating or ten percent (10%).
Reason: Strike of the last line should not be removed- language provides additional clarity Defer to staff on proper capitalization of “rating”
Comment #214Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 27Paragraph / Figure / Table / Note: 904.3.2.5.1Comment Intent: ObjectionComment Type: EditorialComment: I take issue with the highlighted text below: 904.3.2.5.1 The QA File review for sampled ratings shall include a review of the greater of one (1) file or ten percent (10%) of the projected worst-case energy simulation files for each new sampled community in order to confirm that minimum rated features and worst-case specifications have been entered into the rating software accurately. Energy simulation files for an existing sampled community shall receive a QA File review, at a rate of one (1) file or ten percent (10%) of the worst-case energy simulation files, if the minimum rated features and/or threshold specifications change. Here's why: the language of this standard should mirror a new sampled community, otherwise it leaves holes for errors. The reason is because this proposed standards says a lot with what isn't actually written in there. Existing sampled communities will receive a QA File review...it the minimum rated features and/or threshold specifications change. Let's set up an example: if a jurisdiction doesn't change the threshold specifications except when there's a new code, that means those numbers would change, at the minimum, of every three years (if they accept the new code). Furthermore, the builder and/or developer isn't changing the minimum rated features during those three years. What does that mean? It means that a Rater could potentially only receive QA File reviews at a rate of one file or ten percent of the worst-case energy simulation files for a year. Then the next two years it could be nothing, or less than 10%, because hey, threshold specs didn't change and the jurisdiction hasn't accepted a new code. God forbid this goes in somewhere in Texas where they are still working on a 2006 IECC building code. I move to correct the language to close this potential gap. Proposed Change: 904.3.2.5.1 The QA File review for sampled ratings shall include a review of the greater of one (1) file or ten percent (10%) of the projected worst-case energy simulation files for each new sampled community in order to confirm that minimum rated features and worst-case specifications have been entered into the rating software accurately. Energy simulation files for an existing sampled community shall receive a QA File review, at a rate of one (1) file or ten percent (10%) of the worst-case energy simulation files, if the minimum rated features and/or threshold specifications change. Response: Accept
904.3.2.5.1 The QA File review for sampled ratings shall include a review of the greater of one (1) file or ten percent (10%) of the projected worst-case energy simulation files for each new sampled community in order to confirm that minimum rated features and worst-case specifications have been entered into the rating software accurately. Energy simulation files for an existing sampled community shall receive a QA File review, at a rate of one (1) file or ten percent (10%) of the worst-case energy simulation files, if the minimum rated features and/or threshold specifications change.
Here's why: the language of this standard should mirror a new sampled community, otherwise it leaves holes for errors. The reason is because this proposed standards says a lot with what isn't actually written in there.
Existing sampled communities will receive a QA File review...it the minimum rated features and/or threshold specifications change.
Let's set up an example: if a jurisdiction doesn't change the threshold specifications except when there's a new code, that means those numbers would change, at the minimum, of every three years (if they accept the new code). Furthermore, the builder and/or developer isn't changing the minimum rated features during those three years.
What does that mean?
It means that a Rater could potentially only receive QA File reviews at a rate of one file or ten percent of the worst-case energy simulation files for a year. Then the next two years it could be nothing, or less than 10%, because hey, threshold specs didn't change and the jurisdiction hasn't accepted a new code. God forbid this goes in somewhere in Texas where they are still working on a 2006 IECC building code.
I move to correct the language to close this potential gap.
Comment #215Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-6Paragraph / Figure / Table / Note: 904.3.3.1.1Comment Intent: ObjectionComment Type: EditorialComment: An explanation of rounding up is not necessary. If they can't grasp that, they shouldn't be able to become quality agents. Proposed Change: Strike and insert the following: 904.3.3.1.1904.4.2.1 HERS Raters. For each HERS Rater, the Provider’s Quality Assurance Contractor/Quality Agent Designee shall be responsible for an annual onsite QA fField review of the greater of one (1) rating on a completed home or one percent (1%) of the HERS Rater's annual total of homesratings for which Confirmed or Sampled ratings and diagnostic testing services were provided. When determining the number of QA fField reviews to complete for a HERS Rater, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 homesratings x 1% = 1.01 means that 2 QA fField reviews shall be completed. Response: Reject Reason: Additional language adds clarity
An explanation of rounding up is not necessary. If they can't grasp that, they shouldn't be able to become quality agents.
Strike and insert the following:
904.3.3.1.1904.4.2.1 HERS Raters. For each HERS Rater, the Provider’s Quality Assurance Contractor/Quality Agent Designee shall be responsible for an annual onsite QA fField review of the greater of one (1) rating on a completed home or one percent (1%) of the HERS Rater's annual total of homesratings for which Confirmed or Sampled ratings and diagnostic testing services were provided. When determining the number of QA fField reviews to complete for a HERS Rater, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 homesratings x 1% = 1.01 means that 2 QA fField reviews shall be completed.
Reason: Additional language adds clarity
Comment #216Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 28Paragraph / Figure / Table / Note: 904.3.3.1.1Comment Intent: ObjectionComment Type: TechnicalComment: This section does not take into consideration the fact that a rater performing this many ratings per year is prone to making mistakes that can impact hundreds of homes when QA levels are reduced. QA should be consistent and ongoing for all raters regardless of volume. Allowing this provision to remain undermines the intent of these changes which is to improve the quality and consistency of ratings, not to undermine the foundation. We propose striking this section. Proposed Change: 904.3.3.1.1.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the field QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated. Response: Accept Reason: Entire section will be removed
This section does not take into consideration the fact that a rater performing this many ratings per year is prone to making mistakes that can impact hundreds of homes when QA levels are reduced. QA should be consistent and ongoing for all raters regardless of volume. Allowing this provision to remain undermines the intent of these changes which is to improve the quality and consistency of ratings, not to undermine the foundation. We propose striking this section.
Comment #217Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 28Paragraph / Figure / Table / Note: 904.3.3.1.1.1Comment Intent: ObjectionComment Type: GeneralComment: I take an issue with the following language: 904.3.3.1.1.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the field QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated. Three reasons: 1) This is incredibly biased towards large rating companies, and it goes directly against holding everyone accountable to the same level. It shouldn't matter how many ratings someone does- they still run the same risk of messing up or lying. Doing more in this case just means they have an easier chance to skip out on having their files reviewed. 2) This proposed language would have a huge affect on rating companies that do mostly sampling. Literally, it's right there in the first line, "...who conduct over 500 confirmed ratings..." If you're mostly doing sampling you're going to be hit at a higher rate for QA reviews than someone doing the bare minimum of 500 confirmed ratings. 3) How is less oversight better? There isn't any sort of net that would make up the lack of field reviews right now. Unless we dramatically shifted to letting computers do what they do and review all the files for issues, there's no sort of net to catch the problems that occur from a lack of field reviews. Less oversight is a huge issue, especially when RESNET is in the process of enhancing the consistency of HERS ratings nationwide. I move to completely strike the language from the proposed standards. Proposed Change: 904.3.3.1.1.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the field QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated. Response: Accept Reason: Entire section will be removed
I take an issue with the following language:
Three reasons:
3) How is less oversight better? There isn't any sort of net that would make up the lack of field reviews right now. Unless we dramatically shifted to letting computers do what they do and review all the files for issues, there's no sort of net to catch the problems that occur from a lack of field reviews. Less oversight is a huge issue, especially when RESNET is in the process of enhancing the consistency of HERS ratings nationwide.
Comment #218Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 28Paragraph / Figure / Table / Note: 904.3.3.1.1.1Comment Intent: ObjectionComment Type: TechnicalComment: Based on my Field QA experience with large volume raters, this is unreachable, however I think the intent is good. I think it should be changed to 1 year period to make it more obtainable. I also believe some clarification is necessary for "reduced by 25% and 50%." Does this mean that the number of field reviews goes from 1% to .75%? and from 1% to 0.5% respectively? Proposed Change: 904.3.3.1.1.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a one (1) two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review shall be reduced by 25% or 0.75% of the annual total. If no errors are found in the subsequent two (2) years then the field QA reviews shall be reduced by 50% in the following years or to 0.5% of the annual total. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated. Response: Reject Reason: Entire section will be removed
Based on my Field QA experience with large volume raters, this is unreachable, however I think the intent is good. I think it should be changed to 1 year period to make it more obtainable.
I also believe some clarification is necessary for "reduced by 25% and 50%." Does this mean that the number of field reviews goes from 1% to .75%? and from 1% to 0.5% respectively?
904.3.3.1.1.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a one (1) two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review shall be reduced by 25% or 0.75% of the annual total. If no errors are found in the subsequent two (2) years then the field QA reviews shall be reduced by 50% in the following years or to 0.5% of the annual total. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated.
Comment #219Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-6Paragraph / Figure / Table / Note: 904.3.3.1.1.1Comment Intent: ObjectionComment Type: TechnicalComment: RESNET has always allowed Providers to have more strict and frequent reviews than the minimums established in these standards. The use of the word, "shall" removes that ability. Proposed Change: 904.3.3.1.1.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review may shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the field QA reviews may shall be reduced by 50% in the following years. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated. Response: Reject Reason: Entire section will be removed
RESNET has always allowed Providers to have more strict and frequent reviews than the minimums established in these standards. The use of the word, "shall" removes that ability.
904.3.3.1.1.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review may shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the field QA reviews may shall be reduced by 50% in the following years. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated.
Comment #220Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 28Paragraph / Figure / Table / Note: 904.3.3.1.1.1Comment Intent: ObjectionComment Type: GeneralComment: QA is QA and should be performed on Raters regardless of their volume. This large Rater bias is yet another industry barrier to the small volume raters. For years we have said that QA is the price of doing business for the small Rater and in the same was it should just be the cost of doing business for the large volume Rater. It is difficult to see how our current QA levels are statistically sound. Good work is good work and the market will reward those that do good work. It is RESNET’s job to ensure that the quality of each Rating is maintained. This goes in the opposite direction. Proposed Change: 904.3.3.1.1.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the field QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated. Response: Accept Reason: Entire section will be removed
QA is QA and should be performed on Raters regardless of their volume. This large Rater bias is yet another industry barrier to the small volume raters. For years we have said that QA is the price of doing business for the small Rater and in the same was it should just be the cost of doing business for the large volume Rater. It is difficult to see how our current QA levels are statistically sound. Good work is good work and the market will reward those that do good work. It is RESNET’s job to ensure that the quality of each Rating is maintained. This goes in the opposite direction.
Comment #221Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 28Paragraph / Figure / Table / Note: 904.3.3.1.1.1Comment Intent: ObjectionComment Type: GeneralComment: 904.3.3.1.1.1 strike out the entire thing as this is biased toward a rater that produces an arbitrary number of ratings. Proposed Change: 904.3.3.1.1.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the field QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated. Response: Accept Reason: Entire section will be removed
904.3.3.1.1.1
strike out the entire thing as this is biased toward a rater that produces an arbitrary number of ratings.
Comment #222Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-6Paragraph / Figure / Table / Note: 904.3.3.1.1.1Comment Intent: ObjectionComment Type: TechnicalComment: High-volume Raters should not be awarded lower QA rates since they have increased exposure in the marketplace. Proposed Change: 904.3.3.1.1.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 on field QA reviews, their quality field QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the field QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 1% field QA review threshold will be reinstated. Response: Accept Reason: Entire section will be removed
High-volume Raters should not be awarded lower QA rates since they have increased exposure in the marketplace.
Comment #223Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 29Paragraph / Figure / Table / Note: 904.3.3.1.2Comment Intent: ObjectionComment Type: GeneralComment: I take issue with the following highlighted language: 904.3.3.1.2 Rating Field Inspectors. For HERS Raters utilizing RFI’s, the Quality Agent shall ensure that a QA Field review is completed on the greater of one (1) rating on a completed home or one percent (1%) of each RFI’s annual total of confirmed or sampled ratings the RFI assisted with. If an RFI conducts a test or an inspection of any minimum rated feature on a rated home, that home is counted in the “annual total” of ratings used for the 1% calculation for that RFI. When determining the number of QA Field reviews to complete for an RFI, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 ratings x 1% = 1.01 means that 2 QA Field reviews shall be completed. The RFI QA Field reviews may fulfill all or a portion of the HERS Rater’s annual QA Field review requirement. This language could become incredibly overbearing in a multitude of ways. If a Rating Field Inspector does a duct blaster test at a pre-drywall inspection for every home at a rating company that does 5000 homes, you’d have to do 50 field QAs split among the RFIs of that rating company. Then a Rater does the final- well dang. You're doubling up their Field QA requirements! Additionally, one could misconstrue this to include any sort of energy audit for a code official or utility program, which is outside the purview of RESNET and QA Providers. No need to stick our noses where they shouldn't belong. This language should be completely struck because of the overbearing consequences that could occur. Proposed Change: 904.3.3.1.2 Rating Field Inspectors. For HERS Raters utilizing RFI’s, the Quality Agent shall ensure that a QA Field review is completed on the greater of one (1) rating on a completed home or one percent (1%) of each RFI’s annual total of confirmed or sampled ratings the RFI assisted with. If an RFI conducts a test or an inspection of any minimum rated feature on a rated home, that home is counted in the “annual total” of ratings used for the 1% calculation for that RFI. When determining the number of QA Field reviews to complete for an RFI, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 ratings x 1% = 1.01 means that 2 QA Field reviews shall be completed. The RFI QA Field reviews may fulfill all or a portion of the HERS Rater’s annual QAField review requirement. Response: Reject Reason: Each RFI should have their own field QA reviews
I take issue with the following highlighted language:
904.3.3.1.2 Rating Field Inspectors. For HERS Raters utilizing RFI’s, the Quality Agent shall ensure that a QA Field review is completed on the greater of one (1) rating on a completed home or one percent (1%) of each RFI’s annual total of confirmed or sampled ratings the RFI assisted with. If an RFI conducts a test or an inspection of any minimum rated feature on a rated home, that home is counted in the “annual total” of ratings used for the 1% calculation for that RFI. When determining the number of QA Field reviews to complete for an RFI, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 ratings x 1% = 1.01 means that 2 QA Field reviews shall be completed. The RFI QA Field reviews may fulfill all or a portion of the HERS Rater’s annual QA Field review requirement.
This language could become incredibly overbearing in a multitude of ways.
If a Rating Field Inspector does a duct blaster test at a pre-drywall inspection for every home at a rating company that does 5000 homes, you’d have to do 50 field QAs split among the RFIs of that rating company. Then a Rater does the final- well dang. You're doubling up their Field QA requirements!
Additionally, one could misconstrue this to include any sort of energy audit for a code official or utility program, which is outside the purview of RESNET and QA Providers. No need to stick our noses where they shouldn't belong.
This language should be completely struck because of the overbearing consequences that could occur.
904.3.3.1.2 Rating Field Inspectors. For HERS Raters utilizing RFI’s, the Quality Agent shall ensure that a QA Field review is completed on the greater of one (1) rating on a completed home or one percent (1%) of each RFI’s annual total of confirmed or sampled ratings the RFI assisted with. If an RFI conducts a test or an inspection of any minimum rated feature on a rated home, that home is counted in the “annual total” of ratings used for the 1% calculation for that RFI. When determining the number of QA Field reviews to complete for an RFI, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 ratings x 1% = 1.01 means that 2 QA Field reviews shall be completed. The RFI QA Field reviews may fulfill all or a portion of the HERS Rater’s annual QAField review requirement.
Reason: Each RFI should have their own field QA reviews
Comment #224Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 29Paragraph / Figure / Table / Note: 904.3.3.1.2Comment Intent: ObjectionComment Type: TechnicalComment: The proposed addition of "If an RFI conducts a test or an inspection of any minimum rated feature on a rated home, that home is counted in the 'annual total' of ratings used for the 1% calculation for that RFI" will have unintended consquences. To properly achieve the intent of this proposed change will require more complicated language than has been proposed. To keep the language of the Standards as simple as possible, RESNET shoudl craft an implenetation policy outside of the Standards. Proposed Change: 904.3.3.1.2904.4.2.2 QA field reviews for Rating Field Inspectors(RFIs). For HERS Raters utilizing Rating Field Inspectors (RFI’s), the QAQuality Agent Designee shall ensure that a QA fField review is completed on the greater of one (1) rating on a completed home or one percent (1%) of each RFI’s annual total of homes for which confirmed or sampled ratings and diagnostic testing services were provided by the RFI assisted with. If an RFI conducts a test or an inspection of any minimum rated feature on a rated home, that home is counted in the “annual total” of ratings used for the 1% calculation for that RFI. When determining the number of QA Field reviews to complete for an RFI, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 ratings x 1% = 1.01 means that 2 QA Field reviews shall be completed. The RFI QA fField reviews may fulfill all or a portion of the HERS Rater’s annual QA fField review requirement. Response: Accept
The proposed addition of "If an RFI conducts a test or an inspection of any minimum rated feature on a rated home, that home is counted in the 'annual total' of ratings used for the 1% calculation for that RFI" will have unintended consquences. To properly achieve the intent of this proposed change will require more complicated language than has been proposed. To keep the language of the Standards as simple as possible, RESNET shoudl craft an implenetation policy outside of the Standards.
904.3.3.1.2904.4.2.2 QA field reviews for Rating Field Inspectors(RFIs). For HERS Raters utilizing Rating Field Inspectors (RFI’s), the QAQuality Agent Designee shall ensure that a QA fField review is completed on the greater of one (1) rating on a completed home or one percent (1%) of each RFI’s annual total of homes for which confirmed or sampled ratings and diagnostic testing services were provided by the RFI assisted with. If an RFI conducts a test or an inspection of any minimum rated feature on a rated home, that home is counted in the “annual total” of ratings used for the 1% calculation for that RFI. When determining the number of QA Field reviews to complete for an RFI, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 ratings x 1% = 1.01 means that 2 QA Field reviews shall be completed. The RFI QA fField reviews may fulfill all or a portion of the HERS Rater’s annual QA fField review requirement.
Comment #225Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.2Comment Intent: ObjectionComment Type: GeneralComment: Raters are required to oversee the work of the Rating Field Inspectors. It is the Rater's responsibility, therefore, to ensure the Rating Field Inspector is performing work according to the requirements of the Standards. It is NOT the responsibility of the Quality Assurance Provider to perform Quality Management on RFIs, particularly since there is NO requirement for a contractual relationship between QA Providers and RFIs under these Standards. This creates an unenforceable provision in the Standards and an impossible compliance burden for Quality Assurance Providers. Proposed Change: Strike the following in its entirety: 904.3.3.1.2904.4.2.2 QA field reviews for Rating Field Inspectors(RFIs). For HERS Raters utilizing Rating Field Inspectors (RFI’s), the QAQuality Agent Designee shall ensure that a QA fField review is completed on the greater of one (1) rating on a completed home or one percent (1%) of each RFI’s annual total of homes for which confirmed or sampled ratings and diagnostic testing services were provided by the RFI assisted with. If an RFI conducts a test or an inspection of any minimum rated feature on a rated home, that home is counted in the “annual total” of ratings used for the 1% calculation for that RFI. When determining the number of QA Field reviews to complete for an RFI, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 ratings x 1% = 1.01 means that 2 QA Field reviews shall be completed. The RFI QA fField reviews may fulfill all or a portion of the HERS Rater’s annual QA fField review requirement. Do NOT replace. Response: Reject Reason: Each RFI should have their own field QA reviews
Raters are required to oversee the work of the Rating Field Inspectors. It is the Rater's responsibility, therefore, to ensure the Rating Field Inspector is performing work according to the requirements of the Standards. It is NOT the responsibility of the Quality Assurance Provider to perform Quality Management on RFIs, particularly since there is NO requirement for a contractual relationship between QA Providers and RFIs under these Standards. This creates an unenforceable provision in the Standards and an impossible compliance burden for Quality Assurance Providers.
Comment #226Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 29Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: GeneralComment: I take issue with the following highlighted text: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up). For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review shall be on a completed home and one (1) additional QA Field review shall be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field review is required and shall count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviews are required and they shall count towards two, but no more than two, of the QA Field reviews. I won't get into the interpretation of this standard yet, but I would like to comment on the highlighted text. This could be a huge sinkhole for QA oversight. I like that the proposal is opening up Pre-drywall inspections for QA Field reviews, but I'm very hesitant about requiring it. I think it'd take too much time from the Quality Agent and HERS Rater or RFI. A much better solution would be to have Pre-drywall inspections optional. Say I need to get a field review in on an RFI, but they only have pre-drywall inspections scheduled. Instead of making the Rating company shift their schedule around, I can now go do that pre-drywall. On the flip side, if it's required, you're much more likely to use up the 10% maximum and what happens when you need to do one more field review because the company did just over how many they thought they would, and you have to do the field review on that RFI but they're only scheduled for finals? Yeah, now you have to step into their business and make them suit your needs. I'd much rather not have to screw around with someone else's business. Simply put: change the language to make it optional, and you've got a great solution to many QA problems. Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent may perform shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews can shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and can shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up). For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review can shall be on a completed home and one (1) additional QA Field review can shall be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field review may be performed is required and can shall count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviewsmay be performed are required and they can shall count towards two, but no more than two, of the QA Field reviews. Response: Accept Reason: Reasonable and allows QA agent to have flexibility
904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up).
For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review shall be on a completed home and one (1) additional QA Field review shall be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field review is required and shall count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviews are required and they shall count towards two, but no more than two, of the QA Field reviews.
I won't get into the interpretation of this standard yet, but I would like to comment on the highlighted text.
This could be a huge sinkhole for QA oversight. I like that the proposal is opening up Pre-drywall inspections for QA Field reviews, but I'm very hesitant about requiring it. I think it'd take too much time from the Quality Agent and HERS Rater or RFI.
A much better solution would be to have Pre-drywall inspections optional. Say I need to get a field review in on an RFI, but they only have pre-drywall inspections scheduled. Instead of making the Rating company shift their schedule around, I can now go do that pre-drywall.
On the flip side, if it's required, you're much more likely to use up the 10% maximum and what happens when you need to do one more field review because the company did just over how many they thought they would, and you have to do the field review on that RFI but they're only scheduled for finals? Yeah, now you have to step into their business and make them suit your needs. I'd much rather not have to screw around with someone else's business.
Simply put: change the language to make it optional, and you've got a great solution to many QA problems.
904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent may perform shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews can shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and can shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up).
For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review can shall be on a completed home and one (1) additional QA Field review can shall be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field review may be performed is required and can shall count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviewsmay be performed are required and they can shall count towards two, but no more than two, of the QA Field reviews.
Reason: Reasonable and allows QA agent to have flexibility
Comment #227Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: GeneralComment: It is my opinion that this will not increase the accuracy of the rated home. The quality of the preinspection is trumped by the actual measurements of air leakage. Quality of insulation installation is easily verified by infra red camera if thermal performance is questioned. Furthermore the delays to the home builder could be an issue if they have to wait for this separate inspection from a QA provider. They have to wait for the HERS rater to make this inspection pursuant to the Standard. Proposed Change: delte the entire concept from the standard Response: Reject Reason: Pre-drywall QA is an important part of the QA process.
It is my opinion that this will not increase the accuracy of the rated home. The quality of the preinspection is trumped by the actual measurements of air leakage. Quality of insulation installation is easily verified by infra red camera if thermal performance is questioned.
Furthermore the delays to the home builder could be an issue if they have to wait for this separate inspection from a QA provider.
They have to wait for the HERS rater to make this inspection pursuant to the Standard.
delte the entire concept from the standard
Reason: Pre-drywall QA is an important part of the QA process.
Comment #228Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 29Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: EditorialComment: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up). There is a large portion of the minimum rated features that either can or needs to be verified during pre-drywall, so it seems logical that the percentage range should reflect that ratio more accurately. The outcome of the final inspection is fairly reliant on how well the pre-drywall inspection is conducted, and is much more significant than this section describes. Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10% 50%, of the total number of QA Field reviews (rounded up) Change the high end of the range to 50% to allow for a proportional number of pre-drywall QA’s relative to the ratio of the minimum rated features that can or should be verified at pre-drywall. Response: Reject Reason: 50% is too stringent of a requirement for the standard
There is a large portion of the minimum rated features that either can or needs to be verified during pre-drywall, so it seems logical that the percentage range should reflect that ratio more accurately. The outcome of the final inspection is fairly reliant on how well the pre-drywall inspection is conducted, and is much more significant than this section describes.
904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10% 50%, of the total number of QA Field reviews (rounded up)
Change the high end of the range to 50% to allow for a proportional number of pre-drywall QA’s relative to the ratio of the minimum rated features that can or should be verified at pre-drywall.
Reason: 50% is too stringent of a requirement for the standard
Comment #229Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: GeneralComment: Adding pre drywall field QAs is going to incur a significant cost increase to raters due to added trips and more time spent on Field QAs. This will in turn force raters to raise prices to compensate. All I am saying is a hard look at the cost/benefit ratio needs to be looked at because the only time I really think this matters over all is if some one is giving grade 1 to insulation in walls and other enclosed spaces that cant be visually inspected normally. Proposed Change: Possibly drop the pre drywall inspection. Response: Reject Reason: Pre-drywall QA is an important part of the QA process. Revised section from “shall” to “can” per comment number #225
Adding pre drywall field QAs is going to incur a significant cost increase to raters due to added trips and more time spent on Field QAs. This will in turn force raters to raise prices to compensate. All I am saying is a hard look at the cost/benefit ratio needs to be looked at because the only time I really think this matters over all is if some one is giving grade 1 to insulation in walls and other enclosed spaces that cant be visually inspected normally.
Possibly drop the pre drywall inspection.
Reason: Pre-drywall QA is an important part of the QA process. Revised section from “shall” to “can” per comment number #225
Comment #230Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 34Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: EditorialComment: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up). There is a large portion of the minimum rated features that either can or needs to be verified during pre-drywall, so it seems logical that the percentage range should reflect that ratio more accurately. The outcome of the final inspection is fairly reliant on how well the pre-drywall inspection is conducted, and is much more significant than this section describes. Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10% 50%, of the total number of QA Field reviews (rounded up) Change the high end of the range to 50% to allow for a proportional number of pre-drywall QA’s relative to the ratio of the minimum rated features that can or should be verified at pre-drywall. Response: Reject Reason: 50% is too stringent of a requirement for the standard.
Reason: 50% is too stringent of a requirement for the standard.
Comment #231Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: EditorialComment: Allowing only 10% of QA to be conducted at Rough is far too limited. At a quick glance 6 to 7 of the 24 minimum rated features for a HERS Rated Home would be verified at Rough (depending on when you prefer to conduct duct testing). If approximately 25% to 30% of minimum rated features are collected at Rough then why would be allow only 10% of homes to be QA'ed at Rough. In Rough QA is vital to the quality and consistency of Ratings (and I believe it is) then it should be QA'ed at a higher rate than 10%. Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10% 25%, but no more than 10% 25%, of the total number of QA Field reviews (rounded up). For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review shall be on a completed home and one (1) additional QA Field review shall be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) four (4) QA Field reviews, one (1) pre-drywall QA Field review is required and shall count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more five (5) to eight (8) QA Field reviews, two (2) pre-drywall QA Field reviews are required and they shall count towards two, but no more than two, of the QA Field reviews,and so on. Response: Accept Reason: Accept in principle. Accepting only the change from 10% to (no more than) 25% which allows the QA Agent more flexibility
Allowing only 10% of QA to be conducted at Rough is far too limited. At a quick glance 6 to 7 of the 24 minimum rated features for a HERS Rated Home would be verified at Rough (depending on when you prefer to conduct duct testing). If approximately 25% to 30% of minimum rated features are collected at Rough then why would be allow only 10% of homes to be QA'ed at Rough. In Rough QA is vital to the quality and consistency of Ratings (and I believe it is) then it should be QA'ed at a higher rate than 10%.
904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10% 25%, but no more than 10% 25%, of the total number of QA Field reviews (rounded up).
For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review shall be on a completed home and one (1) additional QA Field review shall be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) four (4) QA Field reviews, one (1) pre-drywall QA Field review is required and shall count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more five (5) to eight (8) QA Field reviews, two (2) pre-drywall QA Field reviews are required and they shall count towards two, but no more than two, of the QA Field reviews,and so on.
Reason: Accept in principle. Accepting only the change from 10% to (no more than) 25% which allows the QA Agent more flexibility
Comment #232Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: GeneralComment: Mulitple Pre-drywall QA Field Inspections are aggregious and difficult to coordinate with construction schedules. An alternative is offered in the proposed language. Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on for completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on for completed homes., and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up). For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review shall be on a completed home and one (1) additional QA Field review shall be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field review is required and shall count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviews are required and they shall count towards two, but no more than two, of the QA Field reviews. Pre-drywall QA Field reviews shall be limited to one per year per HERs Rater and RFI. The Pre-drywall QA Field Review shall be used and be counted as towards the 1% QA Field review requirement as noted above. For example: If a HERs Rater or RFI is required to have one (1) Field Review, one (1) QA Field review shall be on a completed home and one (1) review shall be a Pre-drywall QA Field Review. If a HERs Rater or RFI is required to have multiple QA Field Reviews based upon the number of homes uploaded to the RESNET Registry in one calaender year, then at least one (1) and no more than one (1) Pre-drywall QA Field Review shall be conducted. The Pre-drywall QA Field review shall then be counted towards the total of all QA Field Reviews for the annual total for that HERs Rater or RFI. In the event that the QA Agent is unable to coordinate a Pre-drywall QA Field Review within the allotted schedule for construction of the home, sufficient photo documentation of the Pre-drywall inspection shall be permitted in lieu of the on-site Pre-drywall QA Field review and be considered a “virtual” QA Field Review. Such photo documentation shall include: Time and Date of HERs Rater or RFI field Visit Name of the Builder Project Address Photo of the home’s exterior Representative photo documentation of each insulation type within the home to include at least one exterior wall per floor including basements, conditioned spaces and attics. Representative photos of insualted floors and attics shall be included. Response: Accept Reason: Accept in principle. Revised section from “shall” to “can” per comment number #225
Mulitple Pre-drywall QA Field Inspections are aggregious and difficult to coordinate with construction schedules. An alternative is offered in the proposed language.
904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on for completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on for completed homes., and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up). For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review shall be on a completed home and one (1) additional QA Field review shall be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field review is required and shall count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviews are required and they shall count towards two, but no more than two, of the QA Field reviews.
Pre-drywall QA Field reviews shall be limited to one per year per HERs Rater and RFI. The Pre-drywall QA Field Review shall be used and be counted as towards the 1% QA Field review requirement as noted above. For example: If a HERs Rater or RFI is required to have one (1) Field Review, one (1) QA Field review shall be on a completed home and one (1) review shall be a Pre-drywall QA Field Review. If a HERs Rater or RFI is required to have multiple QA Field Reviews based upon the number of homes uploaded to the RESNET Registry in one calaender year, then at least one (1) and no more than one (1) Pre-drywall QA Field Review shall be conducted. The Pre-drywall QA Field review shall then be counted towards the total of all QA Field Reviews for the annual total for that HERs Rater or RFI.
In the event that the QA Agent is unable to coordinate a Pre-drywall QA Field Review within the allotted schedule for construction of the home, sufficient photo documentation of the Pre-drywall inspection shall be permitted in lieu of the on-site Pre-drywall QA Field review and be considered a “virtual” QA Field Review. Such photo documentation shall include:
Time and Date of HERs Rater or RFI field Visit
Name of the Builder
Project Address
Photo of the home’s exterior
Representative photo documentation of each insulation type within the home to include at least one exterior wall per floor including basements, conditioned spaces and attics. Representative photos of insualted floors and attics shall be included.
Reason: Accept in principle. Revised section from “shall” to “can” per comment number #225
Comment #233Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 29Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: TechnicalComment: This is essentially doubling the amount of QA required, for low volume raters (<100 ratings/year). However, I agree with the intent, that pre-drywall QA is important to start including in the Field QA process for RESNET. The edits below would meet the intent of implementing predrywall QA, without burdening low volume raters. Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI, if more than one (1) Field review is required annually for a HERS Rater or RFI . Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up). For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review shall be on a completed home and one (1) additional QA Field review shall be on the same or a different home before drywall is installed.If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field review is required and shall count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviews are required and they shall count towards two, but no more than two, of the QA Field reviews. 904.3.3.1.4 RFIs are exempt from receiving a QA field review for pre-drywall or final inspections and/or testing if they have not performed inspections and/or testing of any minimum rated features for pre-drywall or completed homes within the calendar year. For example, if a HERS Rater of RFI have not completed any pre-drywall inspections within the calendar year, they are exempt from QA Field reviews for pre-drywall inspections. 904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed if more than one (1) Field review is required annually for a HERS Rater or RFI. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtual” QA Field review methodology specified by RESNET. Response: Accept Reason: Accept in principle. Revised section from “shall” to “can” per comment number #225
This is essentially doubling the amount of QA required, for low volume raters (<100 ratings/year). However, I agree with the intent, that pre-drywall QA is important to start including in the Field QA process for RESNET. The edits below would meet the intent of implementing predrywall QA, without burdening low volume raters.
904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI, if more than one (1) Field review is required annually for a HERS Rater or RFI . Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up).
For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review shall be on a completed home and one (1) additional QA Field review shall be on the same or a different home before drywall is installed.If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field review is required and shall count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviews are required and they shall count towards two, but no more than two, of the QA Field reviews.
904.3.3.1.4 RFIs are exempt from receiving a QA field review for pre-drywall or final inspections and/or testing if they have not performed inspections and/or testing of any minimum rated features for pre-drywall or completed homes within the calendar year. For example, if a HERS Rater of RFI have not completed any pre-drywall inspections within the calendar year, they are exempt from QA Field reviews for pre-drywall inspections.
904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed if more than one (1) Field review is required annually for a HERS Rater or RFI. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtual” QA Field review methodology specified by RESNET.
Comment #234Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: Not an ObjectionComment Type: GeneralComment: I agree that TBI Field QA's should be done. However, there is nothing in the Standards to completely define this type of inspection and there is nothing in RESNET's HERS Rater Training Curriculum to teach raters how to do this inpection. Additional information needs to be specified about this type of inspection before we make the QA of it a standard. Proposed Change: N/A Just an observation Response: Accept Reason: Accept in principle. Revised section from “shall” to “can” per comment number #225
I agree that TBI Field QA's should be done. However, there is nothing in the Standards to completely define this type of inspection and there is nothing in RESNET's HERS Rater Training Curriculum to teach raters how to do this inpection.
Additional information needs to be specified about this type of inspection before we make the QA of it a standard.
N/A Just an observation
Comment #235Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: Not an ObjectionComment Type: GeneralComment: This section looks, at first glance, to double QA costs for small raters and marginally increase costs for mid to large ones. Proposed Change: N/A Just an observation Response: Accept Reason: Accept in principle. Revised section from “shall” to “can” per comment number #225
This section looks, at first glance, to double QA costs for small raters and marginally increase costs for mid to large ones.
Comment #236Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: TechnicalComment: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on for completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on for completed homes., and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up). For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review shall be on a completed home and one (1) additional QA Field review shall be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field review is required and shall count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviews are required and they shall count towards two, but no more than two, of the QA Field reviews. Proposed Change: Pre-drywall QA Field reviews shall be limited to one per year per HERs Rater and RFI. The Pre-drywall QA Field Review shall be used and be counted as towards the 1% QA Field review requirement as noted above. For example: If a HERs Rater or RFI is required to have one (1) Field Review, one (1) QA Field review shall be on a completed home or one (1) review shall be a Pre-drywall QA Field Review. If a HERs Rater or RFI is required to have multiple QA Field Reviews based upon the number of homes uploaded to the RESNET Registry in one calendar year, then at least one (1) and no more than one (1) Pre-drywall QA Field Review shall be conducted. The Pre-drywall QA Field review shall then be counted towards the total of all QA Field Reviews for the annual total for that HERs Rater or RFI. Response: Accept Reason: Accept in principle. Revised section from “shall” to “can” per comment number #225
Pre-drywall QA Field reviews shall be limited to one per year per HERs Rater and RFI. The Pre-drywall QA Field Review shall be used and be counted as towards the 1% QA Field review requirement as noted above. For example: If a HERs Rater or RFI is required to have one (1) Field Review, one (1) QA Field review shall be on a completed home or one (1) review shall be a Pre-drywall QA Field Review. If a HERs Rater or RFI is required to have multiple QA Field Reviews based upon the number of homes uploaded to the RESNET Registry in one calendar year, then at least one (1) and no more than one (1) Pre-drywall QA Field Review shall be conducted. The Pre-drywall QA Field review shall then be counted towards the total of all QA Field Reviews for the annual total for that HERs Rater or RFI.
Comment #237Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: EditorialComment: It is my opinion that RESNET should allow pre-drywall QA Field Reviews to account for more of the total number of QA Field reviews, as 25% to 30% of minimum rated features are inspected at Rough. Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10% 20%, but no more than 10% 50%, of the total number of QA Field reviews (rounded up) Response: Reject Reason: 50% is too stringent of a requirement for the standard.
It is my opinion that RESNET should allow pre-drywall QA Field Reviews to account for more of the total number of QA Field reviews, as 25% to 30% of minimum rated features are inspected at Rough.
904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10% 20%, but no more than 10% 50%, of the total number of QA Field reviews (rounded up)
Comment #238Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 29Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: TechnicalComment: 904.3.3.1.3 Pre-drywall QA Field reviews A one size fits all approach to this type of QA is going to be very challenging and burdensome, especially to lower volume raters and the QA agents that have to schedule this QA event. Also, this technical language of this section is somewhat difficult to follow. We would like to propose an approach that accomodates raters of all sizes, and is easier to comprehend. Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up). For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review shall be on a completed home and one (1) additional QA Field review shall be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field review is required and shall count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviews are required and they shall count towards two, but no more than two, of the QA Field reviews. 903.3.3.1.3.1 For raters who complete ratings on less than 100 homes per year, at least one Pre-drywall QA Field review shall be completed every three years. The Pre-drywall QA shall not count towards the total annual required QA Field review on completed homes. 903.3.3.1.3.2 For raters who complete ratings on more than 100 homes per year, at least one Pre-drywall QA field review shall be completed annually. The Pre-drywall QA shall count towards one out of each ten of the total required QA Field review on completed homes. 903.3.3.1.3.3 For raters who complete ratings on more than 1,000 homes per year, at least two Pre-drywall QA field reviews shall be completed annually. The Pre-drywall QA shall count towards one out of each ten of the total required QA Field review on completed homes. Response: Reject Reason: Revised this section from “shall” to “can” giving the QA agent flexibility to increase as justified. Percentages should be based on the individual not on the size of the rating company.
904.3.3.1.3 Pre-drywall QA Field reviews
A one size fits all approach to this type of QA is going to be very challenging and burdensome, especially to lower volume raters and the QA agents that have to schedule this QA event. Also, this technical language of this section is somewhat difficult to follow. We would like to propose an approach that accomodates raters of all sizes, and is easier to comprehend.
903.3.3.1.3.1 For raters who complete ratings on less than 100 homes per year, at least one Pre-drywall QA Field review shall be completed every three years. The Pre-drywall QA shall not count towards the total annual required QA Field review on completed homes.
903.3.3.1.3.2 For raters who complete ratings on more than 100 homes per year, at least one Pre-drywall QA field review shall be completed annually. The Pre-drywall QA shall count towards one out of each ten of the total required QA Field review on completed homes.
903.3.3.1.3.3 For raters who complete ratings on more than 1,000 homes per year, at least two Pre-drywall QA field reviews shall be completed annually. The Pre-drywall QA shall count towards one out of each ten of the total required QA Field review on completed homes.
Reason: Revised this section from “shall” to “can” giving the QA agent flexibility to increase as justified. Percentages should be based on the individual not on the size of the rating company.
Comment #239Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 29Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: Not an ObjectionComment Type: TechnicalComment: There are situations when a home is inspected during the rating process, but the rating is never confirmed. If pre-drywall field QA is performed, it should still be counted towards the rater's annual pre-drywall field QA requirements. Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up). In the event the rating is not confirmed, the pre-drywall field QA shall count as meeting this requirement. Response: Reject Reason: Logistics of tracking this would be difficult
There are situations when a home is inspected during the rating process, but the rating is never confirmed. If pre-drywall field QA is performed, it should still be counted towards the rater's annual pre-drywall field QA requirements.
904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or RFI. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up). In the event the rating is not confirmed, the pre-drywall field QA shall count as meeting this requirement.
Reason: Logistics of tracking this would be difficult
Comment #240Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 29Paragraph / Figure / Table / Note: 904.3.3.1.4Comment Intent: ObjectionComment Type: GeneralComment: I think the following highlighted standard should be completely struck, as Pre-drywall inspections should be optional, rather than required. 904.3.3.1.4 RFIs are exempt from receiving a QA field review for pre-drywall or final inspections and/or testing if they have not performed inspections and/or testing of any minimum rated features for pre-drywall or completed homes within the calendar year. For example, if a HERS Rater of RFI have not completed any pre-drywall inspections within the calendar year, they are exempt from QA Field reviews for pre-drywall inspections. Proposed Change: 904.3.3.1.4 RFIs are exempt from receiving a QA field review for pre-drywall or final inspections and/or testing if they have not performed inspections and/or testing of any minimum rated features for pre-drywall or completed homes within the calendar year. For example, if a HERS Rater of RFI have not completed any pre-drywall inspections within the calendar year, they are exempt from QA Field reviews for pre-drywall inspections. Response: Accept Reason: Accept in principle. Changed this section from “shall” to “can” per comment #225
I think the following highlighted standard should be completely struck, as Pre-drywall inspections should be optional, rather than required.
Reason: Accept in principle. Changed this section from “shall” to “can” per comment #225
Comment #241Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.4Comment Intent: Not an ObjectionComment Type: GeneralComment: As written, this section appears to apply to HERS Raters and RFIs, but HERS Raters are not included in the first sentence. Proposed Change: 904.3.3.1.4 HERS Raters and RFIs are exempt from receiving a QA field review for pre-drywall or final inspections and/or testing if they have not performed inspections and/or testing of any minimum rated features for pre-drywall or completed homes within the calendar year. For example, if a HERS Rater of or RFI have not completed any pre-drywall inspections within the calendar year, they are exempt from QA Field reviews for pre-drywall inspections. Response: Accept Reason: addition of rater to this section is logical
As written, this section appears to apply to HERS Raters and RFIs, but HERS Raters are not included in the first sentence.
904.3.3.1.4 HERS Raters and RFIs are exempt from receiving a QA field review for pre-drywall or final inspections and/or testing if they have not performed inspections and/or testing of any minimum rated features for pre-drywall or completed homes within the calendar year. For example, if a HERS Rater of or RFI have not completed any pre-drywall inspections within the calendar year, they are exempt from QA Field reviews for pre-drywall inspections.
Reason: addition of rater to this section is logical
Comment #242Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.4Comment Intent: ObjectionComment Type: GeneralComment: This section is unnecessary since Raters are responsible for ensuring the work of the RFIs they oversee is compliant with the Standards. Proposed Change: Strike the following in its entirety: 904.3.3.1.4 RFIs are exempt from receiving a QA field review for pre-drywall or final inspections and/or testing if they have not performed inspections and/or testing of any minimum rated features for pre-drywall or completed homes within the calendar year. For example, if a HERS Rater of RFI have not completed any pre- drywall inspections within the calendar year, they are exempt from QA Field reviews for pre-drywall inspections. Do NOT replace. Response: Reject Reason: RFIs should be subject to QA reviews.
This section is unnecessary since Raters are responsible for ensuring the work of the RFIs they oversee is compliant with the Standards.
904.3.3.1.4 RFIs are exempt from receiving a QA field review for pre-drywall or final inspections and/or testing if they have not performed inspections and/or testing of any minimum rated features for pre-drywall or completed homes within the calendar year. For example, if a HERS Rater of RFI have not completed any pre- drywall inspections within the calendar year, they are exempt from QA Field reviews for pre-drywall inspections.
Reason: RFIs should be subject to QA reviews.
Comment #243Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.4Comment Intent: ObjectionComment Type: TechnicalComment: Creating an additional required field QA for low-volume raters who perform less than 100 ratings per year creates a major financial burden for them. Also, the math does not work. If a rater performs over 100 but under 200 ratings for the year, they are required to have one completed home field reviewed and one pre-drywall home field reviewed, but the pre-drywall home cannot count for more than 10% of the total number of QA Field reviews? In this case it is 50% and is allowed as stated in the second paragraph. I believe that pre-drywall Field QA is highly valuable and should be performed. However, I also believe, especially in the case of low-volume raters, that the Quality Agent working with that Rater is the best person to determine what type of field QA should be performed. If the Rater has not had a pre-drywall QA performed within a year, the Quality Agent will likely be performing one soon. I propose that the pre-drywall Field QA be required only if 2 or more Field QA reviews are required in a year or at a minimum every other year for low volume raters who only require one Field QA in a year. The number of required reviews increases if the rater is struggling, so it would then automatically follow that additional reviews of both types get performed. This really needs to be up to the Quality Agent working with the Rater rather than this attempt to cover all situations so generically. Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or and RFI every other year at a minimum. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up). For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review shall be on a completed home and one (1) additional QA Field review shall be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field review is required and shall count towards one, but no more than one, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviews are required and they shall count towards two, but no more than two, of the QA Field reviews. Response: Accept Reason: Accept in principle. Changed this section from “shall” to “can” per comment #225
Creating an additional required field QA for low-volume raters who perform less than 100 ratings per year creates a major financial burden for them. Also, the math does not work. If a rater performs over 100 but under 200 ratings for the year, they are required to have one completed home field reviewed and one pre-drywall home field reviewed, but the pre-drywall home cannot count for more than 10% of the total number of QA Field reviews? In this case it is 50% and is allowed as stated in the second paragraph. I believe that pre-drywall Field QA is highly valuable and should be performed. However, I also believe, especially in the case of low-volume raters, that the Quality Agent working with that Rater is the best person to determine what type of field QA should be performed. If the Rater has not had a pre-drywall QA performed within a year, the Quality Agent will likely be performing one soon. I propose that the pre-drywall Field QA be required only if 2 or more Field QA reviews are required in a year or at a minimum every other year for low volume raters who only require one Field QA in a year. The number of required reviews increases if the rater is struggling, so it would then automatically follow that additional reviews of both types get performed. This really needs to be up to the Quality Agent working with the Rater rather than this attempt to cover all situations so generically.
904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Agent shall ensure that a pre-drywall QA Field review is completed on a minimum of one (1) home for each HERS Rater or and RFI every other year at a minimum. Pre-drywall QA Field reviews shall be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shall replace 10%, but no more than 10%, of the total number of QA Field reviews (rounded up).
Comment #244Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.4Comment Intent: Not an ObjectionComment Type: EditorialComment: HERS Raters are listed in the example, but are absent from the standard language itself. Proposed Change: 904.3.3.1.4 HERS Raters and RFIs are exempt from receiving a QA field review for pre-drywall or final inspections and/or testing if they have not performed inspections and/or testing of any minimum rated features for pre-drywall or completed homes within the calendar year. For example, if a HERS Rater of RFI have not completed any predrywall inspections within the calendar year, they are exempt from QA Field reviews for pre-drywall inspections. Response: Accept Reason: addition of rater to this section is logical
HERS Raters are listed in the example, but are absent from the standard language itself.
904.3.3.1.4 HERS Raters and RFIs are exempt from receiving a QA field review for pre-drywall or final inspections and/or testing if they have not performed inspections and/or testing of any minimum rated features for pre-drywall or completed homes within the calendar year. For example, if a HERS Rater of RFI have not completed any predrywall inspections within the calendar year, they are exempt from QA Field reviews for pre-drywall inspections.
Comment #245Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 29-30Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: Not an ObjectionComment Type: EditorialComment: I have an issue with the highlighted text below: 904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtual” QA Field review methodology specified by RESNET. While I believe that Virtual QA would be extremely useful for any rater and Quality Agent, I think the language in this standard is confusing and needs clarification. Most of the confusion comes from the insertion of the pre-drywall QA field review stuff. If you drop it, things make a lot more sense. I move to reorganize the language of this proposed standard to what I have below: Proposed Change: 904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtual” QA Field review methodology specified by RESNET. Response: Accept Reason: logical change since pre-drywall QA reviews are not required.
I have an issue with the highlighted text below:
While I believe that Virtual QA would be extremely useful for any rater and Quality Agent, I think the language in this standard is confusing and needs clarification. Most of the confusion comes from the insertion of the pre-drywall QA field review stuff. If you drop it, things make a lot more sense.
I move to reorganize the language of this proposed standard to what I have below:
Reason: logical change since pre-drywall QA reviews are not required.
Comment #246Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-8Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: EditorialComment: I whole heartedly support Virtual QA as I believe it is the only way to successfully implement the new QA Standards for volume and/or remote HERS Raters. Furthermore I believe Virtual QA, when done well, is the equal in quality and stringency to on-site QA. If it is equal to on-site QA then it should be treated as equal and should not be limited in its application. If it is not equal, then it should not be implemented at all. Proposed Change: 904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtual” QA Field review methodology specified by RESNET. Response: Reject Reason: at least one on-site QA review should be required because of the value to the rater/RFI
I whole heartedly support Virtual QA as I believe it is the only way to successfully implement the new QA Standards for volume and/or remote HERS Raters. Furthermore I believe Virtual QA, when done well, is the equal in quality and stringency to on-site QA. If it is equal to on-site QA then it should be treated as equal and should not be limited in its application. If it is not equal, then it should not be implemented at all.
904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtual” QA Field review methodology specified by RESNET.
Reason: at least one on-site QA review should be required because of the value to the rater/RFI
Comment #247Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: GeneralComment: Propose adding photo documentation to the definition of "virtual" QA Field Inspection with a list of specific items to be captured on site. Proposed Change: 904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or Working Draft WD-02 Chapter Nine RESNET Standards 9-8 a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtual” QA Field review methodology specified by RESNET, including photo documentation detailed above in 904.3.3.1.3. Note: this references proposed changes to 904.3.3.1.3 included in Comment #116. Response: Reject Reason: Will be determined in the remote QA protocol
Propose adding photo documentation to the definition of "virtual" QA Field Inspection with a list of specific items to be captured on site.
904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or Working Draft WD-02 Chapter Nine RESNET Standards 9-8 a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtual” QA Field review methodology specified by RESNET, including photo documentation detailed above in 904.3.3.1.3.
Note: this references proposed changes to 904.3.3.1.3 included in Comment #116.
Reason: Will be determined in the remote QA protocol
Comment #248Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7-8Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: EditorialComment: This language conflates "virtual" with "remote". "Virtual" means being very close to being something without actually being it, while "remote" means separated by time and space. Additionally, this section contains permissive language that renders it unenforceable. Proposed Change: Strike the following in its entirety: 904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Fieldreviews must be completed on-site and in-person, the other may be "virtual". Allother QA Field reviews, for completed and pre-drywall homes, may be performedusing a “virtual” QA Field review methodology specified by RESNET. Do NOT replace. Once RESNET develops acceptable methodologies for remote quality management, an amendment must be proposed to add those provisions to the Standard. Until then, this is completely unenforceable. Response: Reject Reason: the remote QA protocol will be separate from but referenced in the standards. This allows the protocols to be edited when needed
This language conflates "virtual" with "remote". "Virtual" means being very close to being something without actually being it, while "remote" means separated by time and space.
Additionally, this section contains permissive language that renders it unenforceable.
904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Fieldreviews must be completed on-site and in-person, the other may be "virtual". Allother QA Field reviews, for completed and pre-drywall homes, may be performedusing a “virtual” QA Field review methodology specified by RESNET.
Do NOT replace. Once RESNET develops acceptable methodologies for remote quality management, an amendment must be proposed to add those provisions to the Standard. Until then, this is completely unenforceable.
Reason: the remote QA protocol will be separate from but referenced in the standards. This allows the protocols to be edited when needed
Comment #249Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: Not an ObjectionComment Type: EditorialComment: The term “Vitrual” as stated in section 904.3.3.1.5 and section 904.3.3.2.5 as “Vitrual QA Field reviews“ should be replaced with the term “Remote QA Field reviews“ Vitrual has the conation of simulated on a computer. This process is actually a remote process, implying the evaluation is taking place remotely. Proposed Change: As it appears in the Working Draft WD-02 904.3.3.1.5 “Virtual" “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual" “remote”. All other QA Field reviews, for completed and pre-drywall homes, may be performed using a "virtual" “Remote” QA Field review methodology specified by RESNET. 904.3.3.2.5 Virtual Remote QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET. Response: Accept
The term “Vitrual” as stated in section 904.3.3.1.5 and section 904.3.3.2.5 as “Vitrual QA Field reviews“ should be replaced with the term “Remote QA Field reviews“
Vitrual has the conation of simulated on a computer. This process is actually a remote process, implying the evaluation is taking place remotely.
As it appears in the Working Draft WD-02
904.3.3.1.5 “Virtual" “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual" “remote”. All other QA Field reviews, for completed and pre-drywall homes, may be performed using a "virtual" “Remote” QA Field review methodology specified by RESNET.
904.3.3.2.5 Virtual Remote QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET.
Comment #250Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: Not an ObjectionComment Type: EditorialComment: The term “Vitrual” as stated in section 904.3.3.1.5 and section 904.3.3.2.5 as “Vitrual QA Field reviews“ should be replaced with the term “Remote QA Field reviews“ Vitrual has the conation of simulated on a computer. This process is actually a remote process, implying the evaluation is taking place remotely. Proposed Change: As it appears in the Working Draft WD-02 904.3.3.1.5 “Virtual" “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual" “remote”. All other QA Field reviews, for completed and pre-drywall homes, may be performed using a "virtual" “Remote” QA Field review methodology specified by RESNET. 904.3.3.2.5 Virtual Remote QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET. Response: Accept
Comment #251Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9/8Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: EditorialComment: I whole heartedly support Virtual QA as I believe it is the only way to successfully implement the new QA Standards for volume and/or remote HERS Raters. Furthermore I believe Virtual QA, when done well, is the equal in quality and stringency to on-site QA. If it is equal to on-site QA then it should be treated as equal and should not be limited in its application. If it is not equal, then it should not be implemented at all. Proposed Change: 904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtual” QA Field review methodology specified by RESNET. Response: Reject Reason: at least one on-site QA review should be required because of the value to the rater/RFI
Comment #252Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: EditorialComment: The term “Vitrual” as stated in section 904.3.3.1.5 and section 904.3.3.2.5 as “Vitrual QA Field reviews“ should be replaced with the term “Remote QA Field reviews“ Vitrual has the conation of simulated on a computer. This process is actually a remote process, implying the evaluation is taking place remotely. Proposed Change: 904.3.3.1.5 “Virtual" “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual" “remote”. All other QA Field reviews, for completed and pre-drywall homes, may be performed using a "virtual" “Remote” QA Field review methodology specified by RESNET. 904.3.3.2.5 Virtual Remote QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET. Response: Accept
Comment #253Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 29Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: GeneralComment: If Virtual QA is as good as being on site then why is one on site visit required? This adds cost and complicates QA. Proposed Change: 904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtual” QA Field review methodology specified by RESNET. Response: Reject Reason: at least one on-site QA review should be required because of the value to the rater/RFI
If Virtual QA is as good as being on site then why is one on site visit required? This adds cost and complicates QA.
Comment #254Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: Not an ObjectionComment Type: GeneralComment: Of course, we need details to see if this will really reduce cost or not. But it appears like mid to large raters will benefit here. And providers who engage in this technology quickly will have a recruiting advantage because of lowering cost and headache to the raters. We also feel that this has not yet been vetted enough to make sure there are limited problems. Who will design the technology & how will the QA's be trained to implement it? Proposed Change: N/A Just an observation Response: Reject Reason: the details for implementing remote QA will be developed in the protocol
Of course, we need details to see if this will really reduce cost or not. But it appears like mid to large raters will benefit here. And providers who engage in this technology quickly will have a recruiting advantage because of lowering cost and headache to the raters.
We also feel that this has not yet been vetted enough to make sure there are limited problems. Who will design the technology & how will the QA's be trained to implement it?
Reason: the details for implementing remote QA will be developed in the protocol
Comment #255Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 29Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: TechnicalComment: 904.3.3.1.5 “Virtual” QA Field reviews This type of review could go two ways. On one hand, it has promise to significantly cut cost/travel for QA. On the other hand, this means that a Rater could perform 500 ratings and only have one independently reviewed in the field. This would be undervaluing on-site QA, and subsequently reduce the overall quality of QA. Also, a more well tested, proven and systematic approach to virtual QA needs to be developed before RESNET should allow the majority of all field QA to be performed in this manner. Current QA capabilities discussed at the 2016 RESNET conference have not been refined for such a high volume of QA reviews and thus should not be involved at a high percentage. We propose a more pragmatic approach to ushering in virtual QA that maintains the value of the onsite QA, which will likely always be superior in overall quality to a virtual QA. We have many examples where a virtual QA would not be able to easily uncover serious quality assurance issues found during nan onsite QA, if at all. The first sentence in the section is redundant and language is already provided for in previous sections. Proposed Change: 904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required annual QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, "Virtual" QA Field reviews may be performed for no more than 50% of all subsequent QA Field reviews, using a “virtual” QA Field review methodology specified by RESNET. Response: Reject Reason: not adding this requirement gives the QA agent flexibility
904.3.3.1.5 “Virtual” QA Field reviews
This type of review could go two ways. On one hand, it has promise to significantly cut cost/travel for QA. On the other hand, this means that a Rater could perform 500 ratings and only have one independently reviewed in the field. This would be undervaluing on-site QA, and subsequently reduce the overall quality of QA. Also, a more well tested, proven and systematic approach to virtual QA needs to be developed before RESNET should allow the majority of all field QA to be performed in this manner. Current QA capabilities discussed at the 2016 RESNET conference have not been refined for such a high volume of QA reviews and thus should not be involved at a high percentage.
We propose a more pragmatic approach to ushering in virtual QA that maintains the value of the onsite QA, which will likely always be superior in overall quality to a virtual QA. We have many examples where a virtual QA would not be able to easily uncover serious quality assurance issues found during nan onsite QA, if at all.
The first sentence in the section is redundant and language is already provided for in previous sections.
904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required annual QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, "Virtual" QA Field reviews may be performed for no more than 50% of all subsequent QA Field reviews, using a “virtual” QA Field review methodology specified by RESNET.
Reason: not adding this requirement gives the QA agent flexibility
Comment #256Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7 and 9-8Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: TechnicalComment: Is this section trying to say that all Raters must have at least two QA Field reviews annually? I don't think so, but that's one way to read it. I amended the second section to say that the first QA Field review must be in-person and on a completed house. Any additional QA Field reviews required throughout the year may be performed on houses at either pre-drywall or completion and may be conducted in person or virtually. Proposed Change: 904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home annually. If more than one (1) QA Field review is required, and also one (1) on-site, in-person QA Field review can be completed on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person annually. , the other may be "virtual". All additional other QA Field reviews may be completed on homes at the pre-drywall stage or at completion., for completed and pre-drywall homes, may be performed using a “vVirtual” QA Field reviews methodology may be used for all additional QA Field reviews, as specified by RESNET-defined methodology. Response: Accept Reason: Accept in principle. Change “shall” to “can” in this section
Is this section trying to say that all Raters must have at least two QA Field reviews annually? I don't think so, but that's one way to read it.
I amended the second section to say that the first QA Field review must be in-person and on a completed house. Any additional QA Field reviews required throughout the year may be performed on houses at either pre-drywall or completion and may be conducted in person or virtually.
904.3.3.1.5 “Virtual” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home annually. If more than one (1) QA Field review is required, and also one (1) on-site, in-person QA Field review can be completed on the same or a different home before drywall is installed.
One of the two required QA Field reviews must be completed on-site and in-person annually. , the other may be "virtual". All additional other QA Field reviews may be completed on homes at the pre-drywall stage or at completion., for completed and pre-drywall homes, may be performed using a “vVirtual” QA Field reviews methodology may be used for all additional QA Field reviews, as specified by RESNET-defined methodology.
Reason: Accept in principle. Change “shall” to “can” in this section
Comment #257Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-8Paragraph / Figure / Table / Note: 904.3.3.1.7Comment Intent: ObjectionComment Type: EditorialComment: The word on-site should be removed given the addition of Virtual QA to be Standard. Proposed Change: 904.3.3.1.7 The ProviderQuality Agents shall complete a minimum of 1% quarterly onsite QA Field reviews of Rating Quality Assurance Provider’s ratings, based on the total number of ratings registered by the Provider in the previous quarter, until all annual QA requirements for the Provider have been met for each Rater. QA field reviews are not required on every Rater every quarter. Response: Accept
The word on-site should be removed given the addition of Virtual QA to be Standard.
904.3.3.1.7 The ProviderQuality Agents shall complete a minimum of 1% quarterly onsite QA Field reviews of Rating Quality Assurance Provider’s ratings, based on the total number of ratings registered by the Provider in the previous quarter, until all annual QA requirements for the Provider have been met for each Rater. QA field reviews are not required on every Rater every quarter.
Comment #258Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-8Paragraph / Figure / Table / Note: 904.3.3.1.7Comment Intent: Not an ObjectionComment Type: EditorialComment: The continuation of allowing QA Field Reviews to be conducted based on a previous quarter makes great sense. New wording in 904.3.1.1 however contradicts this practice when applied to Q4 of one year and Q1 of the subsequent year as it requires QA Reviews to be conducted on the same homes as those used for the "annual total of ratings". Proposed Change: No change Response: Reject Reason: There is no prohibition in the standards preventing the QA of homes registered to the Registry in the previous calendar year.
The continuation of allowing QA Field Reviews to be conducted based on a previous quarter makes great sense. New wording in 904.3.1.1 however contradicts this practice when applied to Q4 of one year and Q1 of the subsequent year as it requires QA Reviews to be conducted on the same homes as those used for the "annual total of ratings".
No change
Reason: There is no prohibition in the standards preventing the QA of homes registered to the Registry in the previous calendar year.
Comment #259Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-8 9-10Paragraph / Figure / Table / Note: 904.3.3.2Comment Intent: Not an ObjectionComment Type: EditorialComment: The addition of section 904.3.3.2.5 creates an inherent conflict with the requirements for QA field reviews included in the rest of Section 904.3.3.2, which include requirements that cannot be performed remotely, such as collecting dimensional measurements and completing field performance testing. This could be resolved by separating this from the Field QA section. This section need to be expanded to include technology, processes, protocols and procedures developed by RESNET. Specific language has not been proposed, but it is critical that these processes be developed included before the change to accept virtual QA is made. The devil is in the details and this cannot be included until the details are included. Proposed Change: 904.3.3.2 Requirements for On-Site QA Field reviews. 904.3.3.32.5 Requirements for Virtual QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET. Response: Reject Reason: final remote QA protocols will meet the standards for field QA reviews
The addition of section 904.3.3.2.5 creates an inherent conflict with the requirements for QA field reviews included in the rest of Section 904.3.3.2, which include requirements that cannot be performed remotely, such as collecting dimensional measurements and completing field performance testing.
This could be resolved by separating this from the Field QA section. This section need to be expanded to include technology, processes, protocols and procedures developed by RESNET.
Specific language has not been proposed, but it is critical that these processes be developed included before the change to accept virtual QA is made. The devil is in the details and this cannot be included until the details are included.
904.3.3.2 Requirements for On-Site QA Field reviews.
904.3.3.32.5 Requirements for Virtual QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET.
Reason: final remote QA protocols will meet the standards for field QA reviews
Comment #260Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-9Paragraph / Figure / Table / Note: 904.3.3.2.2Comment Intent: Not an ObjectionComment Type: EditorialComment: When a Quality Agent is working with an RFI in-person (be it phyically or virtually) it may not be necessary for the Quality Agent to actualy collect the measurements or complete the tests or inspections if they can confirm that the RFI is doing the collection and completion per the RESNET Standards. Proposed Change: 904.3.3.2.2 Rating Field Inspectors. The QA Field review shall confirm the accuracy of data collection and reporting by the RFI for the rating receiving a QA Field review. 904.3.3.2.2.1 As necessary, collect or observe the collection of dimensional measurements in the field for the home to evaluate the accuracy of those that may have been determined by the RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards. 904.3.3.2.2.2 Complete or observe in the field all necessary performance testing and all necessary inspections of minimum rated features for the home to evaluate the accuracy of those that may have been determined by the RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards. Response: Reject Reason: redundant language
When a Quality Agent is working with an RFI in-person (be it phyically or virtually) it may not be necessary for the Quality Agent to actualy collect the measurements or complete the tests or inspections if they can confirm that the RFI is doing the collection and completion per the RESNET Standards.
904.3.3.2.2 Rating Field Inspectors. The QA Field review shall confirm the accuracy of data collection and reporting by the RFI for the rating receiving a QA Field review. 904.3.3.2.2.1 As necessary, collect or observe the collection of dimensional measurements in the field for the home to evaluate the accuracy of those that may have been determined by the RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards. 904.3.3.2.2.2 Complete or observe in the field all necessary performance testing and all necessary inspections of minimum rated features for the home to evaluate the accuracy of those that may have been determined by the RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards.
Reason: redundant language
Comment #261Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-9Paragraph / Figure / Table / Note: 904.3.3.2.2Comment Intent: Not an ObjectionComment Type: EditorialComment: When a Quality Agent is working with an RFI in-person (be it phyically or virtually) it may not be necessary for the Quality Agent to actualy collect the measurements or complete the tests or inspections if they can confirm that the RFI is doing the collection and completion per the RESNET Standards. Proposed Change: 904.3.3.2.2 Rating Field Inspectors. The QA Field review shall confirm the accuracy of data collection and reporting by the RFI for the rating receiving a QA Field review. 904.3.3.2.2.1 As necessary, collect or observe the collection of dimensional measurements in the field for the home to evaluate the accuracy of those that may have been determined by the RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards. 904.3.3.2.2.2 Complete or observe in the field all necessary performance testing and all necessary inspections of minimum rated features for the home to evaluate the accuracy of those that may have been determined by the RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards. Response: Reject Reason: redundant language
Comment #262Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9/9Paragraph / Figure / Table / Note: 904.3.3.2.2Comment Intent: Not an ObjectionComment Type: EditorialComment: When a Quality Agent is working with an RFI in-person (be it phyically or virtually) it may not be necessary for the Quality Agent to actualy collect the measurements or complete the tests or inspections if they can confirm that the RFI is doing the collection and completion per the RESNET Standards. Proposed Change: 904.3.3.2.2 Rating Field Inspectors. The QA Field review shall confirm the accuracy of data collection and reporting by the RFI for the rating receiving a QA Field review. 904.3.3.2.2.1 As necessary, collect or observe the collection of dimensional measurements in the field for the home to evaluate the accuracy of those that may have been determined by the RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards. 904.3.3.2.2.2 Complete or observe in the field all necessary performance testing and all necessary inspections of minimum rated features for the home to evaluate the accuracy of those that may have been determined by the RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards. Response: Reject Reason: redundant language
Comment #263Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-8Paragraph / Figure / Table / Note: 904.3.3.2.2-904.3.3.2.2.2Comment Intent: ObjectionComment Type: GeneralComment: This language is unnecessary and unenforceable. Quality Assurance Providers cannot be held accountable for the work of RFIs performed under the auspices of the certified Rater WHEN there is no requirement for a contractual relationship between the RFI and the Quality Assurance Provider under these Standards. Proposed Change: Strike the following in its entirety: 904.3.3.2.2 Rating Field Inspectors. The QA Field review shall confirm the accuracy of data collection and reporting by the RFI for the rating receiving a QA Field review. 904.3.3.2.2.1 As necessary, collect dimensional measurements in the field for the home to evaluate the accuracy of those that may have been determined by the RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards. 904.3.3.2.2.2 Complete in the field all necessary performance testing and all necessary inspections of minimum rated features for the home to evaluate the accuracy of those that may have been determined by the RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards. Do NOT replace. Response: Reject Reason: RFIs should be subject to quality assurance
This language is unnecessary and unenforceable. Quality Assurance Providers cannot be held accountable for the work of RFIs performed under the auspices of the certified Rater WHEN there is no requirement for a contractual relationship between the RFI and the Quality Assurance Provider under these Standards.
904.3.3.2.2 Rating Field Inspectors. The QA Field review shall confirm the accuracy of data collection and reporting by the RFI for the rating receiving a QA Field review. 904.3.3.2.2.1 As necessary, collect dimensional measurements in the field for the home to evaluate the accuracy of those that may have been determined by the RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards. 904.3.3.2.2.2 Complete in the field all necessary performance testing and all necessary inspections of minimum rated features for the home to evaluate the accuracy of those that may have been determined by the RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards.
Reason: RFIs should be subject to quality assurance
Comment #264Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-9Paragraph / Figure / Table / Note: 904.3.3.2.3Comment Intent: Not an ObjectionComment Type: EditorialComment: When a Quality Agent is working with an RFI in-person (be it phyically or virtually) it may not be necessary for the Quality Agent to actualy collect the measurements or complete the tests or inspections if they can confirm that the RFI is doing the collection and completion per the RESNET Standards. Proposed Change: 904.3.3.2.3 Pre-drywall. For homes receiving a QA Field review prior to the installation of drywall, the QA shall complete, or observe the completion of, in the field all necessary performance testing and all necessary inspections of minimum rated features for the home to evaluate the accuracy of those determined by the HERS Rater or RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards. Response: Reject Reason: redundant language
904.3.3.2.3 Pre-drywall. For homes receiving a QA Field review prior to the installation of drywall, the QA shall complete, or observe the completion of, in the field all necessary performance testing and all necessary inspections of minimum rated features for the home to evaluate the accuracy of those determined by the HERS Rater or RFI, including conformance to the requirements set forth in Chapter 8 and Appendix A of these Standards.
Comment #265Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 31Paragraph / Figure / Table / Note: 904.3.3.2.3Comment Intent: Not an ObjectionComment Type: GeneralComment: Chapter 8 is being replaced by 380 correct? Also, 2009 IECC gives excellent prescriptive guidance and helps to align the standard better with codes. Proposed Change: Pre-drywall. For homes receiving a QA Field review prior to the installation of drywall, the QA shall complete in the field all necessary performance testing and all necessary inspections of minimum rated features for the home to evaluate the accuracy of those determined by the HERS Rater or RFI, including conformance to the requirements set forth in Chapter 8 Standard 380, IECC 2009 thermal enclosure checklist and Appendix A of the Mortgage Industry National Home Energy Rating Systems Standards. Response: Accept Reason: Accept in principle. References to chapter 8 will be updated to standard 380. Standards will not reference standards outside of RESNET or other ANSI standards
Chapter 8 is being replaced by 380 correct? Also, 2009 IECC gives excellent prescriptive guidance and helps to align the standard better with codes.
Pre-drywall. For homes receiving a QA Field review prior to the installation of drywall, the QA shall complete in the field all necessary performance testing and all necessary inspections of minimum rated features for the home to evaluate the accuracy of those determined by the HERS Rater or RFI, including conformance to the requirements set forth in Chapter 8 Standard 380, IECC 2009 thermal enclosure checklist and Appendix A of the Mortgage Industry National Home Energy Rating Systems Standards.
Reason: Accept in principle. References to chapter 8 will be updated to standard 380. Standards will not reference standards outside of RESNET or other ANSI standards
Comment #266Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-9Paragraph / Figure / Table / Note: 904.3.3.2.4Comment Intent: ObjectionComment Type: GeneralComment: This language is unnecessary and unenforceable. Quality Assurance Providers cannot be held accountable for the work of RFIs performed under the auspices of the certified Rater WHEN there is no requirement for a contractual relationship between the RFI and the Quality Assurance Provider under these Standards. Additionally, this section has permissive language that renders it unenforceable. Proposed Change: Strike the following in its entirety: 904.3.3.2.4904.4.2.4 Each home rating selected for a QA fField review for each HERS Rater and RFI shall be randomly selected from as many different builders and communities as possible. Special effort should be taken to make certain that the selected homesratings are as representative as possible of the homesratings being ratedcompleted, i.e. new and existing homes, geographic location, builder, trade contractor, variety of floor plans, etc., which, in some instances, may require more than the minimum (1) home or one percent (1%). Replace with: 904.3.3.2.4 Each rating selected for a QA Field review for each HERS Rater shall be randomly selected. Response: Reject Reason: RFIs should be subject to quality assurance
Additionally, this section has permissive language that renders it unenforceable.
904.3.3.2.4904.4.2.4 Each home rating selected for a QA fField review for each HERS Rater and RFI shall be randomly selected from as many different builders and communities as possible. Special effort should be taken to make certain that the selected homesratings are as representative as possible of the homesratings being ratedcompleted, i.e. new and existing homes, geographic location, builder, trade contractor, variety of floor plans, etc., which, in some instances, may require more than the minimum (1) home or one percent (1%).
904.3.3.2.4 Each rating selected for a QA Field review for each HERS Rater shall be randomly selected.
Comment #267Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 32Paragraph / Figure / Table / Note: 904.3.3.2.5Comment Intent: ObjectionComment Type: GeneralComment: I move that the following proposed language get struck until a significant amount of testing is done in regards to virtual QA. Additionally, it should remain out of the standards until such a time when a methodology that has received stringent testing and public comments can be put into the standards: 904.3.3.2.5 Virtual QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET. Proposed Change: 904.3.3.2.5 Virtual QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET. Response: Reject Reason: Protocols for remote QA will be developed and beta tested.
I move that the following proposed language get struck until a significant amount of testing is done in regards to virtual QA. Additionally, it should remain out of the standards until such a time when a methodology that has received stringent testing and public comments can be put into the standards:
Reason: Protocols for remote QA will be developed and beta tested.
Comment #268Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-10Paragraph / Figure / Table / Note: 904.3.3.2.5Comment Intent: ObjectionComment Type: GeneralComment: This section is redundant. This element was addressed in Section 904.3.3.1.5. Additionally, this section contains permissive language and is unenforceable. Once RESNET approves a methodology for remote quality management, a Standard Amendment must be written to modify the currrent Standards to allow this activity. The cart is before the horse on this one... Proposed Change: Strike the following in its entirety: 904.3.3.2.5 Virtual QA Field reviews. QA Field reviews not completed on-site, in- person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET. Do NOT replace. Response: Reject Reason: Protocols for remote QA will be developed and beta tested.
This section is redundant. This element was addressed in Section 904.3.3.1.5.
Additionally, this section contains permissive language and is unenforceable. Once RESNET approves a methodology for remote quality management, a Standard Amendment must be written to modify the currrent Standards to allow this activity. The cart is before the horse on this one...
904.3.3.2.5 Virtual QA Field reviews. QA Field reviews not completed on-site, in- person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET.
Comment #269Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.2.5Comment Intent: Not an ObjectionComment Type: TechnicalComment: Based on similar accepted methods on other industries or new technologies that are accessible or in development, I’m proposing a series of options that define the terms highlighted in section 904.3.3.1.5 and 904.3.3.2.5 review methodology specified by RESNET. 904.3.3.1.5 “Virtual" QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a "virtual" QA Field review methodology specified by RESNET. 904.3.3.2.5 Virtual QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET. Additional clarification - the term or use of “Virtual QA Assistant“ should not be included on introduced. The purpose of a remote QA procedure is to eliminate the cost of a QA attending the process. Having a Virtual QA Assistant defeats this a viable solution. The sections that were added in the Proposed Changes section below were intended to define the options for Video Review and what are some other methods that can verify compliance thru Remote QA Field review without using a Video QA Field review. This method may be limited by internet access. A- What is a Remote Video QA Field review. This method can be used or ... B- Video 95% of pre drywall conditions and allow the QA to review them The officially reviewed 1% should allow adequate time for clarification and review before drywall is installed. I understand this my be a challenge but would be a similar time frame as a live review. Note when the Rater has to record almost all or the pre drywall conditions, the video(s) can be reviewed at an ongoing time frame and if conditions are not clear or installations are not compliant, the QA can provide feedback to correct further videos or correct installation defects. The QA would have only officially reviewed 1% of the installations, this option provides 95% to be evaluated. B- Also included using an app that documents the conditions, installations and performance tests. These apps do not need internet access to gather data and automatically perform and acquire the test data for blower door, duct tests and ventilation flow measurements. The data can be uploaded later but was stored securely on the mobile device. The EPA is currently developing an Energy Star Field App that is designed to document and validate field conditions, installations and fully verify performance tests. Based on these types of applications being developed I recommend the RESNET develop standards (specific fields and functions) and a review process to approve apps that can labeled “Approved RESNET Apps” The features of the Apps described below are being developed by most manufacturers. Our industry is developing Remote Verification Data for performance testing. It is vital that RESNET be at the forefront of this integration and development. Personal comments - Futurology, the ability to imagine, anticipate and integrate future technologies. Technology is changing at an amazing rate and we cannot predict or maintain a list of products or processes that allow Raters to confirm compliance with their QA - and maintain that list in the Standards. The methodology and approved techniques can be updated and listed on RESNET website and referenced in the Standards. Not approving or providing the Remote or “Virtual QA Field Review” option to Raters will only demonstrate that RESNET is not maintaining its commitment to cutting edge solutions. Remember the iPhone is only 9 years old and most of the sophisticated apps are less then 4 years old. Communication apps are also in there developmental stage for mobile devices. Streaming video and video conference calls will be common place because 4G becomes 5G and there will be more coverage areas. Sooner then later, there will be RESNET app separate from the Energy Star app that will allow documentation sharing, live conference video, storage of images and additional videos, storage and verification of performance data (blower door, duct test, exhaust fan flows, CO detectors and ...) This data will integrate in to the RATING software and store the data in a cloud storage that can be accessed by 3rd party vendors that have access. The future of home RATINGS begins here. There is a PDF file attached. I apologize for any typos - this was finished late at night! Proposed Change: As stated in Working Draft WD-02 904.3.3.2.5 Virtual QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using 904.3.3.2.5.1 or 904.3.3.2.5.5 There may be additional video technology or processes, protocols, and procedures that are similar but not listed and may be used by the QA if they believe the application meets the intent of the methodology of the Virtual QA Field review. 904.3.3.2.5.1 Remote Video Live Observation. This method uses a live video feed from the job site to the QA. This method requires the ability to maintain a live video that can demonstrate compliance in all areas of the site for review. The live video feed may be provided through an internet service that is arranged by the QA and Rater. The connection and video quality should be evaluated before the QA Field review. The QA may request that a phone reception and or headset is used for communication. The QA has the option of forgoing performance testing verification if the Rater uses section 904.3.3.2.5.8 Performance Test Data App a) All job files required by the QA should be sent to the QA prior to the Remote Video Live Observation b) The Rater must also be able to capture images as requested by the QA and/or are needed for documentation. c) The Rater should prepare the job site for full access to all areas to prevent delays, (e.g. ladders installed and hatches are open.) The areas must be well lit to provide a clear and high quality video d) The QA may require specific online services or equipment to provide a stable signal and a clear and high quality video. 904.3.3.2.5.5 Compliance includes completing section 904.3.3.2.5.6 and either 904.3.3.2.5.7 or 904.3.3.2.5.8 904.3.3.2.5.6 Video taping of pre drywall conditions. The Rater or RFI will video tape and narrate the conditions of 95% of all Ratings or partial ratings that involve a pre drywall condition. {note to be removed - 95% is selected to account for technical failures}. The Rater will also capture images on all installed appliances, performance tests and any other images the QA has requested for this method. These videos must be stored on a cloud server storage that either the QA has been provided access or belongs to the QA, or the videos are shared with the QA via an individual link that is sent to the QA. These videos must be available within 48 hours of the video taping. The QA is only required to review 1% of the videos, but can review any or all of the videos. The QA will notify the Rater which location(s) will be used for the required 1% review. This review must be coordinated with the builder to allow the QA the ability to review the video and request additional clarification thru a combination of documentation, video or pictures before the drywall is applied. 904.3.3.2.5.7 Integrated RATING App is used that captures the data fields required for a Rating and images to confirm installations. This app must be approved by RESNET (for a list of approved app go to www.RESNET.com/XYZ) The app must directly communicate with the RATING software, transferring the RATING data directly, without the means of manual input into the RATING software. The Integrated RATING app must directly integrate with the manufacturer of the test device or the manufacturers software to perform the requirements of section 904.3.3.2.5.8. If the Integrated RATING app can complete the requirements of section 904.3.3.2.5.8 a Performance Test Data App must also be used. {note to be removed - EPA is developing an Energy Star Field App that is designed to document and validate field conditions, installations and performance tests) 904.3.3.2.5.8 Performance Test Data (PTD) App is used to connect to the manufacturers testing device or is integrated in the manufactures testing device (e.g. manometer) and performs the required test automatically and captures without the means of manual input, the test data for blower door, duct tests and/or ventilation flow measurements. The test data must be incorruptible or not able to be altered at time during the capture, storage or when transferred. The data can be stored on a cloud server or stored on the device with encryption. The PTD app must be able fully perform the requirements of the testing standards, including selectable fields confirming the required test conditions (e.g. all interior doors open, location of pressure tap) and calculate the results. The PTD app must provide a location where the test is performed as a geolocation. The PTD app must include the address, size and volume of the structure or area being tested, Raters (or RFI’s) name, equipment type, serial numbers and calibration dates and all required testing data used for calculations (e.g. temperature) If an Integrated RATING app is not used, the PTD app test data must communicate directly with the RATING software with data that is incorruptible or not able to be altered. Response: Reject Reason: The protocols for remote QA will be developed separately from the standards
Based on similar accepted methods on other industries or new technologies that are accessible or in development, I’m proposing a series of options that define the terms highlighted in section 904.3.3.1.5 and 904.3.3.2.5
review methodology specified by RESNET.
904.3.3.1.5 “Virtual" QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a "virtual" QA Field review methodology specified by RESNET.
Additional clarification - the term or use of “Virtual QA Assistant“ should not be included on introduced. The purpose of a remote QA procedure is to eliminate the cost of a QA attending the process. Having a Virtual QA Assistant defeats this a viable solution.
The sections that were added in the Proposed Changes section below were intended to define the options for Video Review and what are some other methods that can verify compliance thru Remote QA Field review without using a Video QA Field review. This method may be limited by internet access.
A- What is a Remote Video QA Field review. This method can be used or ...
B- Video 95% of pre drywall conditions and allow the QA to review them The officially reviewed 1% should allow adequate time for clarification and review before drywall is installed. I understand this my be a challenge but would be a similar time frame as a live review. Note when the Rater has to record almost all or the pre drywall conditions, the video(s) can be reviewed at an ongoing time frame and if conditions are not clear or installations are not compliant, the QA can provide feedback to correct further videos or correct installation defects. The QA would have only officially reviewed 1% of the installations, this option provides 95% to be evaluated.
B- Also included using an app that documents the conditions, installations and performance tests. These apps do not need internet access to gather data and automatically perform and acquire the test data for blower door, duct tests and ventilation flow measurements. The data can be uploaded later but was stored securely on the mobile device.
The EPA is currently developing an Energy Star Field App that is designed to document and validate field conditions, installations and fully verify performance tests. Based on these types of applications being developed I recommend the RESNET develop standards (specific fields and functions) and a review process to approve apps that can labeled “Approved RESNET Apps” The features of the Apps described below are being developed by most manufacturers. Our industry is developing Remote Verification Data for performance testing. It is vital that RESNET be at the forefront of this integration and development.
Personal comments - Futurology, the ability to imagine, anticipate and integrate future technologies. Technology is changing at an amazing rate and we cannot predict or maintain a list of products or processes that allow Raters to confirm compliance with their QA - and maintain that list in the Standards. The methodology and approved techniques can be updated and listed on RESNET website and referenced in the Standards. Not approving or providing the Remote or “Virtual QA Field Review” option to Raters will only demonstrate that RESNET is not maintaining its commitment to cutting edge solutions.
Remember the iPhone is only 9 years old and most of the sophisticated apps are less then 4 years old. Communication apps are also in there developmental stage for mobile devices. Streaming video and video conference calls will be common place because 4G becomes 5G and there will be more coverage areas.
Sooner then later, there will be RESNET app separate from the Energy Star app that will allow documentation sharing, live conference video, storage of images and additional videos, storage and verification of performance data (blower door, duct test, exhaust fan flows, CO detectors and ...) This data will integrate in to the RATING software and store the data in a cloud storage that can be accessed by 3rd party vendors that have access. The future of home RATINGS begins here.
There is a PDF file attached. I apologize for any typos - this was finished late at night!
As stated in Working Draft WD-02
904.3.3.2.5 Virtual QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using 904.3.3.2.5.1 or 904.3.3.2.5.5 There may be additional video technology or processes, protocols, and procedures that are similar but not listed and may be used by the QA if they believe the application meets the intent of the methodology of the Virtual QA Field review.
904.3.3.2.5.1 Remote Video Live Observation. This method uses a live video feed from the job site to the QA. This method requires the ability to maintain a live video that can demonstrate compliance in all areas of the site for review. The live video feed may be provided through an internet service that is arranged by the QA and Rater. The connection and video quality should be evaluated before the QA Field review. The QA may request that a phone reception and or headset is used for communication. The QA has the option of forgoing performance testing verification if the Rater uses section 904.3.3.2.5.8 Performance Test Data App
a) All job files required by the QA should be sent to the QA prior to the Remote Video Live Observation
b) The Rater must also be able to capture images as requested by the QA and/or are needed for documentation.
c) The Rater should prepare the job site for full access to all areas to prevent delays, (e.g. ladders installed and hatches are open.) The areas must be well lit to provide a clear and high quality video
d) The QA may require specific online services or equipment to provide a stable signal and a clear and high quality video.
904.3.3.2.5.5 Compliance includes completing section 904.3.3.2.5.6 and either 904.3.3.2.5.7 or 904.3.3.2.5.8
904.3.3.2.5.6 Video taping of pre drywall conditions. The Rater or RFI will video tape and narrate the conditions of 95% of all Ratings or partial ratings that involve a pre drywall condition. {note to be removed - 95% is selected to account for technical failures}. The Rater will also capture images on all installed appliances, performance tests and any other images the QA has requested for this method. These videos must be stored on a cloud server storage that either the QA has been provided access or belongs to the QA, or the videos are shared with the QA via an individual link that is sent to the QA. These videos must be available within 48 hours of the video taping. The QA is only required to review 1% of the videos, but can review any or all of the videos. The QA will notify the Rater which location(s) will be used for the required 1% review. This review must be coordinated with the builder to allow the QA the ability to review the video and request additional clarification thru a combination of documentation, video or pictures before the drywall is applied.
904.3.3.2.5.7 Integrated RATING App is used that captures the data fields required for a Rating and images to confirm installations. This app must be approved by RESNET (for a list of approved app go to www.RESNET.com/XYZ) The app must directly communicate with the RATING software, transferring the RATING data directly, without the means of manual input into the RATING software. The Integrated RATING app must directly integrate with the manufacturer of the test device or the manufacturers software to perform the requirements of section 904.3.3.2.5.8. If the Integrated RATING app can complete the requirements of section 904.3.3.2.5.8 a Performance Test Data App must also be used. {note to be removed - EPA is developing an Energy Star Field App that is designed to document and validate field conditions, installations and performance tests)
904.3.3.2.5.8 Performance Test Data (PTD) App is used to connect to the manufacturers testing device or is integrated in the manufactures testing device (e.g. manometer) and performs the required test automatically and captures without the means of manual input, the test data for blower door, duct tests and/or ventilation flow measurements. The test data must be incorruptible or not able to be altered at time during the capture, storage or when transferred. The data can be stored on a cloud server or stored on the device with encryption. The PTD app must be able fully perform the requirements of the testing standards, including selectable fields confirming the required test conditions (e.g. all interior doors open, location of pressure tap) and calculate the results. The PTD app must provide a location where the test is performed as a geolocation. The PTD app must include the address, size and volume of the structure or area being tested, Raters (or RFI’s) name, equipment type, serial numbers and calibration dates and all required testing data used for calculations (e.g. temperature) If an Integrated RATING app is not used, the PTD app test data must communicate directly with the RATING software with data that is incorruptible or not able to be altered.
Reason: The protocols for remote QA will be developed separately from the standards
Comment #270Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-10Paragraph / Figure / Table / Note: 904.3.3.2.5Comment Intent: ObjectionComment Type: GeneralComment: The conduct of a Virtual QA Field Review is referenced in numerous places throughout the proposed amendment. The only place I could find detail of what this process would include is in section 904.3.3.2.5. "Virtual QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET." To be able to effectively comment on the proposed amendment and understand the implications of using a Virtual QA process, it is important to know what is required. Please provide additional details. Proposed Change: 904.3.3.2.5. "Virtual QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET." Expand definition of processes, protocols, and procedures. Response: Accept Reason: Accept in principle. The protocols for remote QA will be developed separately from the standards
The conduct of a Virtual QA Field Review is referenced in numerous places throughout the proposed amendment. The only place I could find detail of what this process would include is in section 904.3.3.2.5. "Virtual QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET."
To be able to effectively comment on the proposed amendment and understand the implications of using a Virtual QA process, it is important to know what is required.
Please provide additional details.
904.3.3.2.5. "Virtual QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Agent, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET."
Expand definition of processes, protocols, and procedures.
Reason: Accept in principle. The protocols for remote QA will be developed separately from the standards
Comment #271Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-10Paragraph / Figure / Table / Note: 904.3.4.1 and subsectionsComment Intent: Not an ObjectionComment Type: EditorialComment: Can the yellow section just cite the explanation elsewhere in the Standard of how sampled Ratings shall be counted towards total annual Ratings? Simple grammatical clarifications elsewhere. Proposed Change: 904.3.4.1 In addition to the Quality Assurance requirements specified in this Chapter, quality assurance for multifamily projects shall include, at a minimum, the following: 904.3.4.1.1 All dwelling units that are certified or qualified by the use of sampling shall be considered to be “rRatings”. QA File and QA Field reviews shall be conducted on a percentage of all the dwelling units certified or qualified under sampling, rather than the percentage of tested and inspected dwelling units. 904.3.4.1.2 To ensure that Quality Assurance is being completed on HERS Raters and RFI’s rather than builders, QA Field reviews for multifamily buildings shall be conducted on certified or qualified dwelling units within sample sets that have received field testing and/or inspections. 904.3.4.1.3 If units within a multifamily building have multiple space conditioning configurations such that some units have ducts and other units do not, the Quality Agent shall choose a unit with ducts for QA Field review. AlternativelyAdditionally, if the building has some units with ducts that are within conditioned space while others have ducts that are outside of the building envelope, the Quality Agent shall choose a unit with ducts outside of the envelope for QA Field review. 904.3.4.1.4 For multifamily projects, when selected, field QA Field reviews shall include a comprehensive inspection of all minimum rated features that are possible to be inspected within the selected units and within the building during the time of the field QA Field review. This means that the Quality AgentD shall inspect attic insulation via a common attic access where present, mechanical rooms that house common mechanical systems that serve multiple units, common ventilation systems, laundry systems, common laundry etc. Response: Accept Reason: Accept edits and will ask Paul and Thiel to develop new language for this section.
Can the yellow section just cite the explanation elsewhere in the Standard of how sampled Ratings shall be counted towards total annual Ratings?
Simple grammatical clarifications elsewhere.
904.3.4.1 In addition to the Quality Assurance requirements specified in this Chapter, quality assurance for multifamily projects shall include, at a minimum, the following:
904.3.4.1.1 All dwelling units that are certified or qualified by the use of sampling shall be considered to be “rRatings”. QA File and QA Field reviews shall be conducted on a percentage of all the dwelling units certified or qualified under sampling, rather than the percentage of tested and inspected dwelling units.
904.3.4.1.2 To ensure that Quality Assurance is being completed on HERS Raters and RFI’s rather than builders, QA Field reviews for multifamily buildings shall be conducted on certified or qualified dwelling units within sample sets that have received field testing and/or inspections.
904.3.4.1.3 If units within a multifamily building have multiple space conditioning configurations such that some units have ducts and other units do not, the Quality Agent shall choose a unit with ducts for QA Field review. AlternativelyAdditionally, if the building has some units with ducts that are within conditioned space while others have ducts that are outside of the building envelope, the Quality Agent shall choose a unit with ducts outside of the envelope for QA Field review.
904.3.4.1.4 For multifamily projects, when selected, field QA Field reviews shall include a comprehensive inspection of all minimum rated features that are possible to be inspected within the selected units and within the building during the time of the field QA Field review. This means that the Quality AgentD shall inspect attic insulation via a common attic access where present, mechanical rooms that house common mechanical systems that serve multiple units, common ventilation systems, laundry systems, common laundry etc.
Reason: Accept edits and will ask Paul and Thiel to develop new language for this section.
Comment #272Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-10Paragraph / Figure / Table / Note: 904.3.4.1.1 & 904.3.4.1.2Comment Intent: Not an ObjectionComment Type: GeneralComment: Is this saying that all units are counted for QA but QA can only be done on any unit that was actually tested? Proposed Change: N/A Just an observation Response: Reject Reason: No change is proposed but all sampled and confirmed ratings are included in the QA process.
Is this saying that all units are counted for QA but QA can only be done on any unit that was actually tested?
Reason: No change is proposed but all sampled and confirmed ratings are included in the QA process.
Comment #273Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 34Paragraph / Figure / Table / Note: 904.3.4.1.2Comment Intent: ObjectionComment Type: TechnicalComment: This to me reads that we can only perform QA in inspected units not sampled units. As units turn over quickly this adds to complicate the QA scheduling process. As the rater is being QA'ed on process it doesn’t matter which unit is used for the QA. . also if we test/inspect for the minimum rated features thru out a sample set ie BD one unit, DB another, windows in another etc, then how do you determine which unit to use as the QA unit? do they all count? if so the section is redundant this section is also counter the the language set out in the Multi Family Guidelines My recmendation is to strikeout and remove the entire 904.3.4.1.2 section Proposed Change: 904.3.4.1.2 To ensure that Quality Assurance is being completed on HERS Raters and RFI’s rather than builders, QA Field reviews for multifamily buildings shall be conducted on certified or qualified dwelling units within sample sets that have received field testing and/or inspections. Response: Accept Reason: Accept in principle and will ask Paul and Thiel to develop new language for this section.
This to me reads that we can only perform QA in inspected units not sampled units. As units turn over quickly this adds to complicate the QA scheduling process. As the rater is being QA'ed on process it doesn’t matter which unit is used for the QA. .
also if we test/inspect for the minimum rated features thru out a sample set ie BD one unit, DB another, windows in another etc, then how do you determine which unit to use as the QA unit? do they all count? if so the section is redundant
this section is also counter the the language set out in the Multi Family Guidelines
My recmendation is to strikeout and remove the entire 904.3.4.1.2 section
Reason: Accept in principle and will ask Paul and Thiel to develop new language for this section.
Comment #274Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-10Paragraph / Figure / Table / Note: 904.3.4.1.2Comment Intent: ObjectionComment Type: TechnicalComment: This to me reads that we can only perform QA in inspected units not sampled units. As units turn over quickly this adds to complicate the QA scheduling process. As the rater is being QA'ed on process it doesn’t matter which unit is used for the QA. . also if we test/inspect for the minimum rated features thru out a sample set ie BD one unit, DB another, windows in another etc, then how do you determine which unit to use as the QA unit? do they all count? if so the section is redundant this section is also counter the the language set out in the Multi Family Guidelines My recommendation is to strikeout and remove the entire 904.3.4.1.2 section and add the language already in the MF guidelines Proposed Change: 904.3.4.1.2 To ensure that Quality Assurance is being completed on HERS Raters and RFI’s rather than builders, QA Field reviews for multifamily buildings shall be conducted on certified or qualified dwelling units within sample sets that have received field testing and/or inspections. 904.3.4.1.2 the field QA required may be conducted on any of the certifier or qualified ( sampled) dwelling units within the sample set and shall NOT be limited to the tested and inspected dwelling units. Response: Accept Reason: Accept in principle and will ask Paul and Thiel to develop new language for this section.
My recommendation is to strikeout and remove the entire 904.3.4.1.2 section and add the language already in the MF guidelines
904.3.4.1.2 the field QA required may be conducted on any of the certifier or qualified ( sampled) dwelling units within the sample set and shall NOT be limited to the tested and inspected dwelling units.
Comment #275Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-10Paragraph / Figure / Table / Note: 904.3.4.1.2Comment Intent: ObjectionComment Type: TechnicalComment: I propose you should be able to sample any sample sets...whether they received field testing or not. This is true QA. Proposed Change: 904.3.4.1.2 To ensure that Quality Assurance is being completed on HERS Raters and RFI’s rather than builders, QA Field reviews for multifamily buildings shall be conducted on certified or qualified dwelling units within any sample sets. that have received field testing and/or inspections. Response: Reject Reason: not consistent for single family QA process and new language will be proposed that will align with single family QA. QA review is being conducted on the rater/RFI and not the builder
I propose you should be able to sample any sample sets...whether they received field testing or not. This is true QA.
904.3.4.1.2 To ensure that Quality Assurance is being completed on HERS Raters and RFI’s rather than builders, QA Field reviews for multifamily buildings shall be conducted on certified or qualified dwelling units within any sample sets. that have received field testing and/or inspections.
Reason: not consistent for single family QA process and new language will be proposed that will align with single family QA. QA review is being conducted on the rater/RFI and not the builder
Comment #276Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-10, 9-11Paragraph / Figure / Table / Note: 904.3.4.2Comment Intent: ObjectionComment Type: GeneralComment: Limiting a particular MF project from being used more than once to meet the Field QA quota unless the project includes more than 100 units is overly restrictive. It is likely that the entire scope of a rating cannot be reviewed by performing field QA on a single unit. The proposed language is an attempt to make this less restrictive by allowing 1 field QA for every 50 units. Proposed Change: 904.3.4.2.2 Exception. If a particular multifamily development contained more than 100 50 units. In such an instance, one field QA Field review per every 100 50 units of that development shall count towards the annual field QA Field review quota. Response: Accept Reason: Added flexibility for the QA Agent and scheduling as well as cost savings are all beneficial. This retains the focus of QA being on the rater/RFI instead of the builder
Limiting a particular MF project from being used more than once to meet the Field QA quota unless the project includes more than 100 units is overly restrictive. It is likely that the entire scope of a rating cannot be reviewed by performing field QA on a single unit. The proposed language is an attempt to make this less restrictive by allowing 1 field QA for every 50 units.
904.3.4.2.2 Exception. If a particular multifamily development contained more than 100 50 units. In such an instance, one field QA Field review per every 100 50 units of that development shall count towards the annual field QA Field review quota.
Reason: Added flexibility for the QA Agent and scheduling as well as cost savings are all beneficial. This retains the focus of QA being on the rater/RFI instead of the builder
Comment #277Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-10-11Paragraph / Figure / Table / Note: 904.3.4.2-904.3.4.2.3Comment Intent: ObjectionComment Type: GeneralComment: There is no need for a Standard section that immediately requires 3 exceptions to address the unintended consequences of a poorly written section. Proposed Change: Strike the following in its entirety: 904.3.4.2904.4.2.4.2 If the annual rating volume of a HERS Rater is such that more than one field QA Field review is required for that annual period’s field QA Field review quota (i.e. the HERS Rater completed more than 100 ratings during the annual period), no more than one field QA Field review within a particular multifamily development shall count toward meeting the total field QA Field review quota. 904.3.4.2.1 Exception. If a Rater/RFI did not perform ratings on any other single or multifamily buildings for the calendar year and the multifamily building is 100 units or less, then pre-drywall and final QA Field reviews may be performed on the multifamily building that was rated. 904.3.4.2.2904.4.2.4.2.1 An eException. would be allowed iIf a particular multifamily development contained more than 100 units. In such an instance, one field QA Field review per every 100 units of that development shall count towards the annual field QA Field review quota. 904.3.4.2.3904.4.2.4.2.2 Another eException. would be allowed iIf the HERS Rater had one or more Rating Field Inspectors (RFIRFI’s) who worked with them throughout the annual period, in which case the Quality AgentD may select multiple units within a particular multifamily development to count towards the annual field QA Field review quota for each RFI as long as those additional field QA Field reviews represent work performed by each individual RFI during the annual period. Do NOT replace. Response: Reject Reason: No solutions or alternatives offered for this section. Exceptions allow for flexibility for the QA agent and scheduling.
There is no need for a Standard section that immediately requires 3 exceptions to address the unintended consequences of a poorly written section.
904.3.4.2904.4.2.4.2 If the annual rating volume of a HERS Rater is such that more than one field QA Field review is required for that annual period’s field QA Field review quota (i.e. the HERS Rater completed more than 100 ratings during the annual period), no more than one field QA Field review within a particular multifamily development shall count toward meeting the total field QA Field review quota. 904.3.4.2.1 Exception. If a Rater/RFI did not perform ratings on any other single or multifamily buildings for the calendar year and the multifamily building is 100 units or less, then pre-drywall and final QA Field reviews may be performed on the multifamily building that was rated.
904.3.4.2.2904.4.2.4.2.1 An eException. would be allowed iIf a particular multifamily development contained more than 100 units. In such an instance, one field QA Field review per every 100 units of that development shall count towards the annual field QA Field review quota.
904.3.4.2.3904.4.2.4.2.2 Another eException. would be allowed iIf the HERS Rater had one or more Rating Field Inspectors (RFIRFI’s) who worked with them throughout the annual period, in which case the Quality AgentD may select multiple units within a particular multifamily development to count towards the annual field QA Field review quota for each RFI as long as those additional field QA Field reviews represent work performed by each individual RFI during the annual period.
Reason: No solutions or alternatives offered for this section. Exceptions allow for flexibility for the QA agent and scheduling.
Comment #278Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 33Paragraph / Figure / Table / Note: 904.3.4.2.2Comment Intent: ObjectionComment Type: TechnicalComment: as most MF units are by and large very similar in design and given the larger % of units, the rapid pace of multi family construction and the strong possibility units will be occupied in a short time after the onsite rating, allowing a larger QA window will tremendously ease the time / expense and logistics for the QA process. I propose allowing 2% of units to used for QA which, in general for a large MF project containing 300 units would mean allowing 6 units instead of 3 units to be availabe for QA. for a smaller 101 unit project the rate goes from 2 to 3, ( rounding up ). Proposed Change: 904.3.4.2.2904.4.2.4.2.1 An Exception. would be allowed iIf a particular multifamily development contained more than 100 units. In such an instance, one two field QA Field review per every 100 units of that development shall count towards the annual field QA Field review quota. Response: Accept Reason: Accept in principle. Similar change was made per comment #275
as most MF units are by and large very similar in design and given the larger % of units, the rapid pace of multi family construction and the strong possibility units will be occupied in a short time after the onsite rating, allowing a larger QA window will tremendously ease the time / expense and logistics for the QA process. I propose allowing 2% of units to used for QA which, in general for a large MF project containing 300 units would mean allowing 6 units instead of 3 units to be availabe for QA. for a smaller 101 unit project the rate goes from 2 to 3, ( rounding up ).
904.3.4.2.2904.4.2.4.2.1 An Exception. would be allowed iIf a particular multifamily development contained more than 100 units. In such an instance, one two field QA Field review per every 100 units of that development shall count towards the annual field QA Field review quota.
Reason: Accept in principle. Similar change was made per comment #275
Comment #279Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 34Paragraph / Figure / Table / Note: 904.3.5 and subsectionsComment Intent: ObjectionComment Type: TechnicalComment: 904.3.5.5 and subsections None of the thresholds for levels of non-compliance in this section make sense. We can only surmise that the intent of the thresholds proposed under this section and its subsections assumes that ratings selected for 10% QA File review are being evaluated based on the cumulative change in HERS Index per proposed section 904.3.5.1. However, the 10% QA File Review does not require manipulation of the rating file or a comparison of the pre and post QA HERS Index. The 10% QA File review only requires that, “For of each Confirmed Rating, confirm that the values entered into the HERS Rating Software for all Minimum Rated Features are supported by actual on-site field-verified test data.” That’s all folks. We would propose a change to the language under section 904.3.2.4.3, but no changes are being proposed to the requirements for 10% QA File review. Given this error, this section has too many issues to remain as is and shoudl be struck until new language is proposed for section 904.3.2.4.3. Proposed Change: 904.3.5.5904.4.3.4 Multiple instances of non-compliance with 904.4.2.5 QA File and/or QA Field review for a Rater or RFI shall, at a minimum, trigger an increased rate of QA fFile reviews or QA Field reviewsonsite inspections of homes and additional appropriate disciplinary action in accordance with the Provider’s written Rater disciplinary procedures. 904.3.5.5.1 When in the course of quality assurance review, four (4) or more ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.1.1 The Rater shall be placed on probation; 904.3.5.5.1.2 If the noncompliant ratings are due to errors found in QA File review, the Rater’s File QA shall be increased to 15% ratings for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 15% = 7.5 means that 8 QA File reviews shall be completed; 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”; 904.3.5.5.2 If additional noncompliance or major errors are discovered during the period of increased File or Field QA, the Quality Agent shall review 100% of the next five (5) rating files submitted or field inspections by the RFI. If noncompliance or major errors continue to be discovered, the Rater shall be suspended in accordance with the Provider’s written HERS Rater/RFI disciplinary procedure. Response: Reject Reason: The section should be rewritten but not deleted completely but it brings attention to the fact that the file review section should be edited to make it clear that the file should be corrected if errors are found.
904.3.5.5 and subsections
None of the thresholds for levels of non-compliance in this section make sense. We can only surmise that the intent of the thresholds proposed under this section and its subsections assumes that ratings selected for 10% QA File review are being evaluated based on the cumulative change in HERS Index per proposed section 904.3.5.1. However, the 10% QA File Review does not require manipulation of the rating file or a comparison of the pre and post QA HERS Index. The 10% QA File review only requires that, “For of each Confirmed Rating, confirm that the values entered into the HERS Rating Software for all Minimum Rated Features are supported by actual on-site field-verified test data.” That’s all folks. We would propose a change to the language under section 904.3.2.4.3, but no changes are being proposed to the requirements for 10% QA File review. Given this error, this section has too many issues to remain as is and shoudl be struck until new language is proposed for section 904.3.2.4.3.
904.3.5.5904.4.3.4 Multiple instances of non-compliance with 904.4.2.5 QA File and/or QA Field review for a Rater or RFI shall, at a minimum, trigger an increased rate of QA fFile reviews or QA Field reviewsonsite inspections of homes and additional appropriate disciplinary action in accordance with the Provider’s written Rater disciplinary procedures.
904.3.5.5.1 When in the course of quality assurance review, four (4) or more ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur:
904.3.5.5.1.1 The Rater shall be placed on probation;
904.3.5.5.1.2 If the noncompliant ratings are due to errors found in QA File review, the Rater’s File QA shall be increased to 15% ratings for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 15% = 7.5 means that 8 QA File reviews shall be completed;
904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”;
904.3.5.5.2 If additional noncompliance or major errors are discovered during the period of increased File or Field QA, the Quality Agent shall review 100% of the next five (5) rating files submitted or field inspections by the RFI. If noncompliance or major errors continue to be discovered, the Rater shall be suspended in accordance with the Provider’s written HERS Rater/RFI disciplinary procedure.
Reason: The section should be rewritten but not deleted completely but it brings attention to the fact that the file review section should be edited to make it clear that the file should be corrected if errors are found.
Comment #280Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 33-34Paragraph / Figure / Table / Note: 904.3.5.1Comment Intent: Not an ObjectionComment Type: GeneralComment: I have an issue with the following highlighted text: 904.3.5.1 Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores for each energy simulation file. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable cumulative variance never less than four (4) HERS Index points. For example, if an energy simulation file shows an initial HERS Index of 75, the allowable cumulative variance in the HERS Index score is 75 x 5% = 3.75, or an allowable cumulative variance of no more than the 4 HERS Index minimum. If during the QA review, the QA determines that corrections to the energy simulation file were necessary which moved the HERS Index down 2 points and up 3 point, for a cumulative move of 5 HERS Index points, then the rating shall be deemed “non-compliant.” First things first: I don't think the statement "For example...shall be deemed "non-compliant," should be inserted into the standards. I believe it should be released with an SDC 900 Interpretation post, rather than be part of the standards. And yes, I understand SDC 900 did help write these proposed standards. Secondly, and more important in my mind, is the cumulative variance. I understand why, because if a HERS Rater messes up on the DWH and mechanical ventilation, and the corrections cause a cumulative variance of 5 HERS points, there go two big mess ups. I actually think this is a really good idea- it broadens the scope of potential non-compliant files, and can help crack down on people making minor, yet important changes. Proposed Change: 904.3.5.1 Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores for each energy simulation file. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable cumulative variance never less than four (4) HERS Index points. For example, if an energy simulation file shows an initial HERS Index of 75, the allowable cumulative variance in the HERS Index score is 75 x 5% = 3.75, or an allowable cumulative variance of no more than the 4 HERS Index minimum. If during the QA review, the QA determines that corrections to the energy simulation file were necessary which moved the HERS Index down 2 points and up 3 point, for a cumulative move of 5 HERS Index points, then the rating shall be deemed “non-compliant.” Response: Reject Reason: This entire section will be replaced when the file and field review checklist is implemented which will provide consistent methodology
I have an issue with the following highlighted text:
904.3.5.1 Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores for each energy simulation file. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable cumulative variance never less than four (4) HERS Index points.
First things first: I don't think the statement "For example...shall be deemed "non-compliant," should be inserted into the standards. I believe it should be released with an SDC 900 Interpretation post, rather than be part of the standards. And yes, I understand SDC 900 did help write these proposed standards.
Secondly, and more important in my mind, is the cumulative variance. I understand why, because if a HERS Rater messes up on the DWH and mechanical ventilation, and the corrections cause a cumulative variance of 5 HERS points, there go two big mess ups. I actually think this is a really good idea- it broadens the scope of potential non-compliant files, and can help crack down on people making minor, yet important changes.
Reason: This entire section will be replaced when the file and field review checklist is implemented which will provide consistent methodology
Comment #281Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-12Paragraph / Figure / Table / Note: 904.3.5.1Comment Intent: Not an ObjectionComment Type: EditorialComment: Just editorial - missed an "s". Proposed Change: down 2 points and up 3 points, for Response: Reject Reason: This entire section will be replaced when the file and field review checklist is implemented which will provide consistent methodology
Just editorial - missed an "s".
down 2 points and up 3 points, for
Comment #282Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: 904.3.5.1Comment Intent: ObjectionComment Type: TechnicalComment: A large part of why we do QA in our industry is to create a level playing field for all the players. Having lower rates of QA with a criteria that is volume based does not create a level playing field. The proposed section for 904.3.2.2.1 stipulates that only high volume raters get rewarded, which on the surface for lower volume raters does not make sense. Shouldn’t someone who does over 500 confirmed ratings be under more scrutiny than the person who does 50 by virtue of being very busy with rating work and having more room to cut corners? This section refers to not having any errors as defined in section 904.3.5.1. The term errors is not defined here, therefore if this section were to be enacted, errors could be defined by the provider. Some it might mean any error, others it might mean QA failure. Any mistake at all would be more appropriate, but almost impossible to have over 100 reviews without any mistake at all. We all make mistakes and any QAD who goes 100 reviews without finding a single mistake on a rater should be flagged for the quality of their own work. Proposed Change: 904.3.2.2.1 Home Energy Raters who conduct over 500 confirmed ratings in one year and if over a two (2) year period do not have any errors as defined in section 904.3.5.1 during file QA reviews, their file QA review shall be reduced by 25%. If no errors are found in the subsequent two (2) years then the file QA reviews shall be reduced by 50% in the following years. If any errors are found in subsequent years the 10% file QA review threshold will be reinstated. Response: Accept
A large part of why we do QA in our industry is to create a level playing field for all the players. Having lower rates of QA with a criteria that is volume based does not create a level playing field. The proposed section for 904.3.2.2.1 stipulates that only high volume raters get rewarded, which on the surface for lower volume raters does not make sense. Shouldn’t someone who does over 500 confirmed ratings be under more scrutiny than the person who does 50 by virtue of being very busy with rating work and having more room to cut corners?
This section refers to not having any errors as defined in section 904.3.5.1. The term errors is not defined here, therefore if this section were to be enacted, errors could be defined by the provider. Some it might mean any error, others it might mean QA failure. Any mistake at all would be more appropriate, but almost impossible to have over 100 reviews without any mistake at all. We all make mistakes and any QAD who goes 100 reviews without finding a single mistake on a rater should be flagged for the quality of their own work.
Comment #283Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 33Paragraph / Figure / Table / Note: 904.3.5.1Comment Intent: Not an ObjectionComment Type: GeneralComment: The move to +/- 5 % cumulative from +/-3% net has created confusion and needs to be explained in greater detail. In essence, the move is away from total impact in delta (net) to looking at both individual contributions as well as net (cumulative) caused by Rater innacuracies, inconsistnencies, or mistakes. In addition, we recommend adding a consumption delta threshold as an alternative metric. Many programs use modeling to estimate consumption instead of simply relying on HERs scores. Proposed Change: 904.3.5.1 Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index score or more that ten percent (10%)(+/-) of the original consumptiuon estimate in the Performance Summary report for each energy simulation file. Response: Reject Reason: This entire section will be replaced when the file and field review checklist is implemented which will provide consistent methodology
The move to +/- 5 % cumulative from +/-3% net has created confusion and needs to be explained in greater detail. In essence, the move is away from total impact in delta (net) to looking at both individual contributions as well as net (cumulative) caused by Rater innacuracies, inconsistnencies, or mistakes.
In addition, we recommend adding a consumption delta threshold as an alternative metric. Many programs use modeling to estimate consumption instead of simply relying on HERs scores.
904.3.5.1 Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index score or more that ten percent (10%)(+/-) of the original consumptiuon estimate in the Performance Summary report for each energy simulation file.
Comment #284Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-11Paragraph / Figure / Table / Note: 904.3.5.1Comment Intent: ObjectionComment Type: TechnicalComment: Establishing a priority for evaluation would allow all Quality Agents the same protocol for developing the variance. There could be some unintended variation in baseline evaluation (as submitted) to performance testing vs. baseline to envelope deviations for example. If a default protocol is established then all Quality Agents will be using the same protocol for evaluation. Proposed Change: 904.3.5.1 Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores for each energy simulation file. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable cumulative variance never less than four (4) HERS Index points. Evaluation of the variance shall begin in a priority order by evaluation to baseline file (as submitted) intially then deviations to 1) Envelope then 2)Equipment then 3) Infiltration/ventilation then 4) performance testing and finally to 5)other minimum rated features For example, if an energy simulation file shows an initial HERS Index of 75, the allowable cumulative variance in the HERS Index score is 75 x 5% = 3.75, or an allowable cumulative variance of no more than the 4 HERS Index minimum. If during Working Draft WD-02 Chapter Nine RESNET Standards 9-12 the QA review, the QA determines that corrections to the energy simulation file were necessary which moved the HERS Index down 2 points and up 3 point, for a cumulative move of 5 HERS Index points, then the rating shall be deemed “noncompliant.” Response: Reject Reason: This entire section will be replaced when the file and field review checklist is implemented which will provide consistent methodology
Establishing a priority for evaluation would allow all Quality Agents the same protocol for developing the variance. There could be some unintended variation in baseline evaluation (as submitted) to performance testing vs. baseline to envelope deviations for example. If a default protocol is established then all Quality Agents will be using the same protocol for evaluation.
904.3.5.1 Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores for each energy simulation file. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable cumulative variance never less than four (4) HERS Index points. Evaluation of the variance shall begin in a priority order by evaluation to baseline file (as submitted) intially then deviations to 1) Envelope then 2)Equipment then 3) Infiltration/ventilation then 4) performance testing and finally to 5)other minimum rated features For example, if an energy simulation file shows an initial HERS Index of 75, the allowable cumulative variance in the HERS Index score is 75 x 5% = 3.75, or an allowable cumulative variance of no more than the 4 HERS Index minimum. If during Working Draft WD-02 Chapter Nine RESNET Standards 9-12 the QA review, the QA determines that corrections to the energy simulation file were necessary which moved the HERS Index down 2 points and up 3 point, for a cumulative move of 5 HERS Index points, then the rating shall be deemed “noncompliant.”
Comment #285Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 33Paragraph / Figure / Table / Note: 904.3.5.1Comment Intent: ObjectionComment Type: TechnicalComment: There is more to quality assurance of ratings than the cumulative change HERS Index. Also, a cumlative change in HERS Index changes dramatically based on the order in which variations are corrected. This section should be based on a 3 point net or 5 point cumulative index change and a certain amount of signifcant technical discrepancies. The basis for rating compliance has long been a weakness and the proposal to change it to a cumulative index change is a step in the right direction, but since we are at this juncture, let's make it comprehensive and inclusive of more than one way to view a ratiing. Proposed Change: 904.3.5.1 Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not: cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores for each energy simulation file. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable cumulative variance never less greater than four (4) HERS Index points, or; cause a net change of more than 3 HERS Index points, or; have more than 5 significant rating variations, including, but not limited to the following variations: Two or more of the following features is incorrect: Property Address, Builder Info, Rating Organization info, RTIN, Provider ID, Rating Type. Foundation type incorrect Floors on or above grade incorrect Number of bedrooms is incorrect Modeled Climate Location is not best choice available Total CFA, volume, foundation wall, AGW, slab, framed floor, window or ceiling area appears to be incorrect by greater than 10%. More than 2 entries located inaccurately Window adjacent shading properties inaccurately entered on 3 or more windows by one increment or greater Window overhang properties inaccurately entered on 3 or more windows by 1’ or greater for any overhang entry 3 or more window entries oriented inaccurately Any inaccurately modeled assembly which changes the assembly u-value by greater than 15% Any Mechanical System type modeled incorrectly Any Mechanical System entry erroneously added or omitted from the model Any Mechanical System off by greater than 1 efficiency unit Any Mechanical System off by greater than 10 kbtu of capacity Any discrepancy in Mechanical System “capacity weight % load served” or “programmable thermostat” selection Any Duct System entry erroneously added or omitted from the model Duct System Surface Area AND/OR SqFt Served incorrect by greater than 15% Duct System location incorrect by greater than 15% Duct System R-value incorrect by R-2 or greater Duct leakage off by greater than 15% based on info furnished from rater/collected in field Air infiltration off by greater than 15% based on info furnished from rater/collected in field Mechanical ventilation system type inaccurate Mechanical ventilation CFM, efficiency, or wattage incorrect by greater than 25% Refrigerator, dishwasher, or dryer efficiencies off by greater than 20% Clothes washer inaccurately modeled for all features Range/oven AND/OR clothes dryer fuel type incorrect Efficient lighting off by greater than 15% Incorrect modeling of any of the following: interior mass properties, sunspace properties, active solar properties, solar photovoltaic properties. Response: Reject Reason: This entire section will be replaced when the file and field review checklist is implemented which will provide consistent methodology
There is more to quality assurance of ratings than the cumulative change HERS Index. Also, a cumlative change in HERS Index changes dramatically based on the order in which variations are corrected. This section should be based on a 3 point net or 5 point cumulative index change and a certain amount of signifcant technical discrepancies. The basis for rating compliance has long been a weakness and the proposal to change it to a cumulative index change is a step in the right direction, but since we are at this juncture, let's make it comprehensive and inclusive of more than one way to view a ratiing.
904.3.5.1 Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not:
Comment #286Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-11 and 9-12Paragraph / Figure / Table / Note: 904.3.5.1Comment Intent: Not an ObjectionComment Type: TechnicalComment: Aside: There should be a "Comment Intent" that is called "Request for Clarification." Often comments aren't so black and white as "Objection" and "Not an Objection." Often, it's "It depends on what you mean by that." The HERS Index can't vary since it's an Index, by definition. I think the author means that the HERS Index score may vary. Isn't that the terminology we're using these days? When figuring the cumulative HERS Index score shift, in what order must the changes be applied? This process needs to be clear and specific so that it is applied consistently and fairly during every single QA File review by every Quality Agent. Proposed Change: 904.3.5.1 Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of from the original HERS Index scores for each energy simulation file. When calculating the HERS Index score point variance allowed for a given score Index, round down to the nearest whole Index point, with the allowable cumulative variance never less than four (4) HERS Index points. For example, if an energy simulation file shows an initial HERS Index of 75, the allowable cumulative variance in the HERS Index score is 75 x 5% = 3.75, or an allowable cumulative variance of no more than the 4 HERS Index minimum. If, during the QA review, the QA determines that corrections to the energy simulation file were necessary and they which moved the HERS Index score down 2 points and up 3 points, for a cumulative move of 5 HERS Index points, then the rRating shall be deemed “noncompliant.” Response: Accept Reason: Accept in principle. Entire section will be removed
Aside: There should be a "Comment Intent" that is called "Request for Clarification." Often comments aren't so black and white as "Objection" and "Not an Objection." Often, it's "It depends on what you mean by that."
The HERS Index can't vary since it's an Index, by definition. I think the author means that the HERS Index score may vary. Isn't that the terminology we're using these days?
When figuring the cumulative HERS Index score shift, in what order must the changes be applied? This process needs to be clear and specific so that it is applied consistently and fairly during every single QA File review by every Quality Agent.
904.3.5.1 Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of from the original HERS Index scores for each energy simulation file. When calculating the HERS Index score point variance allowed for a given score Index, round down to the nearest whole Index point, with the allowable cumulative variance never less than four (4) HERS Index points.
For example, if an energy simulation file shows an initial HERS Index of 75, the allowable cumulative variance in the HERS Index score is 75 x 5% = 3.75, or an allowable cumulative variance of no more than the 4 HERS Index minimum. If, during the QA review, the QA determines that corrections to the energy simulation file were necessary and they which moved the HERS Index score down 2 points and up 3 points, for a cumulative move of 5 HERS Index points, then the rRating shall be deemed “noncompliant.”
Comment #287Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-11Paragraph / Figure / Table / Note: 904.3.5.1Comment Intent: ObjectionComment Type: GeneralComment: Cumulative variance is much more restrictive then “net” and this will increase the amount of QA failures and thus driving up QA costs. Recommend this is removed or the cumulative limit be raised much further. Implementation obviously will be difficult. Cumulative error accounting is not precisely defined. To be reasonanble, the standard should define what minimum size error is to counted. If any and all tiny variations between QA and Rater file are summed up there could be a large number of small variances adding up to more than 4 points. It's like asking how long a shoreline is. The length depends on how small a unit you measure. ALSO what constitutes an error vs a legitimate difference needs to be defined. For example R-value per inch claimed can have a range of acceptable values. I'd recommend that we remain with the current 3% net change limit and add a 5% deviation limit for the separate heating, cooling and hot water loads. I think this would achieve the same intent with more precision and none of the complications that come from trying to determine the smallest variations that should be included in a cumulative accounting of differences Proposed Change: 904.3.5.1 Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores for each energy simulation file. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable cumulative variance never less than four (4) HERS Index points. For example, if an energy simulation file shows an initial HERS Index of 75, the allowable cumulative variance in the HERS Index score is 75 x 5% = 3.75, or an allowable cumulative variance of no more than the 4 HERS Index minimum. If duringe requirements for other Provider categories that may apply to the organization. Confirm that HERS Index scores for each home QA field reviewed are no more than three percent (3%) (+/-) different than the HERS Index result as determined by the QAD. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable variance never less than two (2) HERS Index points. Furthermore, confirm than the sepreate heating, cooling and hot water loads each do not vary by more than 5% between the Rater value and the QAD values. Response: Reject Reason: This entire section will be replaced when the file and field review checklist is implemented which will provide consistent methodology
Cumulative variance is much more restrictive then “net” and this will increase the amount of QA failures and thus driving up QA costs. Recommend this is removed or the cumulative limit be raised much further. Implementation obviously will be difficult.
Cumulative error accounting is not precisely defined. To be reasonanble, the standard should define what minimum size error is to counted. If any and all tiny variations between QA and Rater file are summed up there could be a large number of small variances adding up to more than 4 points. It's like asking how long a shoreline is. The length depends on how small a unit you measure. ALSO what constitutes an error vs a legitimate difference needs to be defined. For example R-value per inch claimed can have a range of acceptable values.
I'd recommend that we remain with the current 3% net change limit and add a 5% deviation limit for the separate heating, cooling and hot water loads. I think this would achieve the same intent with more precision and none of the complications that come from trying to determine the smallest variations that should be included in a cumulative accounting of differences
904.3.5.1 Confirm that corrections to energy simulation files, as determined by the Quality Agent, do not cumulatively move the HERS Index scores for each home QA Field reviewed more than five percent (5%) (+/-) of the original HERS Index scores for each energy simulation file. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable cumulative variance never less than four (4) HERS Index points. For example, if an energy simulation file shows an initial HERS Index of 75, the allowable cumulative variance in the HERS Index score is 75 x 5% = 3.75, or an
allowable cumulative variance of no more than the 4 HERS Index minimum. If duringe requirements for other Provider categories that may apply to the organization.
Confirm that HERS Index scores for each home QA field reviewed are no more than three percent (3%) (+/-) different than the HERS Index result as determined by the QAD. When calculating the HERS Index point variance allowed for a given Index, round down to the nearest whole Index point, with the allowable variance never less than two (2) HERS Index points.
Furthermore, confirm than the sepreate heating, cooling and hot water loads each do not vary by more than 5% between the Rater value and the QAD values.
Comment #288Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-12Paragraph / Figure / Table / Note: 904.3.5.2Comment Intent: ObjectionComment Type: GeneralComment: Current text reads: Under thesupervision of the QA Agent, non-compliant ratings shall be corrected to come into compliance with RESNET technical guidlines. Suggested text: The QA Agent shall review the cause of the non-compliant rating(s) with the HERS rater. If the cause of the non-compliance is discovered to be systemic, the QA agent shall implement the actions described in Sections 904.3.5.3-904.3.5.5.1.4. The measures RESNET is suggesting for non-compliance will be costly to implement for many providers/raters. It seems reasonable to determine if the issue is an ongoing problem or systemic or is it just a transcription error or one time testing errror etc. Response: Reject Reason: The existing language is needed in case of systemic issues; a non-compliant rating should not be entered into the Registry.
Current text reads: Under thesupervision of the QA Agent, non-compliant ratings shall be corrected to come into compliance with RESNET technical guidlines.
Suggested text: The QA Agent shall review the cause of the non-compliant rating(s) with the HERS rater. If the cause of the non-compliance is discovered to be systemic, the QA agent shall implement the actions described in Sections 904.3.5.3-904.3.5.5.1.4.
The measures RESNET is suggesting for non-compliance will be costly to implement for many providers/raters. It seems reasonable to determine if the issue is an ongoing problem or systemic or is it just a transcription error or one time testing errror etc.
Reason: The existing language is needed in case of systemic issues; a non-compliant rating should not be entered into the Registry.
Comment #289Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-12Paragraph / Figure / Table / Note: 904.3.5.3Comment Intent: ObjectionComment Type: GeneralComment: Since the purpose of this end of the quality process is to detect failures, identify the cause, and develop corrective solutions, the role of the quality control agent is NOT punitive. Their job is to coach, mentor, help disseminate best practices across the industry, uncover why failures happened, and help prevent those failures from happening again across the entire industry. When we discover failures, RESNET should not take punitive action against Raters who cooperate with the investigation. However, the rating company is free to do what they like under applicable laws with their employee. Within this type of framework, it becomes easier to incentivize the desired behavior while leveraging disincentives against rating companies that are engaging in risky behavior. RESNET should stop treating all Raters as equals—they aren’t. Proposed Change: Strike the following in its entirety: 904.3.5.3904.4.3.2 The Quality Agent Designee shall develop and implement a corrective action plan for the HERS Rater of the rating that addresses any underlying problems that led to the non-compliant rating. Whenever feasible, corrective action plans shall include “shadowing” and mentoring of the HERS Rater to better ensure corrections in their rating process and procedures. Replace with: 904.3.5 The Quality Agent shall develop aand implement a coaching plan for the HERS Rater that addresses the underlying problems that led to the non-compliant rating. The coaching plan shall include mentoring the HERS Rater. Response: Accept Reason: Accept in principle- change “coaching” plan to “corrective action” plan
Since the purpose of this end of the quality process is to detect failures, identify the cause, and develop corrective solutions, the role of the quality control agent is NOT punitive. Their job is to coach, mentor, help disseminate best practices across the industry, uncover why failures happened, and help prevent those failures from happening again across the entire industry. When we discover failures, RESNET should not take punitive action against Raters who cooperate with the investigation. However, the rating company is free to do what they like under applicable laws with their employee. Within this type of framework, it becomes easier to incentivize the desired behavior while leveraging disincentives against rating companies that are engaging in risky behavior. RESNET should stop treating all Raters as equals—they aren’t.
904.3.5.3904.4.3.2 The Quality Agent Designee shall develop and implement a corrective action plan for the HERS Rater of the rating that addresses any underlying problems that led to the non-compliant rating. Whenever feasible, corrective action plans shall include “shadowing” and mentoring of the HERS Rater to better ensure corrections in their rating process and procedures.
904.3.5 The Quality Agent shall develop aand implement a coaching plan for the HERS Rater that addresses the underlying problems that led to the non-compliant rating. The coaching plan shall include mentoring the HERS Rater.
Reason: Accept in principle- change “coaching” plan to “corrective action” plan
Comment #290Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 34Paragraph / Figure / Table / Note: 904.3.5.3Comment Intent: Not an ObjectionComment Type: GeneralComment: In the section below, it is not clear who would be dowing the shadowing and mentoring. Please clarify. Proposed Change: The Quality Agent shall develop and implement a corrective action plan for the HERS Rater of the rating that addresses any underlying problems that led to the non-compliant rating. Whenever feasible, corrective action plans shall include “shadowing” and mentoring [by the Rating Provider or the QA Provider?] of the HERS Rater to better ensure corrections in their rating process and procedures. Response: Reject Reason: See changes made in comment #288
In the section below, it is not clear who would be dowing the shadowing and mentoring. Please clarify.
The Quality Agent shall develop and implement a corrective action plan for the HERS Rater of the rating that addresses any underlying problems that led to the non-compliant rating. Whenever feasible, corrective action plans shall include “shadowing” and mentoring [by the Rating Provider or the QA Provider?] of the HERS Rater to better ensure corrections in their rating process and procedures.
Reason: See changes made in comment #288
Comment #291Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-12,9-13Paragraph / Figure / Table / Note: 904.3.5.5Comment Intent: ObjectionComment Type: TechnicalComment: Raters who should perform 101 ratings and 500 ratings should not be allowed the held “four (4) or more” errors standards. An allowance based on %, which includes minimum backstops, is more equitable to all raters. I also recommend aligning the section structure of this portion of the Standard to help alleviate confusion. This can be accomplished in the way suggested below OR by making 904.3.5.5.2 an Exception to 904.3.5.5.1. Proposed Change: 904.3.5.5 Multiple instances of non-compliance with QA File and/or QA Field review for a Rater or RFI shall trigger an increased rate of QA File reviews or QA Field reviews. 904.3.5.5.1 When in the course of quality assurance review, four (4) or more ratings, as outlined in 904.3.5.5.2 and 904.3.5.5.3, in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.1.1 The Rater shall be placed on probation; 904.3.5.5.1.2 If the noncompliant ratings are due to errors found in QA File review, the Rater’s File QA shall be increased to 15% ratings for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 15% = 7.5 means that 8 QA File reviews shall be completed; 904.3.5.5.1.3 When appropriate (e.g. the HERS Rater/RFI previously struggled with field compliance, a piece of equipment is used in the rating that is not commonly found in the market or used by a builder, field test results are out of typical range for the market, etc.), a QA Field review shall be completed by the Quality Agent on the ratings that were out of compliance by more than 5%; 904.3.5.5.1.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI Field QA shall be increased to 5% for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 5% = 2.5 means that 3 QA Field reviews shall be completed. 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”; 904.3.5.5.3 The threshold for Raters and RFI’s who performed work on 100 homes or greater in the prior or current twelve (12) month period from January 1st through December 31st shall be “three (3) or more ratings or 1% of ratings, which ever is greater”; Response: Accept
Raters who should perform 101 ratings and 500 ratings should not be allowed the held “four (4) or more” errors standards. An allowance based on %, which includes minimum backstops, is more equitable to all raters.
I also recommend aligning the section structure of this portion of the Standard to help alleviate confusion. This can be accomplished in the way suggested below OR by making 904.3.5.5.2 an Exception to 904.3.5.5.1.
904.3.5.5 Multiple instances of non-compliance with QA File and/or QA Field review for a Rater or RFI shall trigger an increased rate of QA File reviews or QA Field reviews. 904.3.5.5.1 When in the course of quality assurance review, four (4) or more ratings, as outlined in 904.3.5.5.2 and 904.3.5.5.3, in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.1.1 The Rater shall be placed on probation; 904.3.5.5.1.2 If the noncompliant ratings are due to errors found in QA File review, the Rater’s File QA shall be increased to 15% ratings for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 15% = 7.5 means that 8 QA File reviews shall be completed; 904.3.5.5.1.3 When appropriate (e.g. the HERS Rater/RFI previously struggled with field compliance, a piece of equipment is used in the rating that is not commonly found in the market or used by a builder, field test results are out of typical range for the market, etc.), a QA Field review shall be completed by the Quality Agent on the ratings that were out of compliance by more than 5%; 904.3.5.5.1.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI Field QA shall be increased to 5% for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 5% = 2.5 means that 3 QA Field reviews shall be completed. 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”; 904.3.5.5.3 The threshold for Raters and RFI’s who performed work on 100 homes or greater in the prior or current twelve (12) month period from January 1st through December 31st shall be “three (3) or more ratings or 1% of ratings, which ever is greater”;
Comment #292Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-12Paragraph / Figure / Table / Note: 904.3.5.5.1Comment Intent: ObjectionComment Type: TechnicalComment: The RESNET Standards do not cover "diagnostic" testing. Proposed Change: Strike and replace with the following: 904.3.5.5.1 When in the course of quality assurance review, four (4) or more ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: Response: Accept
The RESNET Standards do not cover "diagnostic" testing.
Strike and replace with the following:
Comment #293Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 35Paragraph / Figure / Table / Note: 904.3.5.5.1Comment Intent: ObjectionComment Type: TechnicalComment: 904.3.5.5.1 When in the course of quality assurance review, four (4) or more ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”; The highlighted values should be appropriately weighted based off a percentage rather than a set number. Four ratings found out of compliance does not equally represent the proficiency of a HERS rater with an annual total of 200 ratings vs. a rater with 800 ratings. A percentage addresses both ends of the spectrum by creating a fair playing field and preventing raters from being penalized solely based on having higher business volume. I suggest 2%, since that is what 904.3.5.5.2 is based off of. If RESNET disagrees with the chosen 2%, please consider changing to a different percentage for the next round of public comments (as long as it's a percentage and not a set number) I struck section 904.3.5.5.2 because section 904.3.5.3 covers RFI's and Raters Proposed Change: 904.3.5.5.1 When in the course of quality assurance review, four (4) or more 2% or greater (rounded up) ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”; Response: Reject Reason: Accepted new proposed thresholds in comment #290
The highlighted values should be appropriately weighted based off a percentage rather than a set number. Four ratings found out of compliance does not equally represent the proficiency of a HERS rater with an annual total of 200 ratings vs. a rater with 800 ratings. A percentage addresses both ends of the spectrum by creating a fair playing field and preventing raters from being penalized solely based on having higher business volume.
I suggest 2%, since that is what 904.3.5.5.2 is based off of. If RESNET disagrees with the chosen 2%, please consider changing to a different percentage for the next round of public comments (as long as it's a percentage and not a set number)
I struck section 904.3.5.5.2 because section 904.3.5.3 covers RFI's and Raters
904.3.5.5.1 When in the course of quality assurance review, four (4) or more 2% or greater (rounded up) ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur:
Reason: Accepted new proposed thresholds in comment #290
Comment #294Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 35Paragraph / Figure / Table / Note: 904.3.5.5.1Comment Intent: ObjectionComment Type: TechnicalComment: 904.3.5.5.1 When in the course of quality assurance review, four (4) or more ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”; The highlighted values should be appropriately weighted based off a percentage rather than a set number. Four ratings found out of compliance does not equally represent the proficiency of a HERS rater with an annual total of 200 ratings vs. a rater with 800 ratings. A percentage addresses both ends of the spectrum by creating a fair playing field and preventing raters from being penalized solely based on having higher business volume. I suggest 4%, since that is what 904.3.5.5.1 is based off of (assume <100 ratings). If RESNET disagrees with the chosen 4%, please consider changing to a different percentage for the next round of public comments (as long as it's a percentage and not a set number) I struck section 904.3.5.5.2 because section 904.3.5.3 covers RFI's and Raters Proposed Change: 904.3.5.5.1 When in the course of quality assurance review, four (4) or more 4% or greater (rounded up) ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”; Response: Reject Reason: Accepted new proposed thresholds in comment #290
I suggest 4%, since that is what 904.3.5.5.1 is based off of (assume <100 ratings). If RESNET disagrees with the chosen 4%, please consider changing to a different percentage for the next round of public comments (as long as it's a percentage and not a set number)
904.3.5.5.1 When in the course of quality assurance review, four (4) or more 4% or greater (rounded up) ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur:
Comment #295Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 34Paragraph / Figure / Table / Note: 904.3.5.5.1 ; 904.3.5.5.2Comment Intent: ObjectionComment Type: EditorialComment: Comment: 904.3.5.5.1 When in the course of quality assurance review, four (4) or more ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”; The highlighted values should be appropriately weighted based off a percentage rather than a set number. Four ratings found out of compliance does not equally represent the proficiency of a HERS rater with an annual total of 200 ratings vs. a rater with 800 ratings. 904.3.5.5.2 does a good job addressing the issue, but there is nothing to address raters who handle a much larger volume of ratings annually. Proposed Change: 904.3.5.5.1 When in the course of quality assurance review, greater than 1% of ratings(rounded up) four (4) or more ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10% (e.g. 100 ratings = 2 or more, 101 = 3 or more, 500 = 6 or more), or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”; The threshold should be moved to: (>) greater than 1% (rounded up to the nearest whole number) of ratings found out of compliance by more than 5% when determining when probation becomes necessary. A percentage addresses both ends of the spectrum by creating a fair playing field and preventing raters from being penalized solely based on having higher business volume. Response: Reject Reason: Accepted new proposed thresholds in comment #290
Comment: 904.3.5.5.1 When in the course of quality assurance review, four (4) or more ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”;
The highlighted values should be appropriately weighted based off a percentage rather than a set number. Four ratings found out of compliance does not equally represent the proficiency of a HERS rater with an annual total of 200 ratings vs. a rater with 800 ratings. 904.3.5.5.2 does a good job addressing the issue, but there is nothing to address raters who handle a much larger volume of ratings annually.
904.3.5.5.1 When in the course of quality assurance review, greater than 1% of ratings(rounded up) four (4) or more ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10% (e.g. 100 ratings = 2 or more, 101 = 3 or more, 500 = 6 or more), or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”;
The threshold should be moved to: (>) greater than 1% (rounded up to the nearest whole number) of ratings found out of compliance by more than 5% when determining when probation becomes necessary. A percentage addresses both ends of the spectrum by creating a fair playing field and preventing raters from being penalized solely based on having higher business volume.
Comment #296Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-12 and 9-13Paragraph / Figure / Table / Note: 904.3.5.5.1 and 904.3.5.5.2Comment Intent: Not an ObjectionComment Type: TechnicalComment: The way these paragraphs are numbered could be considered to make them mutually exclusive. I believe the intent was for the low volume raters to be closer to the allowed percentage of error as higher volume raters by lowering the threshold. This should just be incorporated into 904.3.5.5.1 rather than stuck in its own section. Proposed Change: 904.3.5.5.1 When in the course of quality assurance review, four (4) or more ratings (two (2) or more ratings for those who performed work on fewer than 100 homes) in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”; Response: Reject Reason: Accepted new proposed thresholds in comment #290
The way these paragraphs are numbered could be considered to make them mutually exclusive. I believe the intent was for the low volume raters to be closer to the allowed percentage of error as higher volume raters by lowering the threshold. This should just be incorporated into 904.3.5.5.1 rather than stuck in its own section.
904.3.5.5.1 When in the course of quality assurance review, four (4) or more ratings (two (2) or more ratings for those who performed work on fewer than 100 homes) in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur:
Comment #297Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-12Paragraph / Figure / Table / Note: 904.3.5.5.1 and subsectionsComment Intent: Not an ObjectionComment Type: EditorialComment: Cite other sections of the Standard whenever possible in order to avoid redundancy. The highlighted section should be defined only once in these Standards instead of being inserted into a number of different provisions in a disconnected way. Is it 5% or 10%? Pick one. What happens at 4%? 7%? 11%? Proposed Change: 904.3.5.5.1 When, in the course of quality assurance review, four (4) or more ratings in a twelve (12) month period, from January 1st through December 31st, are found to be out of compliance with section 904.3.5.1by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.1.1 The Rater shall be placed on probation; 904.3.5.5.1.2 If the noncompliant ratings are due to errors found in QA File review, the Rater’s File QA shall be increased to 15% of their Rratings for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 15% = 7.5 means that 8 QA File reviews shall be completed; 904.3.5.5.1.3 When appropriate (e.g. the HERS Rater/RFI previously struggled with field compliance, a piece of equipment is used in the rating that is not commonly found in the market or used by a builder, field test results are out of typical range for the market, etc.), a QA Field review shall be completed by the Quality Agent on the ratings that were out of compliance by more than 5% to 10%; Response: Reject Reason: The percent threshold in this section will be replaced when the file and field review checklist is implemented which will provide consistent methodology
Cite other sections of the Standard whenever possible in order to avoid redundancy.
The highlighted section should be defined only once in these Standards instead of being inserted into a number of different provisions in a disconnected way.
Is it 5% or 10%? Pick one. What happens at 4%? 7%? 11%?
904.3.5.5.1 When, in the course of quality assurance review, four (4) or more ratings in a twelve (12) month period, from January 1st through December 31st, are found to be out of compliance with section 904.3.5.1by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur:
904.3.5.5.1.2 If the noncompliant ratings are due to errors found in QA File review, the Rater’s File QA shall be increased to 15% of their Rratings for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 15% = 7.5 means that 8 QA File reviews shall be completed;
904.3.5.5.1.3 When appropriate (e.g. the HERS Rater/RFI previously struggled with field compliance, a piece of equipment is used in the rating that is not commonly found in the market or used by a builder, field test results are out of typical range for the market, etc.), a QA Field review shall be completed by the Quality Agent on the ratings that were out of compliance by more than 5% to 10%;
Reason: The percent threshold in this section will be replaced when the file and field review checklist is implemented which will provide consistent methodology
Comment #298Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 34Paragraph / Figure / Table / Note: 904.3.5.5.1.2/3Comment Intent: ObjectionComment Type: TechnicalComment: • 904.3.5.5.1.2 Strike out this comment. This is a mistake that keeps happening as QA for file review does not require an analysis of index variation based on the review of the file. This has not been the case and is still not the case in this standard and thus the reference to errors if the file review should be deleted. Proposed Change: 904.3.5.5.1.2 If the noncompliant ratings are due to errors found in QA File review, the Rater’s File QA shall be increased to 15% ratings for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 15% = 7.5 means that 8 QA File reviews shall be completed; Response: Reject Reason: Non-compliant ratings should not be uploaded to the Registry.
• 904.3.5.5.1.2 Strike out this comment. This is a mistake that keeps happening as QA for file review does not require an analysis of index variation based on the review of the file. This has not been the case and is still not the case in this standard and thus the reference to errors if the file review should be deleted.
Reason: Non-compliant ratings should not be uploaded to the Registry.
Comment #299Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-13Paragraph / Figure / Table / Note: 904.3.5.5.1.4Comment Intent: ObjectionComment Type: GeneralComment: QA Providers cannot enforce QA requirements on RFIs. That is the responsibility of the Raters who oversee the work of the RFI. RESNET cannot require QA Providers to perform QA on individuals the QA Provider does not have, and is not required to have, a contractual relationship with. This element is unenforceable. Proposed Change: Strike and replace with the following: 904.3.5.5.1.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI Field QA shall be increased to 5% for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 5% = 2.5 means that 3 QA Field reviews shall be completed. Response: Reject Reason: Raises issue that the standards should address a contractual relationship with the rater and the RFI. Staff will draft language to address this issue.
QA Providers cannot enforce QA requirements on RFIs. That is the responsibility of the Raters who oversee the work of the RFI. RESNET cannot require QA Providers to perform QA on individuals the QA Provider does not have, and is not required to have, a contractual relationship with. This element is unenforceable.
904.3.5.5.1.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI Field QA shall be increased to 5% for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 5% = 2.5 means that 3 QA Field reviews shall be completed.
Reason: Raises issue that the standards should address a contractual relationship with the rater and the RFI. Staff will draft language to address this issue.
Comment #300Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 35Paragraph / Figure / Table / Note: 904.3.5.5.1.4Comment Intent: ObjectionComment Type: TechnicalComment: Raising field QA requirements from 1% to 5% is disproportional to the penalty that File QA noncompliance faces (10% to 15%, with is 1.5x) Example: original to penalty amount (suggested 5%) i. 0-100 ratings (1 to 5 Field QA) ii. 101-200 ratings (2 to 10 Field QA) iii. 201-300 ratings (3 to 15 Field QA) I suggest to make the penality proportional to File QA, which would be raising the amount of QA by 1.5x, or 1.5% or 2 ratings, whichever is larger (instead of 1%) i. 0-100 ratings (1 to 2 Field QA) ii. 101-200 ratings (2 to 3 Field QA) iii. 201-300 ratings (3 to 5 Field QA) Proposed Change: 904.3.5.5.1.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI Field QA shall be increased to 1.55% for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 5% = 2.5 means that 3 QA Field reviews shall be completed. Response: Accept
Raising field QA requirements from 1% to 5% is disproportional to the penalty that File QA noncompliance faces (10% to 15%, with is 1.5x)
Example: original to penalty amount (suggested 5%)
i. 0-100 ratings (1 to 5 Field QA) ii. 101-200 ratings (2 to 10 Field QA) iii. 201-300 ratings (3 to 15 Field QA)
I suggest to make the penality proportional to File QA, which would be raising the amount of QA by 1.5x, or 1.5% or 2 ratings, whichever is larger (instead of 1%)
i. 0-100 ratings (1 to 2 Field QA) ii. 101-200 ratings (2 to 3 Field QA) iii. 201-300 ratings (3 to 5 Field QA)
904.3.5.5.1.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI Field QA shall be increased to 1.55% for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 5% = 2.5 means that 3 QA Field reviews shall be completed.
Comment #301Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 35Paragraph / Figure / Table / Note: 904.3.5.5.1.4Comment Intent: ObjectionComment Type: TechnicalComment: This suggestion is if RESNET rejected comment #223, due to it not being strigent enough Proposed Change: 904.3.5.5.1.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI Field QA shall be increased to 2% 5% for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 5% = 2.5 means that 3 QA Field reviews shall be completed. Response: Reject Reason: Accepted percentage in #299
This suggestion is if RESNET rejected comment #223, due to it not being strigent enough
904.3.5.5.1.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI Field QA shall be increased to 2% 5% for the next twelve (12) month period. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 5% = 2.5 means that 3 QA Field reviews shall be completed.
Reason: Accepted percentage in #299
Comment #302Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-13Paragraph / Figure / Table / Note: 904.3.5.5.1.4Comment Intent: Not an ObjectionComment Type: EditorialComment: The addition of the word "period" creates confusion in this paragraph. Should the increased review be for the next 12 consecutive months beginning immediately or for the next January - December period? I believe the intent is for the increased review to begin immediately. Proposed Change: 904.3.5.5.1.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI Field QA shall be increased to 5% for the next twelve (12) months period. OR 904.3.5.5.1.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI Field QA shall be increased to 5% for the next twelve (12) consecutive months period. Response: Accept
The addition of the word "period" creates confusion in this paragraph. Should the increased review be for the next 12 consecutive months beginning immediately or for the next January - December period? I believe the intent is for the increased review to begin immediately.
904.3.5.5.1.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI Field QA shall be increased to 5% for the next twelve (12) months period.
904.3.5.5.1.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI Field QA shall be increased to 5% for the next twelve (12) consecutive months period.
Comment #303Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 34Paragraph / Figure / Table / Note: 904.3.5.5.1; 904.3.5.5.2Comment Intent: ObjectionComment Type: EditorialComment: 904.3.5.5.1 When in the course of quality assurance review, four (4) or more ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”; The highlighted values should be appropriately weighted based off a percentage rather than a set number. Four ratings found out of compliance does not equally represent the proficiency of a HERS rater with an annual total of 200 ratings vs. a rater with 800 ratings. 904.3.5.5.2 does a good job addressing the issue, but there is nothing to address raters who handle a much larger volume of ratings annually. Proposed Change: 904.3.5.5.1 When in the course of quality assurance review, greater than 1% of ratings(rounded up) four (4) or more ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10% (e.g. 100 ratings = 2 or more, 101 = 3 or more, 500 = 6 or more), or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”; The threshold should be moved to: (>) greater than 1% (rounded up to the nearest whole number) of ratings found out of compliance by more than 5% when determining when probation becomes necessary. A percentage addresses both ends of the spectrum by creating a fair playing field and preventing raters from being penalized solely based on having higher business volume. Response: Reject Reason: Accepted new proposed thresholds in comment #290
904.3.5.5.1 When in the course of quality assurance review, four (4) or more ratings in a twelve (12) month period from January 1st through December 31st are found to be out of compliance by more than 5% to 10%, or the Quality Agent determines that field work (e.g. diagnostic testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”;
Comment #304Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-13Paragraph / Figure / Table / Note: 904.3.5.5.2Comment Intent: ObjectionComment Type: GeneralComment: With the use of the work "shall" this section requires suspension in accordance with the Provider's written HERS Rater/RFI disciplinary procedure. However, there is no requirement in Section 103.4.9.3.2 for mandatory suspension. The proposed change, makes this section consistent that of 103.4.9.3.2. Proposed Change: 904.3.5.5.2 If additional noncompliance or major errors are discovered during the period of increased File or Field QA, the Quality Agent shall review 100% of the next five (5) rating files submitted or field inspections by the RFI. If noncompliance or major errors continue to be discovered, the Rater may shall be suspended in accordance with the Provider’s written HERS Rater/RFI disciplinary procedure. Response: Accept
With the use of the work "shall" this section requires suspension in accordance with the Provider's written HERS Rater/RFI disciplinary procedure. However, there is no requirement in Section 103.4.9.3.2 for mandatory suspension.
The proposed change, makes this section consistent that of 103.4.9.3.2.
904.3.5.5.2 If additional noncompliance or major errors are discovered during the period of increased File or Field QA, the Quality Agent shall review 100% of the next five (5) rating files submitted or field inspections by the RFI. If noncompliance or major errors continue to be discovered, the Rater may shall be suspended in accordance with the Provider’s written HERS Rater/RFI disciplinary procedure.
Comment #305Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-13Paragraph / Figure / Table / Note: 904.3.5.5.2Comment Intent: ObjectionComment Type: GeneralComment: QA Providers cannot enforce QA requirements on RFIs. That is the responsibility of the Raters who oversee the work of the RFI. RESNET cannot require QA Providers to perform QA on individuals the QA Provider does not have, and is not required to have, a contractual relationship with. This element is unenforceable. Proposed Change: Strike and replace with the following: 904.3.5.5.2 The threshold for Raters and RFI’s who performed work on fewer than 100 homes in the prior or current twelve (12) month period from January 1st through December 31st shall be “two (2) or more ratings”; Response: Reject Reason: Raises issue that the standards should address a contractual relationship with the rater and the RFI. Staff will draft language to address this issue.
Comment #306Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-13Paragraph / Figure / Table / Note: 904.3.5.5.2Comment Intent: ObjectionComment Type: EditorialComment: This section is numbered incorrectly. Proposed Change: Strike and replace with the following: 904.3.5.5.23 If additional noncompliance or major errors are discovered during the period of increased File or Field QA, the Quality Agent shall review 100% of the next five (5) rating files submitted or field inspections by the RFI. If noncompliance or major errors continue to be discovered, the Rater shall be suspended in accordance with the Provider’s written HERS Rater/RFI disciplinary procedure. Response: Accept Reason: Staff will review numbering and grammar prior to publication
This section is numbered incorrectly.
904.3.5.5.23 If additional noncompliance or major errors are discovered during the period of increased File or Field QA, the Quality Agent shall review 100% of the next five (5) rating files submitted or field inspections by the RFI. If noncompliance or major errors continue to be discovered, the Rater shall be suspended in accordance with the Provider’s written HERS Rater/RFI disciplinary procedure.
Reason: Staff will review numbering and grammar prior to publication
Comment #307Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-13Paragraph / Figure / Table / Note: 904.3.5.5.2Comment Intent: ObjectionComment Type: GeneralComment: QA Providers cannot be required to perform quality management on RFIs since there is no required contractual relationship between the QA Provider and the RFI. That relationship is covered by the Standards which assign oversight to the Rater the RFI works for. Proposed Change: Strike and replace with the following: 904.3.5.5.23 If additional noncompliance or major errors are discovered during the period of increased File or Field QA, the Quality Agent shall review 100% of the next five (5) rating files submitted or field inspections by the RFI. If noncompliance or major errors continue to be discovered, the Rater shall be suspended in accordance with the Provider’s written HERS Rater/RFI disciplinary procedure. Response: Reject Reason: Raises issue that the standards should address a contractual relationship with the rater and the RFI. Staff will draft language to address this issue.
QA Providers cannot be required to perform quality management on RFIs since there is no required contractual relationship between the QA Provider and the RFI. That relationship is covered by the Standards which assign oversight to the Rater the RFI works for.
Comment #308Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-13Paragraph / Figure / Table / Note: 904.3.5.5.2Comment Intent: Not an ObjectionComment Type: TechnicalComment: Are RFIs required to notify Providers about their upcoming inspections? If not, how would Providers know when the RFI's next field inspections occur? I don't understand how this requirement would be put into practice. Proposed Change: 904.3.5.5.2 If additional noncompliance or major errors are discovered during the period of increased File or Field QA, the Quality Agent shall review 100% of the next five (5) rating files submitted or field inspections by the RFI. If noncompliance or major errors continue to be discovered, the Rater shall be suspended in accordance with the Provider’s written HERS Rater/RFI disciplinary procedure. Response: Accept Reason: Accept in principle Edits- replace “by the RFI” with “conducted” change “shall” to “may” per comment #303
Are RFIs required to notify Providers about their upcoming inspections?
If not, how would Providers know when the RFI's next field inspections occur?
I don't understand how this requirement would be put into practice.
Reason: Accept in principle
Edits- replace “by the RFI” with “conducted” change “shall” to “may” per comment #303
Comment #309Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 35Paragraph / Figure / Table / Note: 904.4Comment Intent: Not an ObjectionComment Type: GeneralComment: This entire section is very vague and leaves many questions to the reader. How are these determined? Is the bar static or does it move at the whim of RESNET QA Manager or other entity (will Providers be graded progressively tougher/easier over time? Will this information be made visible to EEPs and other partners? Should EEPs and other stakeholders be reporting to RESNET when Providers are not meeting program requirements? Proposed Change: It is the expectation of RESNET that Providers fully comply with all the requirements set forth in these Standards. Discovery of one or more areas of non-compliance via the RESNET Quality Assurance process, reporting by a Quality Agent as part of the Provider’s Quality Assurance process, or in the course of RESNET’s research of an ethics or consumer complaint will result in the Quality Agent working with a Provider to come back into compliance. However, on occasion, there may be instances where actions by a Provider are truly egregious and, as such, would be deemed to be “significant non-compliance”. This Section seeks to define the thresholds when actions by a Provider are deemed to be significant non-compliance, thereby requiring that the Quality Agent report the significant non-compliance to RESNET and additional action by RESNET may be taken. Response: Reject Reason: Proposed change is consistent with existing language
This entire section is very vague and leaves many questions to the reader.
How are these determined? Is the bar static or does it move at the whim of RESNET QA Manager or other entity (will Providers be graded progressively tougher/easier over time? Will this information be made visible to EEPs and other partners? Should EEPs and other stakeholders be reporting to RESNET when Providers are not meeting program requirements?
It is the expectation of RESNET that Providers fully comply with all the requirements set forth in these Standards. Discovery of one or more areas of non-compliance via the RESNET Quality Assurance process, reporting by a Quality Agent as part of the Provider’s Quality Assurance process, or in the course of RESNET’s research of an ethics or consumer complaint will result in the Quality Agent working with a Provider to come back into compliance. However, on occasion, there may be instances where actions by a Provider are truly egregious and, as such, would be deemed to be “significant non-compliance”. This Section seeks to define the thresholds when actions by a Provider are deemed to be significant non-compliance, thereby requiring that the Quality Agent report the significant non-compliance to RESNET and additional action by RESNET may be taken.
Reason: Proposed change is consistent with existing language
Comment #310Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-11Paragraph / Figure / Table / Note: 904.4.2.8Comment Intent: ObjectionComment Type: TechnicalComment: 904.4.2.8 With the imminent 3rd party QA and potential additional field QA needed for penalties due to errors, it would make sense to keep the window of opportunity for field Qa as large as possible. Virtual QA will help tremendously in this regard but is dependent on the quality of connection, and as mandatory in person QA is also proposed it may, in some instances, not be an option . if not enough homes/units are available or timing is working against meeting the field QA quota then Keeping the proctored event ( in person or virtual) allows the ability to QA multiple raters at one home or apartment unit and help ensure the QA quotas are met. It seems this is also the intent called out in 904.3.4.2 Proposed Change: 904.4.2.8 If a QA Designee is required to complete an onsite QA inspection on at least two (2) homes for a given Rater, 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. 904.4.2.8.1 A centralized proctored rating QA event is defined as a rating that occurs at a house assigned by the QA Designee at which the QA Designee, or their Delegate, must be onsite to ensure that the Rater being reviewed is working completely independently to gather all aspects of the minimum rated features of a home. The Rater being reviewed will not be allowed to communicate by any means with others while gathering information in the home or creating their rating software file and report. The review shall include, but is not limited to, the following: 1. Diagnostic equipment set-up and testing measurements 2. Insulation evaluation and R-value determination 3. Calculations of gross areas, volumes, and square footage of the home 4. Input and creation of the software rating file and reports 904.4.2.8.2 QA under this Section shall adhere to the same variance allowances provided for in Section 904.4.2.5. Response: Reject Reason: This type event is a good training and educational opportunity but should not be used for QA reviews since remote QA will be an option
904.4.2.8 With the imminent 3rd party QA and potential additional field QA needed for penalties due to errors, it would make sense to keep the window of opportunity for field Qa as large as possible. Virtual QA will help tremendously in this regard but is dependent on the quality of connection, and as mandatory in person QA is also proposed it may, in some instances, not be an option . if not enough homes/units are available or timing is working against meeting the field QA quota then Keeping the proctored event ( in person or virtual) allows the ability to QA multiple raters at one home or apartment unit and help ensure the QA quotas are met. It seems this is also the intent called out in 904.3.4.2
904.4.2.8 If a QA Designee is required to complete an onsite QA inspection on at least two (2) homes for a given Rater, 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. 904.4.2.8.1 A centralized proctored rating QA event is defined as a rating that occurs at a house assigned by the QA Designee at which the QA Designee, or their Delegate, must be onsite to ensure that the Rater being reviewed is working completely independently to gather all aspects of the minimum rated features of a home. The Rater being reviewed will not be allowed to communicate by any means with others while gathering information in the home or creating their rating software file and report. The review shall include, but is not limited to, the following: 1. Diagnostic equipment set-up and testing measurements 2. Insulation evaluation and R-value determination 3. Calculations of gross areas, volumes, and square footage of the home 4. Input and creation of the software rating file and reports 904.4.2.8.2 QA under this Section shall adhere to the same variance allowances provided for in Section 904.4.2.5.
Reason: This type event is a good training and educational opportunity but should not be used for QA reviews since remote QA will be an option
Comment #311Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-11Paragraph / Figure / Table / Note: 904.4.2.8Comment Intent: ObjectionComment Type: TechnicalComment: The QA Event has been used by EnergyLogic not out of necessity, but out of the value it provides to our raters in determining areas of inconsistency. While it does allow for a QA Agent to reduce travel burdens (and reduce cost to some raters by lining up travels with trainings and/or professional development), the real value is in having a group of raters perform a rating on the same home and comparing those results to see how they differ. This event has a clarifying effect on who inconsistent raters can be, and sheds light for areas of improvement in a rating company. Just like QA of pre-drywall inspections has been a best practice, but not performed unless it was convenient, the QA Event could suffer the same fate. Ultimately more frequent use of this event could help the industry achieve greater consistency. By recognizing this event RESNET could help shine a brighter light on those areas of inconsistency between raters. Leaving this event intact in the standard (for those who qualify) would ultimately help maintain the credible and informative process of finding inconsistencies. Taking a more scientific approach using the scientific method, the QA Event is more like a scientific research project. By having a group of raters (the independent variables) all do a rating on the same house we take away all the many variable in different homes and have a constant (control) in our comparison of rater’s results. Achieving greater consistency is the goal here and there is no better way to evaluate this than using a more scientific approach such as a QA Event. I have attached an example of what EnergyLogic has done in a QA Event in the past. This helped in determining areas of discrepancy between raters. Having this data for comparison helps make it clear what areas we have discrepancies in as a group and where we need to focus on improvements. It just takes a little exporting and auto formatting of data to make it apparant what is going on with the inconsistencies. Proposed Change: Do not strike 904.4.2.8 904.4.2.8 If a QA Designee is required to complete an onsite QA inspection on at least two (2) homes for a given Rater, 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. 904.4.2.8.1 A centralized proctored rating QA event is defined as a rating that occurs at a house assigned by the QA Designee at which the QA Designee, or their Delegate, must be onsite to ensure that the Rater being reviewed is working completely independently to gather all aspects of the minimum rated features of a home. The Rater being reviewed will not be allowed to communicate by any means with others while gathering information in the home or creating their rating software file and report. The review shall include, but is not limited to, the following: 1. Diagnostic equipment set-up and testing measurements 2. Insulation evaluation and R-value determination 3. Calculations of gross areas, volumes, and square footage of the home 4. Input and creation of the software rating file and reports 904.4.2.8.2 QA under this Section shall adhere to the same variance allowances provided for in Section 904.4.2.5 Response: Reject Reason: This type event is a good training and educational opportunity but should not be used for QA reviews since remote QA will be an option
The QA Event has been used by EnergyLogic not out of necessity, but out of the value it provides to our raters in determining areas of inconsistency. While it does allow for a QA Agent to reduce travel burdens (and reduce cost to some raters by lining up travels with trainings and/or professional development), the real value is in having a group of raters perform a rating on the same home and comparing those results to see how they differ. This event has a clarifying effect on who inconsistent raters can be, and sheds light for areas of improvement in a rating company. Just like QA of pre-drywall inspections has been a best practice, but not performed unless it was convenient, the QA Event could suffer the same fate. Ultimately more frequent use of this event could help the industry achieve greater consistency. By recognizing this event RESNET could help shine a brighter light on those areas of inconsistency between raters. Leaving this event intact in the standard (for those who qualify) would ultimately help maintain the credible and informative process of finding inconsistencies. Taking a more scientific approach using the scientific method, the QA Event is more like a scientific research project. By having a group of raters (the independent variables) all do a rating on the same house we take away all the many variable in different homes and have a constant (control) in our comparison of rater’s results. Achieving greater consistency is the goal here and there is no better way to evaluate this than using a more scientific approach such as a QA Event.
I have attached an example of what EnergyLogic has done in a QA Event in the past. This helped in determining areas of discrepancy between raters. Having this data for comparison helps make it clear what areas we have discrepancies in as a group and where we need to focus on improvements. It just takes a little exporting and auto formatting of data to make it apparant what is going on with the inconsistencies.
Do not strike 904.4.2.8
904.4.2.8 If a QA Designee is required to complete an onsite QA inspection on at least two (2) homes for a given Rater, 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.
904.4.2.8.1 A centralized proctored rating QA event is defined as a rating that occurs at a house assigned by the QA Designee at which the QA Designee, or their Delegate, must be onsite to ensure that the Rater being reviewed is working completely independently to gather all aspects of the minimum rated features of a home. The Rater being reviewed will not be allowed to communicate by any means with others while gathering information in the home or creating their rating software file and report. The review shall include, but is not limited to, the following:
1. Diagnostic equipment set-up and testing measurements 2. Insulation evaluation and R-value determination 3. Calculations of gross areas, volumes, and square footage of the home 4. Input and creation of the software rating file and reports
904.4.2.8.2 QA under this Section shall adhere to the same variance allowances provided for in Section 904.4.2.5
Comment #312Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 33Paragraph / Figure / Table / Note: 904.4.2.8Comment Intent: ObjectionComment Type: TechnicalComment: proposed change: do not strike out. Southface agrees with existing Comments #79 and #91 Proposed Change: 904.4.2.8 If a QA Designee is required to complete an onsite QA inspection on at least two (2) homes for a given Rater, 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. 904.4.2.8.1 A centralized proctored rating QA event is defined as a rating that occurs at a house assigned by the QA Designee at which the QA Designee, or their Delegate, must be onsite to ensure that the Rater being reviewed is working completely independently to gather all aspects of the minimum rated features of a home. The Rater being reviewed will not be allowed to communicate by any means with others while gathering information in the home or creating their rating software file and report. The review shall include, but is not limited to, the following: 1. Diagnostic equipment set-up and testing measurements 2. Insulation evaluation and R-value determination 3. Calculations of gross areas, volumes, and square footage of the home 4. Input and creation of the software rating file and reports 904.4.2.8.2 QA under this Section shall adhere to the same variance allowances provided for in Section 904.4.2.5. Response: Reject Reason: This type event is a good training and educational opportunity but should not be used for QA reviews since remote QA will be an option
proposed change: do not strike out. Southface agrees with existing Comments #79 and #91
Comment #313Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-11Paragraph / Figure / Table / Note: 904.4.2.8Comment Intent: ObjectionComment Type: GeneralComment: Low-volume raters and raters in outlying areas are at a serious disadvantage with the new standards requiring a higher percentage of field review. Until it is known what the "video technology and processes, protocols, and procedures approved by RESNET" are, it is too soon to assume this will decrease cost or even be usable by these raters. The ability to use a centralized proctored rating QA event is a known cost-cutter and should remain as a viable alternative. Proposed Change: 904.4.2.8 If a Quality Agent Designee is required to complete an onsite QA inspection on at least two (2) homes ratings for a given Rater, the Quality Agent 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 thosehomes evaluated for the onsite or virtual inspection process. 904.4.2.8.1 A centralized proctored rating QA event is defined as a rating that occurs at a house assigned by the Quality Agent Designee at which the Quality Agent Designee, or their Delegate, must be onsite to ensure that the Rater being reviewed is working completely independently to gather all aspects of the minimum rated features of a home. The Rater being reviewed will not be allowed to communicate by any means with others while gathering information in the home or creating their rating software file and report. The review shall include, but is not limited to, the following: 1. Diagnostic equipment set-up and testing measurements 2. Insulation evaluation and R-value determination 3. Calculations of gross areas, volumes, and square footage of the home 4. Input and creation of the software rating file and reports 904.4.2.8.2 QA under this Section shall adhere to the same variance allowances provided for in Section 904.4.2.5. Response: Reject Reason: This type event is a good training and educational opportunity but should not be used for QA reviews since remote QA will be an option
Low-volume raters and raters in outlying areas are at a serious disadvantage with the new standards requiring a higher percentage of field review. Until it is known what the "video technology and processes, protocols, and procedures approved by RESNET" are, it is too soon to assume this will decrease cost or even be usable by these raters. The ability to use a centralized proctored rating QA event is a known cost-cutter and should remain as a viable alternative.
904.4.2.8 If a Quality Agent Designee is required to complete an onsite QA inspection on at least two (2) homes ratings for a given Rater, the Quality Agent 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 thosehomes evaluated for the onsite or virtual inspection process.
904.4.2.8.1 A centralized proctored rating QA event is defined as a rating that occurs at a house assigned by the Quality Agent Designee at which the Quality Agent Designee, or their Delegate, must be onsite to ensure that the Rater being reviewed is working completely independently to gather all aspects of the minimum rated features of a home. The Rater being reviewed will not be allowed to communicate by any means with others while gathering information in the home or creating their rating software file and report. The review shall include, but is not limited to, the following:
904.4.2.8.2 QA under this Section shall adhere to the same variance allowances provided for in Section 904.4.2.5.
Comment #314Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-11Paragraph / Figure / Table / Note: 904.4.2.8Comment Intent: Not an ObjectionComment Type: TechnicalComment: Ignore other requests/comments about not removing this section. While a useful training/mentoring tool, a centralized proctored rating QA event has no place in ensuring rated homes are accurately rated and should not be used in lieu of actual field QA. Proposed Change: No change. We fully support the removal of this section. Response: Accept
Ignore other requests/comments about not removing this section. While a useful training/mentoring tool, a centralized proctored rating QA event has no place in ensuring rated homes are accurately rated and should not be used in lieu of actual field QA.
No change. We fully support the removal of this section.
Comment #315Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 33Paragraph / Figure / Table / Note: 904.4.2.8Comment Intent: ObjectionComment Type: GeneralComment: Although the QA event may need to be reworked a little for the purposes of the new third party QA process the validity of the process is not in question. EnergyLogic and other rating providers have utilized this section of the standards for years and have found that it is extremely beneficial for all involved. For the provider it is cost effective. For the QA Contractor/Agent is it time efficient when working with multiple Raters in a specific marker. For the Rater and the QA Contractor/Agent areas of the Rating process that are blind to the QA Contractor/Agent are reveled and can be addressed. For example, misinterpretations of the standards, poor execution of the diagnostic testing protocols, and Providership wide errors that may not be evident when looking at individual files or houses void of the rater being present. I would strongly urge that the committee work toward reinstating this section of the standard so that is works in unison with the intent of the changes. I believe is does. Proposed Change: 904.4.2.8 If a QA Designee Contractor/Agent is required to complete an onsite QA inspection on at least two (2) homes for a given Rater, the QA Designee Contractor/Agent 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. 904.4.2.8.1 A centralized proctored rating QA event is defined as a rating that occurs at a house assigned by the Designee Contractor/Agent at which the QA Designee Contractor/Agent, or their Delegate, must be onsite to ensure that the Rater being reviewed is working completely independently to gather all aspects of the minimum rated features of a home. The Rater being reviewed will not be allowed to communicate by any means with others while gathering information in the home or creating their rating software file and report. The review shall include, but is not limited to, the following: 1. Diagnostic equipment set-up and testing measurements 2. Insulation evaluation and R-value determination 3. Calculations of gross areas, volumes, and square footage of the home 4. Input and creation of the software rating file and reports Response: Reject Reason: This type event is a good training and educational opportunity but should not be used for QA reviews since remote QA will be an option
Although the QA event may need to be reworked a little for the purposes of the new third party QA process the validity of the process is not in question. EnergyLogic and other rating providers have utilized this section of the standards for years and have found that it is extremely beneficial for all involved. For the provider it is cost effective. For the QA Contractor/Agent is it time efficient when working with multiple Raters in a specific marker. For the Rater and the QA Contractor/Agent areas of the Rating process that are blind to the QA Contractor/Agent are reveled and can be addressed. For example, misinterpretations of the standards, poor execution of the diagnostic testing protocols, and Providership wide errors that may not be evident when looking at individual files or houses void of the rater being present. I would strongly urge that the committee work toward reinstating this section of the standard so that is works in unison with the intent of the changes. I believe is does.
904.4.2.8 If a QA Designee Contractor/Agent is required to complete an onsite QA inspection on at least two (2) homes for a given Rater, the QA Designee Contractor/Agent 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. 904.4.2.8.1 A centralized proctored rating QA event is defined as a rating that occurs at a house assigned by the Designee Contractor/Agent at which the QA Designee Contractor/Agent, or their Delegate, must be onsite to ensure that the Rater being reviewed is working completely independently to gather all aspects of the minimum rated features of a home. The Rater being reviewed will not be allowed to communicate by any means with others while gathering information in the home or creating their rating software file and report. The review shall include, but is not limited to, the following: 1. Diagnostic equipment set-up and testing measurements 2. Insulation evaluation and R-value determination 3. Calculations of gross areas, volumes, and square footage of the home 4. Input and creation of the software rating file and reports
Comment #316Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-14-15Paragraph / Figure / Table / Note: 905-905.1.3.5Comment Intent: ObjectionComment Type: GeneralComment: There is absolutely no need for the introduction of a "Quality Assurance Contractor" when Chapter 1 already designates that Third-party Providers are considered "Quality Assurance Contractors". It is a really bad idea to have duplicative Standards that refer to the exact same role under different titles. Additionally, should you decide to ignore my comments, this section does not belong here but in Chapter 1 under the "Accreditation" section. The requirements to become a Quality Assurance Contractor, as described in this section, is ridiculously lower than what is required to be a Third-party Provider, once again demonstrating a bias against a specific Provider model and favoritism toward the Direct Provider model that the Board of Directors specifically has a policy prohibiting. Proposed Change: Strike the following in its entirety, renumbering as needed: 905 QUALITY ASSURANCE DESIGNEE (QA Designee) CONTRACTORS AND QUALITY AGENTS 905.1 Quality Assurance Contractor. A company who employs one or more Quality Agents certified by RESNET in accordance with these Standards. 905.1.1 RESNET shall approve all Quality Assurance Contractors and maintain a national registry of approved Quality Assurance Contractors. 905.1.2 Third-party Providers who meet the minimum requirements to be a Quality Assurance Contractor can be recognized by RESNET as Quality Assurance Contractors. 905.1.3 A Rating Quality Assurance ProviderMinimum requirements to be a RESNET approved Quality Assurance Contractor: 905.1.3.1 dDesignate one and only one officer, employee, or contractoremployedQuality Agent to be the Primary Quality AgentQuality Assurance Designee for theorganization, responsible for quality assurance within the organization. This doesnot preclude a Provider from having more than one QA Designee on staff or as acontractor, as may be necessary for business models where QA Designees doRatings. The Primary Quality AgentQA Designee shall have ultimateresponsibility, on behalf of the QAQuality Assurance Contractor Provider, forfulfilling the requirements listed in Section 905.8904 and who shall be the singlepoint of contact to RESNET regarding all Quality Assurance matters. All QADesignees shall meet each of the minimum requirements to be a QA Designee asstipulated in this Section. 905.1.3.2 Provide a RESNET approved non-disclosure agreement to Rating Quality Assurance Providers for whom they provide quality assurance services. 905.1.3.3 Demonstrate to RESNET a minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage. 905.1.3.45 Shall not provide other HERS rating services. 905.1.3.5 Other requirements that RESNET may deem necessary and proper to maintain the integrity of the RESNET quality assurance process. 905.2 Quality Agent.The designated officer, employee, or contractor responsible for quality assurance shall meet the following minimum requirements: An individual employed by a Quality Assurance Contractor or Third Party Rating Quality Assurance Provider who is certified as an agent of RESNET to perform quality assurance work as outlined in these Standards. Replace with: 905 Quality Agents 905.1 Quality Agent. An individual employed by a Third Party Rating Quality Assurance Provider who is certified as an agent of RESNET to perform quality assurance work as outlined in these Standards. Response: Reject Reason: Current proposed amendment is consistent with the board’s policy
There is absolutely no need for the introduction of a "Quality Assurance Contractor" when Chapter 1 already designates that Third-party Providers are considered "Quality Assurance Contractors". It is a really bad idea to have duplicative Standards that refer to the exact same role under different titles.
Additionally, should you decide to ignore my comments, this section does not belong here but in Chapter 1 under the "Accreditation" section.
The requirements to become a Quality Assurance Contractor, as described in this section, is ridiculously lower than what is required to be a Third-party Provider, once again demonstrating a bias against a specific Provider model and favoritism toward the Direct Provider model that the Board of Directors specifically has a policy prohibiting.
Strike the following in its entirety, renumbering as needed:
905 QUALITY ASSURANCE DESIGNEE (QA Designee) CONTRACTORS AND QUALITY AGENTS 905.1 Quality Assurance Contractor. A company who employs one or more Quality Agents certified by RESNET in accordance with these Standards. 905.1.1 RESNET shall approve all Quality Assurance Contractors and maintain a national registry of approved Quality Assurance Contractors. 905.1.2 Third-party Providers who meet the minimum requirements to be a Quality Assurance Contractor can be recognized by RESNET as Quality Assurance Contractors. 905.1.3 A Rating Quality Assurance ProviderMinimum requirements to be a RESNET approved Quality Assurance Contractor:
905.1.3.1 dDesignate one and only one officer, employee, or contractoremployedQuality Agent to be the Primary Quality AgentQuality Assurance Designee for theorganization, responsible for quality assurance within the organization. This doesnot preclude a Provider from having more than one QA Designee on staff or as acontractor, as may be necessary for business models where QA Designees doRatings. The Primary Quality AgentQA Designee shall have ultimateresponsibility, on behalf of the QAQuality Assurance Contractor Provider, forfulfilling the requirements listed in Section 905.8904 and who shall be the singlepoint of contact to RESNET regarding all Quality Assurance matters. All QADesignees shall meet each of the minimum requirements to be a QA Designee asstipulated in this Section.
905.1.3.2 Provide a RESNET approved non-disclosure agreement to Rating Quality Assurance Providers for whom they provide quality assurance services. 905.1.3.3 Demonstrate to RESNET a minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage. 905.1.3.45 Shall not provide other HERS rating services. 905.1.3.5 Other requirements that RESNET may deem necessary and proper to maintain the integrity of the RESNET quality assurance process.
905.2 Quality Agent.The designated officer, employee, or contractor responsible for quality assurance shall meet the following minimum requirements: An individual employed by a Quality Assurance Contractor or Third Party Rating Quality Assurance Provider who is certified as an agent of RESNET to perform quality assurance work as outlined in these Standards.
905 Quality Agents
905.1 Quality Agent. An individual employed by a Third Party Rating Quality Assurance Provider who is certified as an agent of RESNET to perform quality assurance work as outlined in these Standards.
Reason: Current proposed amendment is consistent with the board’s policy
Comment #317Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-14Paragraph / Figure / Table / Note: 905.1.2Comment Intent: Not an ObjectionComment Type: EditorialComment: Changes are needed for consistency and clarity. Proposed Change: 905.1.2 Third-party Rating Quality Assurance Providers who meet the minimum requirements to be a Quality Assurance Contractor shall can be recognized by RESNET as Quality Assurance Contractors. Response: Reject Reason: Language will remain “third-party provider” to be consistent with definition and “can” will be changed to “may”
Changes are needed for consistency and clarity.
905.1.2 Third-party Rating Quality Assurance Providers who meet the minimum requirements to be a Quality Assurance Contractor shall can be recognized by RESNET as Quality Assurance Contractors.
Reason: Language will remain “third-party provider” to be consistent with definition and “can” will be changed to “may”
Comment #318Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-14Paragraph / Figure / Table / Note: 905.1.2Comment Intent: ObjectionComment Type: EditorialComment: I believe Direct Provider should be added to this Section in addition to Third Party Provider. Proposed Change: 905.1.2 Third-party or Direct Providers who meet the minimum requirements to be a Quality Assurance Contractor can be recognized by RESNET as Quality Assurance Contractors. Response: Reject Reason: Direct providers may have a separate third party providership that may be a QA contractor
I believe Direct Provider should be added to this Section in addition to Third Party Provider.
905.1.2 Third-party or Direct Providers who meet the minimum requirements to be a Quality Assurance Contractor can be recognized by RESNET as Quality Assurance Contractors.
Reason: Direct providers may have a separate third party providership that may be a QA contractor
Comment #319Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-14Paragraph / Figure / Table / Note: 905.1.2Comment Intent: ObjectionComment Type: EditorialComment: Section 905.1.2.4 which prohibits Quality Assurance Contractors from providing HERS Rating services directly contradicts 103.1.3 which allows Direct Quality Assurance Contractors to provide QA services to HERS Raters outside their company. Proposed Change: Remove 905.1.3.4 in its entirity. Renumber as requried. 905.1.3.4 Shall not provide HERS rating services. 905.1.3.45 Response: Accept Reason: QA contractors should be able to offer rating services because a direct provider may have a third-party division and this restriction contradicts that. Any potential conflict of interest can be covered by the contract between the provider and QA contractor
Section 905.1.2.4 which prohibits Quality Assurance Contractors from providing HERS Rating services directly contradicts 103.1.3 which allows Direct Quality Assurance Contractors to provide QA services to HERS Raters outside their company.
Remove 905.1.3.4 in its entirity. Renumber as requried.
905.1.3.4 Shall not provide HERS rating services.
905.1.3.45
Reason: QA contractors should be able to offer rating services because a direct provider may have a third-party division and this restriction contradicts that. Any potential conflict of interest can be covered by the contract between the provider and QA contractor
Comment #320Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 37Paragraph / Figure / Table / Note: 905.1.3.2Comment Intent: ObjectionComment Type: GeneralComment: I have an issue with the following highlighted text: 905.1.3.2 Provide a RESNET approved non-disclosure agreement to Rating Quality Assurance Providers for whom they provide quality assurance services. Maybe it’s just me, but it seems disingenuous to sign a NDA with someone they perform QA on. If someone is making serious mistakes that could affect the general perception of the industry or create potential health risks, this NDA could stop them from directly telling the home owner/buyers, or even the builders, utility providers, and other interested parties. It would have to go to RESNET via the whistleblower policy and/or ethics complaints, and by the time it gets resolved, a homeowner could be living in a faulty home, the builder may have received a utility rebate already, and plenty of other issues. I don't see this as much of an issue for Third-Party Rating Quality Assurance Providers, but I imagine some huge problems arise when it comes to Direct Rating Quality Assurance Providers. I hesitate to say it needs to be struck, but I would like for my concerns to be read all the same. Proposed Change: N/A Response: Reject Reason: The QA agent shall go to RESNET and not directly to the builder or homeowner
905.1.3.2 Provide a RESNET approved non-disclosure agreement to Rating Quality Assurance Providers for whom they provide quality assurance services.
Maybe it’s just me, but it seems disingenuous to sign a NDA with someone they perform QA on. If someone is making serious mistakes that could affect the general perception of the industry or create potential health risks, this NDA could stop them from directly telling the home owner/buyers, or even the builders, utility providers, and other interested parties. It would have to go to RESNET via the whistleblower policy and/or ethics complaints, and by the time it gets resolved, a homeowner could be living in a faulty home, the builder may have received a utility rebate already, and plenty of other issues.
I don't see this as much of an issue for Third-Party Rating Quality Assurance Providers, but I imagine some huge problems arise when it comes to Direct Rating Quality Assurance Providers.
I hesitate to say it needs to be struck, but I would like for my concerns to be read all the same.
N/A
Reason: The QA agent shall go to RESNET and not directly to the builder or homeowner
Comment #321Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.1.3.4Comment Intent: ObjectionComment Type: GeneralComment: I have concerns that this standard will stall growth in low volume areas and limit RESNET from growing into new areas due to travel cost of Quality Assurance Contractors. After reviewing the standard, I think the virtual QA option will help but unfortunately many areas still don't have good cellular coverage. Therefore, I would like to make the following recommendation: Define low volume by number of ratings in a geographical area and allow the QAD to support themselves by providing HERS ratings along with QAs until such time the area is no longer considered low volume. Proposed Change: 905.1.3.5 Shall not Provide HERS rating services outside designated low volume areas. Response: Reject Reason: QA contractors should be able to offer rating services because a direct provider may have a third-party division and this restriction contradicts that. Any potential conflict of interest can be covered by the contract between the provider and QA contractor
I have concerns that this standard will stall growth in low volume areas and limit RESNET from growing into new areas due to travel cost of Quality Assurance Contractors.
After reviewing the standard, I think the virtual QA option will help but unfortunately many areas still don't have good cellular coverage. Therefore, I would like to make the following recommendation:
Define low volume by number of ratings in a geographical area and allow the QAD to support themselves by providing HERS ratings along with QAs until such time the area is no longer considered low volume.
905.1.3.5 Shall not Provide HERS rating services outside designated low volume areas.
Comment #322Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.1.3.4Comment Intent: ObjectionComment Type: GeneralComment: Section 905.1 defines he roles and requirements of a QA Contractor Section 905.1.3.4 restricts the Quality Agent from providing HERS rating services. In underserved areas with few raters and few ratings performed annually, Placing restrictions on the services that qualified personnel can perform is counter-productive. These underserved areas with low numbers of ratings, often located in rural areas represent a growth opportunity for RESNET and for the improvement in residential energy efficiency. RESNET should define what these under-served areas or areas with low numbers of reported ratings per geographic region are. Based on this designation, certain provisions and exceptions to raters, Quality Agents, and providers should be granted to stimulate more rapid adoption of the HERS index. Proposed Change: 905.1.3.4 Shall not provide HERS rating services, except in designated underserved areas. Response: Reject Reason: QA contractors should be able to offer rating services because a direct provider may have a third-party division and this restriction contradicts that. Any potential conflict of interest can be covered by the contract between the provider and QA contractor
Section 905.1 defines he roles and requirements of a QA Contractor
Section 905.1.3.4 restricts the Quality Agent from providing HERS rating services. In underserved areas with few raters and few ratings performed annually, Placing restrictions on the services that qualified personnel can perform is counter-productive. These underserved areas with low numbers of ratings, often located in rural areas represent a growth opportunity for RESNET and for the improvement in residential energy efficiency.
RESNET should define what these under-served areas or areas with low numbers of reported ratings per geographic region are. Based on this designation, certain provisions and exceptions to raters, Quality Agents, and providers should be granted to stimulate more rapid adoption of the HERS index.
905.1.3.4 Shall not provide HERS rating services, except in designated underserved areas.
Comment #323Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 37Paragraph / Figure / Table / Note: 905.1.3.4Comment Intent: ObjectionComment Type: TechnicalComment: • 905.1.3.4 strike this and include that Quality Insurance Contractors and Agents can provide ratings as long as they then follow the standards for QA oversight. Proposed Change: 905.1.3.45 Shall not provide other HERS rating services in accordance with RESNET standards. Response: Reject Reason: Additional language is not needed
• 905.1.3.4
strike this and include that Quality Insurance Contractors and Agents can provide ratings as long as they then follow the standards for QA oversight.
905.1.3.45 Shall not provide other HERS rating services in accordance with RESNET standards.
Reason: Additional language is not needed
Comment #324Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 37Paragraph / Figure / Table / Note: 905.1.3.4.5Comment Intent: ObjectionComment Type: GeneralComment: in section 103.1.3 the proposed language says, "An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work." In this case why can’s a quality assurance contractor for the provider occasionally do a rating on the other side of the company, especially if a third party is going to do the QA on the rater. I feel it not only gives the Providership more flexibility but ensure that the skill set of the QAC is maintained in the real world of ratings in addition to the QA side of the equation. Proposed Change: 905.1 Quality Assurance Contractor…. 905.1.3.4.5 Shall not provide other HERS rating services. An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. Quality Assurance Contractors may also produce rating for their Direct Rating Quality Assurance Provider as long as an independent Quality Assurance Contractor performs all quality assurance of the Direct Provider’s work. Response: Accept Reason: Accept in principle. The added text is already covered in section 103 but the restriction on providing rating services has been removed per comment #317
in section 103.1.3 the proposed language says, "An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. However, the organization’s Third-Party Rating Quality Assurance Providership may not perform quality assurance of the Direct Provider’s work."
In this case why can’s a quality assurance contractor for the provider occasionally do a rating on the other side of the company, especially if a third party is going to do the QA on the rater. I feel it not only gives the Providership more flexibility but ensure that the skill set of the QAC is maintained in the real world of ratings in addition to the QA side of the equation.
905.1 Quality Assurance Contractor…. 905.1.3.4.5 Shall not provide other HERS rating services.
An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership. Quality Assurance Contractors may also produce rating for their Direct Rating Quality Assurance Provider as long as an independent Quality Assurance Contractor performs all quality assurance of the Direct Provider’s work.
Reason: Accept in principle. The added text is already covered in section 103 but the restriction on providing rating services has been removed per comment #317
Comment #325Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-14, 9-15Paragraph / Figure / Table / Note: 905.1.3.4.5 & 905.2.2.3Comment Intent: ObjectionComment Type: TechnicalComment: 905.1 Quality Assurance Contractor…. 905.1.3.4.5 Shall not provide other HERS rating services. 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; I believe with the robust proposal of financial interest disclosures in 103.1.2.1.1 and the new definition of financial interest that we have much more clear delineations of not being able to QA anyone with a “employer/employee/contractor relationship”. Having RESNET Staff review the disclosures of the QA Contractor and Provider relationships, before approving their partnership, is a “catch all” fail safe that will allow RESNET to apply the financial interest definitions in the standard in a way that fits all of the varying circumstances that may arise. Particularly strong is the following section: 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. I believe this eliminates the need for other exclusions and will allow the market to decide who is best fit for QA Contractor services. Adding to these exclusions by creating delineations where QA Agents can’t be raters and where Rating Companies can’t also be QA Contractors isn’t necessary to meeting the proposed definition of financial interest. This seems to be a high-risk, low-reward proposition for the industry to endeavor during a time of big change. I propose to remove these sections of the proposed standard as I believe it will create a void that cannot be filled without consequence to the quality and consistency in the rating product. The proposed sections would require having to “give-up” doing ratings to be a QA Agent and/or QA Contractor. Rating companies have been through the ropes, understand how to run a rating business, and understand the pitfalls. They typically have experienced raters who can further their career as QA Agents and still keep their work as productive raters. Turnover of good raters is a real issue in our industry. One way EnergyLogic has been able to keep our raters engaged is to allow them the opportunities to become QAD’s. Particularly beneficial is the collaboration with other raters in this process, and even more valuable when those Raters/QA Agents can see other markets. Eliminating the ability for a rater to also do QA could lead to more turnover of our best raters moving on to other endeavors. Every rater who does QA for us, tells us that they are a much better rater after having done some QA. Allowing raters to QA, makes for better raters and ratings. Rating companies also typically have seasonal work and QA Contracting could be a way for rating companies to level this out and more effectively use limited industry resources. Having an exclusion where a QA Agent can’t be an active rater eliminates this efficiency and stretches our resources thin. Having raters as QA Agents would allow us to keep a “bullpen” of QA Agents who can be effective in their work in QA during slower builder seasons, and help the rating operation during the busier seasons, helping boost the quality of ratings during those busy times. The value of the QA product should be competitive with active raters being able to do QA. Creating this exclusion eliminates the direct contact of a rater with active, experienced raters in the QA process. Experienced Rating Companies have the resources and know-how to make excellent QA Contracting Companies. The most qualified individuals to be QA Agents are current QADs. Not allowing rating companies to keep their QADs to become QA Agents, puts an unnecessary administrative and financial burden on those QADs. It would require QADs to break from their current rating companies to form a new Contractor Company and take on similar administrative overhead. This is not a great use of industry resources that could otherwise be shared across one company. Perspective QA Contractor companies will need to juggle taking on significant growing demand for contracted QA. I think there would be better focus on the important work of improved quality of ratings if we didn’t put these unnecessary administrative burdens on QA Contractor companies to form their own business, while also navigating the waters of all these changes. This shift in external QA is a critical one for the industry. Allowing Rating companies to also be QA Contractors and QA Agents to be Active Raters, would allow the industry to more smoothly make this much needed shift, but do so in an effective and minimally disruptive manner. The QA Agent training will be a filtering mechanism to allow the best, most qualified raters to become QA Agents. Couple this with the approval process in section 103.1.2, whereby RESNET Staff reviews the conflicts of interest disclosures and we have a really strong QA path in the process of approval for a QA relationship. Our network is already being stretched for resources given all of the valuable proposals. In cases where there is no conflict of interest, cutting the most experienced people and rating companies out of the process of QA seems to be a high-risk, low-reward proposition that diminishes the value of the Rating and QA products. Proposed Change: QA Agents 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; QA Contractors 905.1.3.45 Shall not provide other HERS rating services. Amendment: 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership and/or operate as a QA Contractor. However, the organization’s Third-Party Rating Quality Assurance Providership, QA Contractor Operation, and/or QA Agents may not perform RESNET quality assurance of the Direct Provider’s work. Response: Accept in principle Reason: the restriction on providing rating services has been removed per comment #317 Revised section to read RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; I believe with the robust proposal of financial interest disclosures in 103.1.2.1.1 and the new definition of financial interest that we have much more clear delineations of not being able to QA anyone with a “employer/employee/contractor relationship”. Having RESNET Staff review the disclosures of the QA Contractor and Provider relationships, before approving their partnership, is a “catch all” fail safe that will allow RESNET to apply the financial interest definitions in the standard in a way that fits all of the varying circumstances that may arise.
Particularly strong is the following section: 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest.
I believe this eliminates the need for other exclusions and will allow the market to decide who is best fit for QA Contractor services. Adding to these exclusions by creating delineations where QA Agents can’t be raters and where Rating Companies can’t also be QA Contractors isn’t necessary to meeting the proposed definition of financial interest. This seems to be a high-risk, low-reward proposition for the industry to endeavor during a time of big change.
I propose to remove these sections of the proposed standard as I believe it will create a void that cannot be filled without consequence to the quality and consistency in the rating product. The proposed sections would require having to “give-up” doing ratings to be a QA Agent and/or QA Contractor. Rating companies have been through the ropes, understand how to run a rating business, and understand the pitfalls. They typically have experienced raters who can further their career as QA Agents and still keep their work as productive raters. Turnover of good raters is a real issue in our industry. One way EnergyLogic has been able to keep our raters engaged is to allow them the opportunities to become QAD’s. Particularly beneficial is the collaboration with other raters in this process, and even more valuable when those Raters/QA Agents can see other markets. Eliminating the ability for a rater to also do QA could lead to more turnover of our best raters moving on to other endeavors. Every rater who does QA for us, tells us that they are a much better rater after having done some QA. Allowing raters to QA, makes for better raters and ratings. Rating companies also typically have seasonal work and QA Contracting could be a way for rating companies to level this out and more effectively use limited industry resources. Having an exclusion where a QA Agent can’t be an active rater eliminates this efficiency and stretches our resources thin. Having raters as QA Agents would allow us to keep a “bullpen” of QA Agents who can be effective in their work in QA during slower builder seasons, and help the rating operation during the busier seasons, helping boost the quality of ratings during those busy times. The value of the QA product should be competitive with active raters being able to do QA. Creating this exclusion eliminates the direct contact of a rater with active, experienced raters in the QA process. Experienced Rating Companies have the resources and know-how to make excellent QA Contracting Companies. The most qualified individuals to be QA Agents are current QADs. Not allowing rating companies to keep their QADs to become QA Agents, puts an unnecessary administrative and financial burden on those QADs. It would require QADs to break from their current rating companies to form a new Contractor Company and take on similar administrative overhead. This is not a great use of industry resources that could otherwise be shared across one company. Perspective QA Contractor companies will need to juggle taking on significant growing demand for contracted QA. I think there would be better focus on the important work of improved quality of ratings if we didn’t put these unnecessary administrative burdens on QA Contractor companies to form their own business, while also navigating the waters of all these changes. This shift in external QA is a critical one for the industry. Allowing Rating companies to also be QA Contractors and QA Agents to be Active Raters, would allow the industry to more smoothly make this much needed shift, but do so in an effective and minimally disruptive manner. The QA Agent training will be a filtering mechanism to allow the best, most qualified raters to become QA Agents. Couple this with the approval process in section 103.1.2, whereby RESNET Staff reviews the conflicts of interest disclosures and we have a really strong QA path in the process of approval for a QA relationship. Our network is already being stretched for resources given all of the valuable proposals. In cases where there is no conflict of interest, cutting the most experienced people and rating companies out of the process of QA seems to be a high-risk, low-reward proposition that diminishes the value of the Rating and QA products.
QA Agents
905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings;
QA Contractors
905.1.3.45 Shall not provide other HERS rating services.
Reason: the restriction on providing rating services has been removed per comment #317
Revised section to read RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
Comment #326Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 37Paragraph / Figure / Table / Note: 905.1.3.5Comment Intent: ObjectionComment Type: TechnicalComment: 905.1.3.5 Unless this section is explained the wording is way to vague for a proper standard and should be removed. If RESNET deems requirements necessary they would be spelled out in the standards and referenced. Proposed Change: 905.1.3.5 Other requirements that RESNET may deem necessary and proper to maintain the integrity of the RESNET quality assurance process Response: Accept
905.1.3.5
Unless this section is explained the wording is way to vague for a proper standard and should be removed. If RESNET deems requirements necessary they would be spelled out in the standards and referenced.
905.1.3.5 Other requirements that RESNET may deem necessary and proper to maintain the integrity of the RESNET quality assurance process
Comment #327Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.2Comment Intent: ObjectionComment Type: EditorialComment: Including "Third Party Rating Quality Assurance Provider" in redundant as all Rating Quality Assurance Providers, be it Direct or Third-Party would be by definition a Quality Assurance Contractor.(ref. 905.1, "Quality Assurance Contractor. A company who employs one or more Quality Agents certified by RESNET in accordance with these Standards"). Alternatively adding "Direct Ratings Quality Assurance Provider" to 905.2 would clean this up if it was felt that that change would be more clear to the reader. Proposed Change: 905.2 Quality Agent. An individual employed by a Quality Assurance Contractor or Third Party Rating Quality Assurance Provider who is certified as an agent of RESNET to perform quality assurance work as outlined in these Standards. Response: Reject Reason: Since a third party provider could be a QA contractor this language is needed in this section
Including "Third Party Rating Quality Assurance Provider" in redundant as all Rating Quality Assurance Providers, be it Direct or Third-Party would be by definition a Quality Assurance Contractor.(ref. 905.1, "Quality Assurance Contractor. A company who employs one or more Quality Agents certified by RESNET in accordance with these Standards"). Alternatively adding "Direct Ratings Quality Assurance Provider" to 905.2 would clean this up if it was felt that that change would be more clear to the reader.
905.2 Quality Agent. An individual employed by a Quality Assurance Contractor or Third Party Rating Quality Assurance Provider who is certified as an agent of RESNET to perform quality assurance work as outlined in these Standards.
Reason: Since a third party provider could be a QA contractor this language is needed in this section
Comment #328Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.2Comment Intent: ObjectionComment Type: EditorialComment: This restriction is unnecessary if Section 103.2.3 is enforced. It will also greatly limit the number of Raters who can become Quality Agents and thus increase the cost of business for all Rating organizations. Proposed Change: 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings for companies with which there is an actual or perceived conflict of interest; Response: Reject Reason: “perceived” conflicts of interests should not be included in standards language
This restriction is unnecessary if Section 103.2.3 is enforced. It will also greatly limit the number of Raters who can become Quality Agents and thus increase the cost of business for all Rating organizations.
905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings for companies with which there is an actual or perceived conflict of interest;
Reason: “perceived” conflicts of interests should not be included in standards language
Comment #329Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.2Comment Intent: Not an ObjectionComment Type: GeneralComment: Does this mean that a Direct Provider can not hire a Quality Agent directly? Must be done through a Wuality Assurance Contractor? But a Third Party Provider can? or the DP can hire a TP? Why? Proposed Change: N/A Just an observation Response: Reject Reason: no change proposed. Standards language will be clear about these questions
Does this mean that a Direct Provider can not hire a Quality Agent directly? Must be done through a Wuality Assurance Contractor? But a Third Party Provider can? or the DP can hire a TP? Why?
Reason: no change proposed. Standards language will be clear about these questions
Comment #330Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 37-39Paragraph / Figure / Table / Note: 905.2.1 to 905.2.3.2Comment Intent: Not an ObjectionComment Type: EditorialComment: I believe that the following text should be move from Chapter 9 to Chapter 2, as it directly pertains to certification and recertification: 905.2.1 RESNET shall certify all Quality Agents and maintain a national registry of certified Quality Agents. 905.2.2 Certification requirements to be a RESNET certified Quality Agent. 905.2.2.1 Attend and successfully complete an on-site RESNET Quality Agent Instruction and Assessment Certification event; 905.2.2.2 Pass the National Quality Agent Competency Test with a minimum score determined by RESNET; 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; 905.2.2.4 Meet the following experience requirements: 905.2.2.4.1 Previous certification as a RESNET HERS Rater; and 905.2.2.4.2 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues or 905.2.2.4.3 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent. 905.2.3 Professional Development for Quality Agents 905.2.3.1 All Quality Agents annually shall: 905.2.3.1.1 Document attendance at the RESNET Conference; and 905.2.3.1.2 Participate in a one-day in-person RESNET update and training. 905.2.3.2 A Quality Agent must renew annually with RESNET to maintain certification. Proposed Change: (The following is an example for numbering, I did not include the proposed changes to Chapter 2) 210 CERTIFICATION AND RECERTIFICATION OF QUALITY AGENTS 210.1905.2.1 RESNET shall certify all Quality Agents and maintain a national registry of certified Quality Agents. 210.1.2905.2.2 Certification requirements to be a RESNET certified Quality Agent. 210.1.2.1905.2.2.1 Attend and successfully complete an on-site RESNET Quality Agent Instruction and Assessment Certification event; 210.1.2.2905.2.2.2 Pass the National Quality Agent Competency Test with a minimum score determined by RESNET; 210.1.2.3905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; 210.1.2.4905.2.2.4 Meet the following experience requirements: 210.1.2.4.1905.2.2.4.1 Previous certification as a RESNET HERS Rater; and 210.1.2.4.2905.2.2.4.2 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues or 210.1.2.4.3905.2.2.4.3 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent. 210.1.3905.2.3 Professional Development for Quality Agents 210.1.3.1905.2.3.1 All Quality Agents annually shall: 210.1.3.1.1905.2.3.1.1 Document attendance at the RESNET Conference; and 210.1.3.1.2905.2.3.1.2 Participate in a one-day in-person RESNET update and training. 210.1.3.2905.2.3.2 A Quality Agent must renew annually with RESNET to maintain certification. 211210 PROVIDER ACCREDITATION CRITERIA 211.1210.1 Minimum Standards for Rater Training Provider Accreditation Rater Training Providers shall be accredited in accordance with the Accreditation Process specified in Chapter 9 of these Standards. A Rating Training Provider must specifically meet the following minimum standards for Accreditation: ?211.1.1.1210.1.1.1 Application Procedure. ?211.1.1.1.1210.1.1.1.1 Applicants shall demonstrate that their training meets the criteria established through this Standard. Documentation shall include: ?211.1.1.1.1.1210.1.1.1.1.1 Training curriculum ?211.1.1.1.1.2210.1.1.1.1.2 Training materials and manuals ?211.1.1.1.1.3210.1.1.1.1.3 Examination materials ?211.1.1.1.1.4210.1.1.1.1.4 Facilities description ?211.1.1.1.1.5210.1.1.1.1.5 Organization description ?211.1.1.1.1.6210.1.1.1.1.6 Principals and staff qualifications (detailed resumes) 212211 RECIPROCITY 212.1211.1 Nationally accredited Home Energy Rating Providers shall accept certified training provided by an accredited Training Provider as meeting the core competencies for a Home Energy Rater. Accredited Home Energy Rating Providers may add additional training requirements needed to address their specific program, climate, software or administrative requirements. Response: Reject Reason: Certification requirements for QADs have always been in chapter 9 it logical keep them in that chapter
I believe that the following text should be move from Chapter 9 to Chapter 2, as it directly pertains to certification and recertification:
905.2.1 RESNET shall certify all Quality Agents and maintain a national registry of certified Quality Agents.
905.2.2 Certification requirements to be a RESNET certified Quality Agent.
905.2.2.1 Attend and successfully complete an on-site RESNET Quality Agent Instruction and Assessment Certification event;
905.2.2.2 Pass the National Quality Agent Competency Test with a minimum score determined by RESNET;
905.2.2.4 Meet the following experience requirements:
905.2.2.4.1 Previous certification as a RESNET HERS Rater; and
905.2.2.4.2 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues or
905.2.2.4.3 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent.
905.2.3 Professional Development for Quality Agents
905.2.3.1 All Quality Agents annually shall:
905.2.3.1.1 Document attendance at the RESNET Conference; and
905.2.3.1.2 Participate in a one-day in-person RESNET update and training.
905.2.3.2 A Quality Agent must renew annually with RESNET to maintain certification.
(The following is an example for numbering, I did not include the proposed changes to Chapter 2)
210 CERTIFICATION AND RECERTIFICATION OF QUALITY AGENTS
210.1905.2.1 RESNET shall certify all Quality Agents and maintain a national registry of certified Quality Agents.
210.1.2905.2.2 Certification requirements to be a RESNET certified Quality Agent.
210.1.2.1905.2.2.1 Attend and successfully complete an on-site RESNET Quality Agent Instruction and Assessment Certification event;
210.1.2.2905.2.2.2 Pass the National Quality Agent Competency Test with a minimum score determined by RESNET;
210.1.2.3905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings;
210.1.2.4905.2.2.4 Meet the following experience requirements:
210.1.2.4.1905.2.2.4.1 Previous certification as a RESNET HERS Rater; and
210.1.2.4.2905.2.2.4.2 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues or
210.1.2.4.3905.2.2.4.3 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent.
210.1.3905.2.3 Professional Development for Quality Agents
210.1.3.1905.2.3.1 All Quality Agents annually shall:
210.1.3.1.1905.2.3.1.1 Document attendance at the RESNET Conference; and
210.1.3.1.2905.2.3.1.2 Participate in a one-day in-person RESNET update and training.
210.1.3.2905.2.3.2 A Quality Agent must renew annually with RESNET to maintain certification.
211210 PROVIDER ACCREDITATION CRITERIA
211.1210.1 Minimum Standards for Rater Training Provider Accreditation Rater Training Providers shall be accredited in accordance with the Accreditation Process specified in Chapter 9 of these Standards. A Rating Training Provider must specifically meet the following minimum standards for Accreditation:
?211.1.1.1210.1.1.1 Application Procedure.
?211.1.1.1.1210.1.1.1.1 Applicants shall demonstrate that their training meets the criteria established through this Standard. Documentation shall include:
?211.1.1.1.1.1210.1.1.1.1.1 Training curriculum
?211.1.1.1.1.2210.1.1.1.1.2 Training materials and manuals
?211.1.1.1.1.3210.1.1.1.1.3 Examination materials
?211.1.1.1.1.4210.1.1.1.1.4 Facilities description
?211.1.1.1.1.5210.1.1.1.1.5 Organization description
?211.1.1.1.1.6210.1.1.1.1.6 Principals and staff qualifications (detailed resumes)
212211 RECIPROCITY
212.1211.1 Nationally accredited Home Energy Rating Providers shall accept certified training provided by an accredited Training Provider as meeting the core competencies for a Home Energy Rater. Accredited Home Energy Rating Providers may add additional training requirements needed to address their specific program, climate, software or administrative requirements.
Reason: Certification requirements for QADs have always been in chapter 9 it logical keep them in that chapter
Comment #331Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.2.2Comment Intent: ObjectionComment Type: EditorialComment: The order of the "certification requirements" for Quality Agents needs to be changed to more accurately reflect the proposed certification process. Proposed Change: 905.2.2 Certification requirements to be a RESNET certified Quality Agent. 905.2.2.1 Meet the following experience requirements: 905.2.2.1.1 Previous certification as a RESNET HERS Rater; and 905.2.2.1.2 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues; or 905.2.2.1.3 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent. 905.2.2.2 Pass the National Quality Agent Competency Test with a minimum score determined by RESNET; 905.2.2.3 Attend and successfully complete an on-site RESNET Quality Agent Instruction and Assessment Certification event; 905.2.2.4 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings. Response: Accept
The order of the "certification requirements" for Quality Agents needs to be changed to more accurately reflect the proposed certification process.
905.2.2.1 Meet the following experience requirements:
905.2.2.1.1 Previous certification as a RESNET HERS Rater; and
905.2.2.1.2 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues; or 905.2.2.1.3 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent.
905.2.2.3 Attend and successfully complete an on-site RESNET Quality Agent Instruction and Assessment Certification event;
905.2.2.4 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings.
Comment #332Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15-17Paragraph / Figure / Table / Note: 905.2.2-905.2.3.2Comment Intent: ObjectionComment Type: GeneralComment: This section is outside the scope of SDC 900 and belongs to SDC 200. According to the non-ANSI policy and procedures manual adopted by the RESNET Board of Directors, SDC 900 should have submitted a proposed amendment to Chapter 2 for SDC 200 to consider instead of overstepping their committee scope. These sections do NOT belong in Chapter 9, they belong to Chapter 2 along with all the other certification requirements for individuals. Proposed Change: Strike the following in its entirety: 905.2.2 Certification requirements to be a RESNET certified Quality Agent. 905.2.2.1 Attend and successfully complete an on-site RESNET Quality Agent Instruction and Assessment Certification event; 905.2.2.2 Pass the National Quality Agent Competency Test with a minimum score determined by RESNET; 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; 905.2.2.34 Meet the following experience requirements: 905.2.2.34.1 905.2.2 Previous certification as a Home Energy RESNET HERS Rater; and 905.2.2.43.2 As a certified Home Energy HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues prior to becoming a QA Designee; or 905.2.2.43.3 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent. 4905.2.2.1 A QA Designee must confirm that the minimum requirements to be a QA Designee and Delegate, as set forth in this Section 905.2, have been met. 905.2.2.2 Five (5) of the twenty-five (25) required confirmed ratings for a QA Designee must be individually reviewed by a QA Designee, three (3) of which may have been included in the annual QA process for a QA Provider in the previous twenty- four (24) months. The five (5) reviewed ratings shall be field reviews in accordance with section 904.4.2. 905.2.3 To be eligible to QA a particular rating type (e.g. sampled, survey/audit), a QA Designee must have completed a minimum of five (5) of that rating or project type or alternate qualification criteria established by RESNET in consultation with the Quality Assurance Committee; 905.2.4 Passing the RESNET Quality Assurance Designee Test. 905.2.4.1 The requirements of 905.2.2 and 905.2.3 must be met within twelve (12) months of passing the RESNET Quality Assurance Designee Test, or the individual must pass the test again prior to being recognized as a QA Designee. 905.2.5 Submit an application to RESNET and be recognized as a qualified QA Designee. 905.2.3905.3 Professional Development for Quality Aagents Designees 905.2.3.1905.3.1 All Quality Agents Designees annually shall: complete a two hour RESNET QA Roundtable on current information AND complete one (1) of the following activities: 905.2.3.1.1905.3.1.1 Document 12 hours of attendance at the RESNET Conference; or and 905.2.3.1.2905.3.1.2 Complete 12 hours of RESNET approved CEU’s; or Participate in a one-day in-person RESNET update and training. 905.2.3.2 A Quality Agent must renew annually with RESNET to maintain certification. Replace with a proposed amendment to Chapter 2, following the correct process laid out in the RESNET non-ANSI Standards Development Policy and Procedure Manual. Response: Reject Reason: certification requirements for QADs have always been in chapter nine
This section is outside the scope of SDC 900 and belongs to SDC 200. According to the non-ANSI policy and procedures manual adopted by the RESNET Board of Directors, SDC 900 should have submitted a proposed amendment to Chapter 2 for SDC 200 to consider instead of overstepping their committee scope.
These sections do NOT belong in Chapter 9, they belong to Chapter 2 along with all the other certification requirements for individuals.
905.2.2 Certification requirements to be a RESNET certified Quality Agent. 905.2.2.1 Attend and successfully complete an on-site RESNET Quality Agent Instruction and Assessment Certification event; 905.2.2.2 Pass the National Quality Agent Competency Test with a minimum score determined by RESNET; 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings;
905.2.2.34 Meet the following experience requirements:
905.2.2.34.1 905.2.2 Previous certification as a Home Energy RESNET HERS
Rater; and 905.2.2.43.2 As a certified Home Energy HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues prior to becoming a QA Designee; or 905.2.2.43.3 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent. 4905.2.2.1 A QA Designee must confirm that the minimum requirements to be a QA Designee and Delegate, as set forth in this Section 905.2, have been met. 905.2.2.2 Five (5) of the twenty-five (25) required confirmed ratings for a QA Designee must be individually reviewed by a QA Designee, three (3) of which may have been included in the annual QA process for a QA Provider in the previous twenty- four (24) months. The five (5) reviewed ratings shall be field reviews in accordance with section 904.4.2. 905.2.3 To be eligible to QA a particular rating type (e.g. sampled, survey/audit), a QA Designee must have completed a minimum of five (5) of that rating or project type or alternate qualification criteria established by RESNET in consultation with the Quality Assurance Committee; 905.2.4 Passing the RESNET Quality Assurance Designee Test. 905.2.4.1 The requirements of 905.2.2 and 905.2.3 must be met within twelve (12) months of passing the RESNET Quality Assurance Designee Test, or the individual must pass the test again prior to being recognized as a QA Designee. 905.2.5 Submit an application to RESNET and be recognized as a qualified QA Designee. 905.2.3905.3 Professional Development for Quality Aagents Designees 905.2.3.1905.3.1 All Quality Agents Designees annually shall: complete a two hour RESNET QA Roundtable on current information AND complete one (1) of the following activities: 905.2.3.1.1905.3.1.1 Document 12 hours of attendance at the RESNET Conference; or and 905.2.3.1.2905.3.1.2 Complete 12 hours of RESNET approved CEU’s; or Participate in a one-day in-person RESNET update and training.
Replace with a proposed amendment to Chapter 2, following the correct process laid out in the RESNET non-ANSI Standards Development Policy and Procedure Manual.
Reason: certification requirements for QADs have always been in chapter nine
Comment #333Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 37Paragraph / Figure / Table / Note: 905.2.2.1Comment Intent: Not an ObjectionComment Type: GeneralComment: I have questions about the highlighted text below: 905.2.2.1 Attend and successfully complete an on-site RESNET Quality Agent Instruction and Assessment Certification event; How often will this be held? Will it be facilitated by RESNET Staff or by Training Providers? What would this even look like? Would it only be held at the RESNET Conference? Proposed Change: N/A, I only have questions. Response: Reject Reason: No proposed change. These questions will be answered outside of the standards
I have questions about the highlighted text below:
How often will this be held? Will it be facilitated by RESNET Staff or by Training Providers? What would this even look like? Would it only be held at the RESNET Conference?
N/A, I only have questions.
Reason: No proposed change. These questions will be answered outside of the standards
Comment #334Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 37Paragraph / Figure / Table / Note: 905.2.2.2Comment Intent: ObjectionComment Type: GeneralComment: I have issues with the highlighted text: 905.2.2.2 Pass the National Quality Agent Competency Test with a minimum score determined by RESNET; My issues breakdown like this: 1) Is RESNET specifically RESNET Staff or the Board of Directors or is it SDC 900? If it's staff, no offense but they haven't taken any of the tests we have to so they are the least qualified to determine an actual minimum score. SDC 900 could potentially decide the score, because it's an interpretation of a part of Chapter 9. I'd prefer the Board of Directors, because it covers all the stakeholders out there. 2) Regardless of who is actually determining the score, the language here as it stands in the proposed Standards would allow the determining party to decide on a minimum score on a case-by-case basis. Holy moley. This is a huge issue, and if you can't see that, you're blind. 3) By having such vague language, you're reducing the quality of our standards. It should be a specific score, instead of "...with a minimum score determined by RESNET;" My suggestion? Put in an actual score instead of trying to retroactively apply one! Proposed Change: 905.2.2.2 Pass the National Quality Agent Competency Test with a minimum score of 90%determined by RESNET; Response: Reject Reason: Test is still under development so a minimum score should not set yet
I have issues with the highlighted text:
My issues breakdown like this:
1) Is RESNET specifically RESNET Staff or the Board of Directors or is it SDC 900? If it's staff, no offense but they haven't taken any of the tests we have to so they are the least qualified to determine an actual minimum score. SDC 900 could potentially decide the score, because it's an interpretation of a part of Chapter 9. I'd prefer the Board of Directors, because it covers all the stakeholders out there.
2) Regardless of who is actually determining the score, the language here as it stands in the proposed Standards would allow the determining party to decide on a minimum score on a case-by-case basis. Holy moley. This is a huge issue, and if you can't see that, you're blind.
3) By having such vague language, you're reducing the quality of our standards. It should be a specific score, instead of "...with a minimum score determined by RESNET;"
My suggestion? Put in an actual score instead of trying to retroactively apply one!
905.2.2.2 Pass the National Quality Agent Competency Test with a minimum score of 90%determined by RESNET;
Reason: Test is still under development so a minimum score should not set yet
Comment #335Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-16Paragraph / Figure / Table / Note: 905.2.2.2 and 905.2.2.3Comment Intent: ObjectionComment Type: TechnicalComment: Where did 25 come from? It's just enough of a barrier to entry if the Quality Agent was not a practicing HERS Rater, but it's a laughably low level if they were/are a practicing HERS Rater who's on his way to becoming a Quality Agent. If the protocol is to have five homes reviewed (I agree - it feels like a good number), then the number of Ratings that would naturally provide the HERS Rater with 5 QA Field reviews is 500 (or 5 years' experience). 100 is also arbitrary but 25 is just so low if the goal is to convert practicing HERS Raters into Quality Agents. Non-compliance issues are those that violate 904.3.3 which includes provisions for "insignificant" non-compliance issues. Our QA Field review to QA File review ratio is 1 out of 10; 1 QA Field review is required for every 10 QA File reviews. Since this ratio has been significant in our industry for some time (and I don't disagree), why not use this ratio to prescribe the training rate for Quality Agents? They will need to be very familiar with whatever software programs their Raters will be using and will generally need to demonstrate their competence in performing Ratings on a wide variety of housing types with a wide variety of specifications. Proposed Change: 905.2.2.4.2 As a certified Home Energy HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) one hundred (100) homes, five (5) of which must have received quality assurance QA Field reviews in accordance with these Standards without significant any non-compliance issues prior to becoming a QA Designee; or 905.2.2.4.3 Complete QA Field reviews on a minimum of fifteen (15) five (5) homes and QA File reviews on a minimum of ten (10) fifty (50) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent. Response: Reject Reason: 25 ratings as a certified rater is a reasonable entry point for becoming QA Agent. 905.2.2.4.3 will be revised to require 10 field QA reviews and 20 file QA reviews
Where did 25 come from? It's just enough of a barrier to entry if the Quality Agent was not a practicing HERS Rater, but it's a laughably low level if they were/are a practicing HERS Rater who's on his way to becoming a Quality Agent. If the protocol is to have five homes reviewed (I agree - it feels like a good number), then the number of Ratings that would naturally provide the HERS Rater with 5 QA Field reviews is 500 (or 5 years' experience). 100 is also arbitrary but 25 is just so low if the goal is to convert practicing HERS Raters into Quality Agents.
Non-compliance issues are those that violate 904.3.3 which includes provisions for "insignificant" non-compliance issues.
Our QA Field review to QA File review ratio is 1 out of 10; 1 QA Field review is required for every 10 QA File reviews. Since this ratio has been significant in our industry for some time (and I don't disagree), why not use this ratio to prescribe the training rate for Quality Agents? They will need to be very familiar with whatever software programs their Raters will be using and will generally need to demonstrate their competence in performing Ratings on a wide variety of housing types with a wide variety of specifications.
905.2.2.4.2 As a certified Home Energy HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) one hundred (100) homes, five (5) of which must have received quality assurance QA Field reviews in accordance with these Standards without significant any non-compliance issues prior to becoming a QA Designee; or
905.2.2.4.3 Complete QA Field reviews on a minimum of fifteen (15) five (5) homes and QA File reviews on a minimum of ten (10) fifty (50) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent.
Reason: 25 ratings as a certified rater is a reasonable entry point for becoming QA Agent. 905.2.2.4.3 will be revised to require 10 field QA reviews and 20 file QA reviews
Comment #336Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 37Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: EditorialComment: I have a problem with the highlighted text below: 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; I understand the intent of this highlighted text. You don't want Quality Agents to be actively doing HERS Ratings. That's obvious. The problem is the language of this would affect anyone who is a HERS Rater in the RESNET National Registry. If they can't be active, i.e. actively doing ratings, what else would they be? A current glance at the available stasuses to put a HERS Rater or RFI into yields the following categories: Active Inactive Suspended - Administrative Suspended - Disciplinary Probation - Disciplinary Terminated - Administrative Terminated - Disciplinary (Revoked) So which one would a certified HERS Rater/RFI who has become a Quality Agent fit in? Another layer to this problem: What if this individual works for code officials or utility programs, but have to be considered "active" in the public access of the RESNET Registry to continue to work for them? They don't do any testing, it's just walk-through visual inspections and whatnot, so they're not actively doing any HERS Ratings. Which category would this Quality Agent fit in to allow them to be "active" Raters, without actively doing ratings? The answer: None of the above. There is not one category above that accurately reflects the true status of a Quality Agent in the RESNET National Registry. Until that functionality gets added to the RESNET National Registry, I move that certain language gets struck from this proposed standard. Proposed Change: 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; Response: Reject Reason: The inactive status would cover the QA Agent’s status
I have a problem with the highlighted text below:
I understand the intent of this highlighted text. You don't want Quality Agents to be actively doing HERS Ratings. That's obvious.
The problem is the language of this would affect anyone who is a HERS Rater in the RESNET National Registry. If they can't be active, i.e. actively doing ratings, what else would they be? A current glance at the available stasuses to put a HERS Rater or RFI into yields the following categories:
So which one would a certified HERS Rater/RFI who has become a Quality Agent fit in?
Another layer to this problem: What if this individual works for code officials or utility programs, but have to be considered "active" in the public access of the RESNET Registry to continue to work for them? They don't do any testing, it's just walk-through visual inspections and whatnot, so they're not actively doing any HERS Ratings. Which category would this Quality Agent fit in to allow them to be "active" Raters, without actively doing ratings?
The answer: None of the above. There is not one category above that accurately reflects the true status of a Quality Agent in the RESNET National Registry.
Until that functionality gets added to the RESNET National Registry, I move that certain language gets struck from this proposed standard.
Reason: The inactive status would cover the QA Agent’s status
Comment #337Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: TechnicalComment: There is concern that the complete prohibition on quality agents performing any ratings could result in a shortage of quality agents or increase the cost of ratings, and is un-necessary to achieve the goals of independent QA. Some active raters could be trained to also serve as quality agents, and could serve as backup regionally as long as independence is maintained. Proposed Change: 905.2.2.3 RESNET certified Quality Agents shall not be who are active certified HERS Raters or RFI’s or perform any work on ratings shall not serve as primary quality agent for any provider and shall not perform quality assurance for any company with whom they have a current or past employment, or contractual relationship.; Response: Accept Reason: Accept in principle. Revised section to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
There is concern that the complete prohibition on quality agents performing any ratings could result in a shortage of quality agents or increase the cost of ratings, and is un-necessary to achieve the goals of independent QA. Some active raters could be trained to also serve as quality agents, and could serve as backup regionally as long as independence is maintained.
905.2.2.3 RESNET certified Quality Agents shall not be who are active certified HERS Raters or RFI’s or perform any work on ratings shall not serve as primary quality agent for any provider and shall not perform quality assurance for any company with whom they have a current or past employment, or contractual relationship.;
Reason: Accept in principle. Revised section to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
Comment #338Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: EditorialComment: This is unnecessary considering it has been accepted that an organization can be both a Direct Rating Provider and a QA Contractor and the rules of engaging in both activities has been clearly defined so there would be no conflict. It is also beneficial to the growth of raters and the quality of QA to allow this, since: Professional growth for raters … very experienced raters would naturally progress to be QA Agents if they so desired and a hard stop of being active to not being active so they can start doing QA seems unrealistic and not appropriate Quality of QA … The best QA personnel are the ones that still have their pulse on the rating work. They are in it and see the challenges and variations of doing ratings in a world of changing building techniques, technology, standards and software. Proposed Change: 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; Response: Accept Reason: Accept in principle. Revised section to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
This is unnecessary considering it has been accepted that an organization can be both a Direct Rating Provider and a QA Contractor and the rules of engaging in both activities has been clearly defined so there would be no conflict.
It is also beneficial to the growth of raters and the quality of QA to allow this, since:
Comment #339Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: TechnicalComment: I believe this section is unnecessary because of the proposed financial interest disclosures in 103.1.2.1.1 and the new definition of financial interest. Quality Agents should be allowed to remain active Raters as long as they are not providing QA on their own Ratings. I believe remaining an active Rating provides valuable experience. This is in alignment with current Standards and requirements for QADs. Proposed Change: 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings they are providing Quality Assurance services on; Response: Accept Reason: Accept in principle. Revised section to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
I believe this section is unnecessary because of the proposed financial interest disclosures in 103.1.2.1.1 and the new definition of financial interest. Quality Agents should be allowed to remain active Raters as long as they are not providing QA on their own Ratings. I believe remaining an active Rating provides valuable experience. This is in alignment with current Standards and requirements for QADs.
905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings they are providing Quality Assurance services on;
Comment #340Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: TechnicalComment: 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; 905.1 Quality Assurance Contractor…. 905.1.3.4.5 Shall not provide other HERS rating services. The proposed changes would limit the opportunities to create year round revenue and potentially hurt the overall quality of ratings for large rating providers with multiple lines of buisiness. I believe with the robust proposal of financial interest disclosures in 103.1.2.1.1 and the new definition of financial interest that we have much more clear delineations of not being able to QA anyone with a “employer/employee/contractor relationship”. Having RESNET Staff review the disclosures of the QA contractor and Provider relationships, before approving their partnership is a catch all fail safe that will allow them to apply the financial interest definitions in the standard as it fits with all of the varying circumstances that may arise. Particularly strong is the following section: 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. I believe this eliminates the need for other exclusions and will allow the market to decide who is best fit for QA Contractor services. Adding to these exclusions by creating delineations where QA Agents can’t be raters and where Rating Companies can’t also be QA Contractors isn’t necessary to meeting the proposed definition of financial interest and seems to be a high risk low reward proposition for the industry to endeavor during a time of big change. I propose to remove these sections of the proposed standard as I believe it will create a void that cannot be filled without consequence to the quality and consistency in the rating product. The proposed sections would require having to “give-up” doing ratings to be a QA Agent and/or QA Contractor. Rating companies have been through the ropes, understand how to run a rating business, and understand the pitfalls. They typically have experienced raters who can further their career as QA Agents and still keep their work as productive raters. Turnover of good raters is a real issue in our industry. One way EnergyLogic has been able to keep our raters engaged is to allow them the opportunities to become QAD’s. Particularly beneficial is the collaboration with other raters in this process, and even more valuable when those Raters/QA Agents can see other markets. Eliminating the ability for a rater to also do QA could lead to more turnover of our best raters moving on to other endeavors. Every rater who does QA for us, tells us that they are a much better rater after having done some QA. Allowing raters to QA, makes for better raters and ratings. Rating companies also typically have seasonal work and QA Contracting could be a way for rating companies to level this out and more effectively use limited industry resources. Having an exclusion where a QA Agent can’t be an active rater eliminates this efficiency and stretches our resources thin. Having raters as QA Agents would allow us to keep a “bullpen” of QA Agents who can be effective in their work in QA during slower builder seasons, and help the rating operation during the busier seasons, helping boost the quality of ratings during those busy times. The value of the QA product should be competitive with active raters being able to do QA. Creating this exclusion eliminates the direct contact of a rater with active, experienced raters in the QA process. Experienced Rating Companies have the resources and know-how to make excellent QA Contracting Companies. The most qualified individuals to be QA Agents are current QADs. Not allowing rating companies to keep their QADs to become QA Agents, puts an unnecessary administrative and financial burden on those QADs. It would require QADs to break from their current rating companies to form a new Contractor Company and take on similar administrative overhead. This is not a great use of industry resources that could otherwise be shared across one company. Perspective QA Contractor companies will need to juggle taking on significant growing demand for contracted QA. I think there would be better focus on the important work of improved quality of ratings if we didn’t put these unnecessary administrative burdens on QA Contractor companies to form their own business while also navigating the waters of all these changes. This shift in 3rd Party QA is a critical one for the industry. Allowing Rating companies to also be QA Contractors and QA Agents to be Active Raters, would allow the industry to more smoothly make this much needed shift, but do so in an effective and minimally disruptive manner. The QA Agent training will be a filtering mechanism to allow the best, most qualified raters to become QA Agents. Couple this with the approval process in section 103.1.2, whereby RESNET Staff reviews the conflicts of interest disclosures really strengthens the process of approval for a QA relationship. Our network is already being stretched for resources given all of the valuable proposals. Cutting the most experienced people and rating companies out of the process of QA when there is no conflict of interest, diminishes the value of the Rating and QA products. Proposed Change: QA Agents 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; QA Contractors 905.1.3.45 Shall not provide other HERS rating services. Amendment: 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership and/or operate as a QA Contractor. However, the organization’s Third-Party Rating Quality Assurance Providership, QA Contractor Operation, and/or QA Agents may not perform RESNET quality assurance of the Direct Provider’s work. Response: Accept Reason: Accept in principle. Revised section to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; 905.1 Quality Assurance Contractor…. 905.1.3.4.5 Shall not provide other HERS rating services.
The proposed changes would limit the opportunities to create year round revenue and potentially hurt the overall quality of ratings for large rating providers with multiple lines of buisiness.
I believe with the robust proposal of financial interest disclosures in 103.1.2.1.1 and the new definition of financial interest that we have much more clear delineations of not being able to QA anyone with a “employer/employee/contractor relationship”. Having RESNET Staff review the disclosures of the QA contractor and Provider relationships, before approving their partnership is a catch all fail safe that will allow them to apply the financial interest definitions in the standard as it fits with all of the varying circumstances that may arise. Particularly strong is the following section:
I believe this eliminates the need for other exclusions and will allow the market to decide who is best fit for QA Contractor services. Adding to these exclusions by creating delineations where QA Agents can’t be raters and where Rating Companies can’t also be QA Contractors isn’t necessary to meeting the proposed definition of financial interest and seems to be a high risk low reward proposition for the industry to endeavor during a time of big change.
I propose to remove these sections of the proposed standard as I believe it will create a void that cannot be filled without consequence to the quality and consistency in the rating product. The proposed sections would require having to “give-up” doing ratings to be a QA Agent and/or QA Contractor. Rating companies have been through the ropes, understand how to run a rating business, and understand the pitfalls. They typically have experienced raters who can further their career as QA Agents and still keep their work as productive raters. Turnover of good raters is a real issue in our industry. One way EnergyLogic has been able to keep our raters engaged is to allow them the opportunities to become QAD’s. Particularly beneficial is the collaboration with other raters in this process, and even more valuable when those Raters/QA Agents can see other markets. Eliminating the ability for a rater to also do QA could lead to more turnover of our best raters moving on to other endeavors. Every rater who does QA for us, tells us that they are a much better rater after having done some QA. Allowing raters to QA, makes for better raters and ratings. Rating companies also typically have seasonal work and QA Contracting could be a way for rating companies to level this out and more effectively use limited industry resources. Having an exclusion where a QA Agent can’t be an active rater eliminates this efficiency and stretches our resources thin. Having raters as QA Agents would allow us to keep a “bullpen” of QA Agents who can be effective in their work in QA during slower builder seasons, and help the rating operation during the busier seasons, helping boost the quality of ratings during those busy times. The value of the QA product should be competitive with active raters being able to do QA. Creating this exclusion eliminates the direct contact of a rater with active, experienced raters in the QA process. Experienced Rating Companies have the resources and know-how to make excellent QA Contracting Companies. The most qualified individuals to be QA Agents are current QADs. Not allowing rating companies to keep their QADs to become QA Agents, puts an unnecessary administrative and financial burden on those QADs. It would require QADs to break from their current rating companies to form a new Contractor Company and take on similar administrative overhead. This is not a great use of industry resources that could otherwise be shared across one company. Perspective QA Contractor companies will need to juggle taking on significant growing demand for contracted QA. I think there would be better focus on the important work of improved quality of ratings if we didn’t put these unnecessary administrative burdens on QA Contractor companies to form their own business while also navigating the waters of all these changes. This shift in 3rd Party QA is a critical one for the industry. Allowing Rating companies to also be QA Contractors and QA Agents to be Active Raters, would allow the industry to more smoothly make this much needed shift, but do so in an effective and minimally disruptive manner. The QA Agent training will be a filtering mechanism to allow the best, most qualified raters to become QA Agents. Couple this with the approval process in section 103.1.2, whereby RESNET Staff reviews the conflicts of interest disclosures really strengthens the process of approval for a QA relationship. Our network is already being stretched for resources given all of the valuable proposals. Cutting the most experienced people and rating companies out of the process of QA when there is no conflict of interest, diminishes the value of the Rating and QA products.
QA Agents 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; QA Contractors 905.1.3.45 Shall not provide other HERS rating services. Amendment:
Comment #341Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 37Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: TechnicalComment: I'm commenting on this to see if it's even a possibility. I'm proposing that Quality Agents should be able to perform work on ratings under a separate providership, if there is no finanical interest as defined and approved by RESNET Proposed Change: 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings, under any Quality Assurance Contractor, Third Party Rating Quality Assurance Provider, or rating company for which he/she is providing quality assurance services for. In this case, quality assurance on the Quality Agent must be done through a separate Quality Assurance Contractor or Third Party Rating Quality Assurance Provider, as long as there is no finanical interest Response: Accept Reason: Accept in principle RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
I'm commenting on this to see if it's even a possibility. I'm proposing that Quality Agents should be able to perform work on ratings under a separate providership, if there is no finanical interest as defined and approved by RESNET
905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings, under any Quality Assurance Contractor, Third Party Rating Quality Assurance Provider, or rating company for which he/she is providing quality assurance services for. In this case, quality assurance on the Quality Agent must be done through a separate Quality Assurance Contractor or Third Party Rating Quality Assurance Provider, as long as there is no finanical interest
Reason: Accept in principle RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
Comment #342Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: GeneralComment: The reason for these proposed changes is to try to make sure there is a pool of available Quality Agents to accomodate surges in demand; losses of agents due to illness, job change, etc.; and other unforeseen circumstances that might put a strain of the ability of the primary 3rd party Quality Agents to adequately fulfill demand. Proposed Change: 905.2.2.3 RESNET certified Quality Agents shall not be who are active certified HERS Raters or RFI’s or perform any work on ratings shall not serve as primary quality agent for any provider and shall not perform quality assurance for any company with whom they have a current or past employment or contractual relationship. Response: Accept Reason: Accept in principle. Revised section to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
The reason for these proposed changes is to try to make sure there is a pool of available Quality Agents to accomodate surges in demand; losses of agents due to illness, job change, etc.; and other unforeseen circumstances that might put a strain of the ability of the primary 3rd party Quality Agents to adequately fulfill demand.
905.2.2.3 RESNET certified Quality Agents shall not be who are active certified HERS Raters or RFI’s or perform any work on ratings shall not serve as primary quality agent for any provider and shall not perform quality assurance for any company with whom they have a current or past employment or contractual relationship.
Comment #343Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 37Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: GeneralComment: If a company has a QA division that preforms 3rd party RESNET QA for a different provider why can't that QA Agent also complete ratings for thier own providership? The QA Agents in therory will be well trained and the most expirenced raters on staff. You are forcing potential QA Agents to pick ratings or QA when many may want to do both. What happens if there is not enought QA work for the QA Agent? Can the QA Agent switch between ratings and QA every year? Proposed Change: 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; Response: Accept Reason: Accept in principle. Revised section to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
If a company has a QA division that preforms 3rd party RESNET QA for a different provider why can't that QA Agent also complete ratings for thier own providership? The QA Agents in therory will be well trained and the most expirenced raters on staff. You are forcing potential QA Agents to pick ratings or QA when many may want to do both. What happens if there is not enought QA work for the QA Agent? Can the QA Agent switch between ratings and QA every year?
Comment #344Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-14, 9-15Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: TechnicalComment: 905.1.3.4.5 <<QA Agents shall not provide ... HERS rating services.>> 905.2.2.3 <<RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings;>> If a QA agent is required to disclose that they also perform ratings, then at that point their potential rater-client can then decide whether there is enough conflict of interest to sever that relationship. For example, our current QAConctractor does QA work and also performs ratings (they do not "QA" their own work). We do not perform QA services but do perform ratings. In this case, both GDS and our QAD consultant perform HERS ratings However, we not perform these services within each other’s geography. it would be economically and logistically infeasible for either of us to do ratings in each other’s geographies. Therefore, given that we are not stepping on each other’s toes I have concluded that there is no conflict of interest or opportunity for collusion. They are a completely independent and third-party QAD. In section 103.1.2.2, RESNET reserves itself the right to veto QA contractor selection based upon actual or perceived conflicts of interest. We could assume that this clause is in place to protect raters from unscrupulous QAD/Raters that may be seeking unfair competitive advantage in the market for HERS ratings. However, in a free and open market, raters can decide whether there is a perceived conflict of interest; whether they confirm that their QA Contractor will be impartial in their QA review process. Therefore, the proposed Section 905.2.2.3 is an unnecessary restriction that would NOT result in greater consistency or integrity, but rather place undue hardship upon a blossoming QA Contractor market. Proposed Change: QA Agents 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; QA Contractors 905.1.3.45 Shall not provide other HERS rating services. Amendment: 103.1.3 An organization classified as a "Direct Rating Quality Assurance Provider" may also contain a separate Third-Party Rating Quality Assurance Providership and/or operate as a QA Contractor providing QA services to independent raters. However, this Third-Party Rating QA contractor may not perform RESNET quality assurance of the ratings performed by the Direct Provider entity. Response: Accept Reason: Accept in principle. Revised section to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
905.1.3.4.5 <<QA Agents shall not provide ... HERS rating services.>>
905.2.2.3 <<RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings;>>
If a QA agent is required to disclose that they also perform ratings, then at that point their potential rater-client can then decide whether there is enough conflict of interest to sever that relationship.
For example, our current QAConctractor does QA work and also performs ratings (they do not "QA" their own work). We do not perform QA services but do perform ratings. In this case, both GDS and our QAD consultant perform HERS ratings However, we not perform these services within each other’s geography. it would be economically and logistically infeasible for either of us to do ratings in each other’s geographies. Therefore, given that we are not stepping on each other’s toes I have concluded that there is no conflict of interest or opportunity for collusion. They are a completely independent and third-party QAD.
In section 103.1.2.2, RESNET reserves itself the right to veto QA contractor selection based upon actual or perceived conflicts of interest. We could assume that this clause is in place to protect raters from unscrupulous QAD/Raters that may be seeking unfair competitive advantage in the market for HERS ratings. However, in a free and open market, raters can decide whether there is a perceived conflict of interest; whether they confirm that their QA Contractor will be impartial in their QA review process. Therefore, the proposed Section 905.2.2.3 is an unnecessary restriction that would NOT result in greater consistency or integrity, but rather place undue hardship upon a blossoming QA Contractor market.
103.1.3 An organization classified as a "Direct Rating Quality Assurance Provider" may also contain a separate Third-Party Rating Quality Assurance Providership and/or operate as a QA Contractor providing QA services to independent raters. However, this Third-Party Rating QA contractor may not perform RESNET quality assurance of the ratings performed by the Direct Provider entity.
Comment #345Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: GeneralComment: Section 905.2 defines the roles and requirements of a Quality Agent. Section 905.2.2.3 restricts the Quality Agent from serving as an active HERS Rater, RFI or perfoming any work on ratings. (What ever that means). In underserved areas with few raters and few ratings performed annually, Placing restrictions on the services that qualified personnel can perform is counter-productive. These underserved areas with low numbers of ratings, often located in rural areas represent a growth opportunity for RESNET and for the improvement in residential energy efficiency. RESNET should define what these under-served areas or areas with low numbers of reported ratings per geographic region are. Based on this designation, certain provisions and exceptions to raters, Quality Agents, and providers should be granted to stimulate more rapid adoption of the HERS index. Proposed Change: 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings, except in designated underserved areas. Response: Reject Reason: QA contractors should be able to offer rating services because a direct provider may have a third-party division and this restriction contradicts that. Any potential conflict of interest can be covered by the contract between the provider and QA contractor
Section 905.2 defines the roles and requirements of a Quality Agent.
Section 905.2.2.3 restricts the Quality Agent from serving as an active HERS Rater, RFI or perfoming any work on ratings. (What ever that means).
In underserved areas with few raters and few ratings performed annually, Placing restrictions on the services that qualified personnel can perform is counter-productive. These underserved areas with low numbers of ratings, often located in rural areas represent a growth opportunity for RESNET and for the improvement in residential energy efficiency.
905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings, except in designated underserved areas.
Comment #346Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: TechnicalComment: There is no reason to eliminate an individual's professional certification of "HERS Rater" when there is ample wording elsewhere in the standard to prevent the conflict of interest this is intended to prevent. Proposed Change: 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings while actively employed as a Quality Agent. Response: Accept Reason: Accept in principle. Revised section to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
There is no reason to eliminate an individual's professional certification of "HERS Rater" when there is ample wording elsewhere in the standard to prevent the conflict of interest this is intended to prevent.
905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings while actively employed as a Quality Agent.
Comment #347Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: GeneralComment: Why the need to prohibit a Quality Agent from being a certified HERS Rater or RFI or to perform work on ratings? If a Quality Agent does some rating work for one Provider in the capacity of a HERS Rater and works separately for a Quality Assurance Contractor that has no financial relationship with that Provider and performs no Quality Assurance work for that Provider, there doesn't seem to be any potential for conflict. Rather, it would give the Quality Agent more practical field and rating experience, only helping to make them better at QA. Proposed Change: 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; Response: Accept Reason: Accept in principle. Revised section to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
Why the need to prohibit a Quality Agent from being a certified HERS Rater or RFI or to perform work on ratings? If a Quality Agent does some rating work for one Provider in the capacity of a HERS Rater and works separately for a Quality Assurance Contractor that has no financial relationship with that Provider and performs no Quality Assurance work for that Provider, there doesn't seem to be any potential for conflict. Rather, it would give the Quality Agent more practical field and rating experience, only helping to make them better at QA.
Comment #348Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 37Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: TechnicalComment: 905.2.2.3 strike as unnecessary. 1. There should be no reason why a QA agent cannot be a hers rater or RFI. 2. This standard covers elsewhere that you cannot perform QA your own work and thus should leave this option open for Quality Agents. Proposed Change: 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; Response: Accept Reason: Accept in principle. Revised section to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
905.2.2.3 strike as unnecessary.
1. There should be no reason why a QA agent cannot be a hers rater or RFI.
2. This standard covers elsewhere that you cannot perform QA your own work and thus should leave this option open for Quality Agents.
Comment #349Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-14, 9-15Paragraph / Figure / Table / Note: 905.2.2.3Comment Intent: ObjectionComment Type: TechnicalComment: Proposed objection: 905.1 Quality Assurance Contractor…. 905.1.3.4.5 Shall not provide other HERS rating services. 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; We believe with the robust proposal of financial interest disclosures in 103.1.2.1.1 and the new definition of financial interest that we have much more clear delineations of not being able to QA anyone with a “employer/employee/contractor relationship”. Having RESNET Staff review the disclosures of the QA Contractor and Provider relationships, before approving their partnership, is a “catch all” fail safe that will allow RESNET to apply the financial interest definitions in the standard in a way that fits all of the varying circumstances that may arise. Particularly strong is the following section: 103.1.2.2 In order to maintain the highest level of integrity for the Rating Industry, RESNET may place restrictions on Quality Assurance Contractor selection by Direct Providers, other than financial interest, if it deems necessary to avoid other actual or perceived conflicts of interest. We believe this eliminates the need for other exclusions and will allow the market to decide who is best fit for QA Contractor services. Adding to these exclusions by creating delineations where QA Agents can’t be raters and where Rating Companies can’t also be QA Contractors isn’t necessary to meeting the proposed definition of financial interest. This seems to be a high-risk, low-reward proposition for the industry to endeavor during a time of big change. We propose to remove these sections of the proposed standard as we believe it will create a void that cannot be filled without consequence to the quality and consistency in the rating product. The proposed sections would require having to forfiet being a HERS Rater to be a QA Agent and/or QA Contractor. Experienced HERS Raters and and their respective companies have been through the ups and downs of the industry understand how to run a rating business, and understand the pitfalls. They typically have experienced raters who can further their career as QA Agents and still keep their work as productive raters. Turnover of good raters is a real issue in our industry. Thus, eliminating the ability for a rater to also do QA could lead to more turnover of our best raters moving on to other endeavors. Allowing raters to QA, makes for better raters and ratings. The value of the QA product should be competitive with active raters being able to do QA. Creating this exclusion eliminates the direct contact of a rater with active, experienced raters in the QA process. Experienced Rating Companies have the resources and know-how to make excellent QA Contracting Companies. The most qualified individuals to be QA Agents are current QADs. Not allowing rating companies to keep their QADs to become QA Agents, puts an unnecessary administrative and financial burden on those QADs. It would require QADs to break from their current rating companies to form a new Contractor Company and take on similar administrative overhead. This is not a great use of industry resources that could otherwise be shared across one company. Perspective QA Contractor companies will need to juggle taking on significant growing demand for contracted QA. I think there would be better focus on the important work of improved quality of ratings if we didn’t put these unnecessary administrative burdens on QA Contractor companies to form their own business, while also navigating the waters of all these changes. This shift in external QA is a critical one for the industry. Allowing Rating companies to also be QA Contractors and QA Agents to be Active Raters, would allow the industry to more smoothly make this much needed shift, but do so in an effective and minimally disruptive manner. The QA Agent training will be a filtering mechanism to allow the best, most qualified raters to become QA Agents. Along with the approval process in section 103.1.2, whereby RESNET Staff reviews the conflicts of interest disclosures and we have a really strong QA path in the process of approval for a QA relationship. Our network is already being stretched for resources given all of the valuable proposals. In cases where there is no conflict of interest, cutting the most experienced people and rating companies out of the process of QA seems to be a high-risk, low-reward proposition that diminishes the value of the Rating and QA products. Proposed Change: Proposed Change to Amendment: QA Agents 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; QA Contractors 905.1.3.45 Shall not provide other HERS rating services. Amendment: 103.1.3 An organization who is a Direct Rating Quality Assurance Provider may also have a separate Third-Party Rating Quality Assurance Providership and/or operate as a QA Contractor. However, the organization’s Third-Party Rating Quality Assurance Providership, QA Contractor Operation, and/or QA Agents may not perform RESNET quality assurance of the Direct Provider’s work. Response: Accept Reason: Accept in principle. Revised section to read: RESNET certified Quality Agents shall not conduct ratings under any Quality Assurance Contractor, Third Party or Direct Provider, or rating company for which he/she is providing quality assurance services. If the Quality Agent conducts a rating it shall be certified under a separate Third Party or Direct Provider. Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
Proposed objection: 905.1 Quality Assurance Contractor…. 905.1.3.4.5 Shall not provide other HERS rating services. 905.2.2.3 RESNET certified Quality Agents shall not be active certified HERS Raters or RFI’s or perform any work on ratings; We believe with the robust proposal of financial interest disclosures in 103.1.2.1.1 and the new definition of financial interest that we have much more clear delineations of not being able to QA anyone with a “employer/employee/contractor relationship”. Having RESNET Staff review the disclosures of the QA Contractor and Provider relationships, before approving their partnership, is a “catch all” fail safe that will allow RESNET to apply the financial interest definitions in the standard in a way that fits all of the varying circumstances that may arise.
Particularly strong is the following section:
We believe this eliminates the need for other exclusions and will allow the market to decide who is best fit for QA Contractor services. Adding to these exclusions by creating delineations where QA Agents can’t be raters and where Rating Companies can’t also be QA Contractors isn’t necessary to meeting the proposed definition of financial interest. This seems to be a high-risk, low-reward proposition for the industry to endeavor during a time of big change.
We propose to remove these sections of the proposed standard as we believe it will create a void that cannot be filled without consequence to the quality and consistency in the rating product. The proposed sections would require having to forfiet being a HERS Rater to be a QA Agent and/or QA Contractor. Experienced HERS Raters and and their respective companies have been through the ups and downs of the industry understand how to run a rating business, and understand the pitfalls. They typically have experienced raters who can further their career as QA Agents and still keep their work as productive raters. Turnover of good raters is a real issue in our industry. Thus, eliminating the ability for a rater to also do QA could lead to more turnover of our best raters moving on to other endeavors. Allowing raters to QA, makes for better raters and ratings. The value of the QA product should be competitive with active raters being able to do QA. Creating this exclusion eliminates the direct contact of a rater with active, experienced raters in the QA process. Experienced Rating Companies have the resources and know-how to make excellent QA Contracting Companies. The most qualified individuals to be QA Agents are current QADs. Not allowing rating companies to keep their QADs to become QA Agents, puts an unnecessary administrative and financial burden on those QADs. It would require QADs to break from their current rating companies to form a new Contractor Company and take on similar administrative overhead. This is not a great use of industry resources that could otherwise be shared across one company. Perspective QA Contractor companies will need to juggle taking on significant growing demand for contracted QA. I think there would be better focus on the important work of improved quality of ratings if we didn’t put these unnecessary administrative burdens on QA Contractor companies to form their own business, while also navigating the waters of all these changes. This shift in external QA is a critical one for the industry. Allowing Rating companies to also be QA Contractors and QA Agents to be Active Raters, would allow the industry to more smoothly make this much needed shift, but do so in an effective and minimally disruptive manner. The QA Agent training will be a filtering mechanism to allow the best, most qualified raters to become QA Agents. Along with the approval process in section 103.1.2, whereby RESNET Staff reviews the conflicts of interest disclosures and we have a really strong QA path in the process of approval for a QA relationship. Our network is already being stretched for resources given all of the valuable proposals. In cases where there is no conflict of interest, cutting the most experienced people and rating companies out of the process of QA seems to be a high-risk, low-reward proposition that diminishes the value of the Rating and QA products.
Comment #350Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 37-38Paragraph / Figure / Table / Note: 905.2.2.4 through 905.2.2.4.3Comment Intent: ObjectionComment Type: EditorialComment: I have an issue with the following highlighted text: 905.2.2.4 Meet the following experience requirements: 905.2.2.4.1 Previous certification as a RESNET HERS Rater; and 905.2.2.4.2 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues or 905.2.2.4.3 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent. Here's my problem: This negatively affects anyone who got the QAD certification but hasn't performed enough field and file reviews on HERS Raters. Reminder- to do 15 QA field reviews, you'd have to have a Rater, Raters or Rating company that does anywhere from 15 ratings (15 different raters) to 1500 ratings (1 rater/rating company). Now either you're an extremely lucky QAD who only has small rating companies and don't have to review 1500 ratings, or you're luck and have a lot of business. Obviously the 10 QA file reviews is a lot simpler to reach. So my question is- why didn't we just straight add a grandfather option to these proposed standards? It's obvious they already passed an exam to do quality assurance work, and remember the requirements to become a QAD- they have to pass that test with a 90% and have at least twenty-five ratings that have had 5 field reviews. Why isn't that good enough to be straight grandfathered in to meet the experience requirement? I move to add specific language that allows anyone who is in good standing and has a QAD certification to meet the experience requirement to become a Quality Agent. Note: I will also be renumbering these to reflect my suggested comment about the current problems with the structure Proposed Change: 905.2.2.4 Meet the following experience requirements: 905.2.2.4.1 Previous certification as a RESNET HERS Rater; and 905.2.2.4.1.12 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues or 905.2.2.4.1.23 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent or 905.2.2.4.1.3 Previous certification as a Quality Assurance Designee (as previously allowed by RESNET) and be in good standing in the RESNET National Registry Response: Reject Reason: Having a minimum experience requirement is a reasonable expectation for Quality Agent qualifications
Here's my problem: This negatively affects anyone who got the QAD certification but hasn't performed enough field and file reviews on HERS Raters.
Reminder- to do 15 QA field reviews, you'd have to have a Rater, Raters or Rating company that does anywhere from 15 ratings (15 different raters) to 1500 ratings (1 rater/rating company). Now either you're an extremely lucky QAD who only has small rating companies and don't have to review 1500 ratings, or you're luck and have a lot of business.
Obviously the 10 QA file reviews is a lot simpler to reach.
So my question is- why didn't we just straight add a grandfather option to these proposed standards? It's obvious they already passed an exam to do quality assurance work, and remember the requirements to become a QAD- they have to pass that test with a 90% and have at least twenty-five ratings that have had 5 field reviews.
Why isn't that good enough to be straight grandfathered in to meet the experience requirement?
I move to add specific language that allows anyone who is in good standing and has a QAD certification to meet the experience requirement to become a Quality Agent.
Note: I will also be renumbering these to reflect my suggested comment about the current problems with the structure
905.2.2.4.1.12 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues or
905.2.2.4.1.23 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent or
905.2.2.4.1.3 Previous certification as a Quality Assurance Designee (as previously allowed by RESNET) and be in good standing in the RESNET National Registry
Reason: Having a minimum experience requirement is a reasonable expectation for Quality Agent qualifications
Comment #351Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 38Paragraph / Figure / Table / Note: 905.2.2.4.2Comment Intent: ObjectionComment Type: GeneralComment: I have a couple problems with the highlighted text below: 905.2.2.4.2 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues or We need to recognize something, right now: How many ratings would a HERS Rater have to complete to receive five QA field reviews? 500. That HERS Rater would have to complete 500 ratings to receive five QA field reviews. On top of that, if they use an RFI, the HERS Rater might not actually be the one getting field QA'd, because some of those field QA's can be done on the RFI in place of the Rater. What I'm trying to say is that this language is a backhanded way to require significant experience from a HERS Rater. Unless the rating company or HERS Rater wants to pay extra in order to get five QA field reviews before they hit 500 ratings, there isn't a good path forward. I appreciate what this language is trying to accomplish- I do- but this is not an equivalent path for individuals to achieve the required experience to become a Quality Agent, especially when compared to 905.2.2.4.3. My suggestion would be to have an upfront standard- if you want them to have a lot of experience as a HERS Rater, just say it. Numbers below are just suggestions I pulled from a hat, much like the 1% required field QAs and 10% required file QAs were. Proposed Change: 905.2.2.4.2 As a certified HERS Rater, complete confirmed ratings on a minimum of sixty (60) twenty-five (25) homes, three (3) five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues or Response: Reject Reason: Having a minimum of 5 field QA reviews is a reasonable expectation for Quality Agent qualifications in addition there alternative qualification path
I have a couple problems with the highlighted text below:
We need to recognize something, right now: How many ratings would a HERS Rater have to complete to receive five QA field reviews?
500.
That HERS Rater would have to complete 500 ratings to receive five QA field reviews. On top of that, if they use an RFI, the HERS Rater might not actually be the one getting field QA'd, because some of those field QA's can be done on the RFI in place of the Rater.
What I'm trying to say is that this language is a backhanded way to require significant experience from a HERS Rater. Unless the rating company or HERS Rater wants to pay extra in order to get five QA field reviews before they hit 500 ratings, there isn't a good path forward.
I appreciate what this language is trying to accomplish- I do- but this is not an equivalent path for individuals to achieve the required experience to become a Quality Agent, especially when compared to 905.2.2.4.3.
My suggestion would be to have an upfront standard- if you want them to have a lot of experience as a HERS Rater, just say it.
Numbers below are just suggestions I pulled from a hat, much like the 1% required field QAs and 10% required file QAs were.
905.2.2.4.2 As a certified HERS Rater, complete confirmed ratings on a minimum of sixty (60) twenty-five (25) homes, three (3) five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues or
Reason: Having a minimum of 5 field QA reviews is a reasonable expectation for Quality Agent qualifications in addition there alternative qualification path
Comment #352Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 38Paragraph / Figure / Table / Note: 905.2.2.4.2 and 905.2.2.4.3Comment Intent: Not an ObjectionComment Type: EditorialComment: I have a problem with the following highlighted text: 905.2.2.4.1 Previous certification as a RESNET HERS Rater; and 905.2.2.4.2 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues or 905.2.2.4.3 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent. In regards to the numbering of the proposed standards, right now it reads like this equation: 1 + 1 or 2. As you can see, if you tried to solve this math problem, you wouldn't be able to decide whether it's 1+1 or 1+2 because there isn't a clear delineation between "1+" and "1 or 2". To continue using an equation as an example, it should look like this: 1+(1 or 2). Simply put, my suggestion would be to just renumber 905.2.2.4.2 and 905.2.2.4.3 to accurately reflect to structure and intent of the proposed standards. Proposed Change: 905.2.2.4.1 Previous certification as a RESNET HERS Rater; and 905.2.2.4.?1.12 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues or 905.2.2.4.1.23 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent. Response: Reject Reason: consistent with current numbering of similar sections in the standard
I have a problem with the following highlighted text:
In regards to the numbering of the proposed standards, right now it reads like this equation: 1 + 1 or 2.
As you can see, if you tried to solve this math problem, you wouldn't be able to decide whether it's 1+1 or 1+2 because there isn't a clear delineation between "1+" and "1 or 2".
To continue using an equation as an example, it should look like this: 1+(1 or 2).
Simply put, my suggestion would be to just renumber 905.2.2.4.2 and 905.2.2.4.3 to accurately reflect to structure and intent of the proposed standards.
905.2.2.4.?1.12 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes, five (5) of which must have received quality assurance field reviews in accordance with these Standards without significant non-compliance issues or
905.2.2.4.1.23 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent.
Reason: consistent with current numbering of similar sections in the standard
Comment #353Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 38Paragraph / Figure / Table / Note: 905.2.2.4.3Comment Intent: Not an ObjectionComment Type: GeneralComment: I am very happy about the following highlighted text: 905.2.2.4.3 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent. Quality Agents would have a HERS Rater certification- so they have the base knowledge all HERS Raters are supposed to have, but they also have job training to help them be better prepared to do the actual quality assurance work. I don’t have a problem if they haven’t done a lot of ratings- I’d prefer someone who was trained to do the specific responsibilities of a quality agent. Outside of the poor language regarding the QADs, this is an excellent step forward. Response: Reject Reason: No proposed change submitted
I am very happy about the following highlighted text:
Quality Agents would have a HERS Rater certification- so they have the base knowledge all HERS Raters are supposed to have, but they also have job training to help them be better prepared to do the actual quality assurance work.
I don’t have a problem if they haven’t done a lot of ratings- I’d prefer someone who was trained to do the specific responsibilities of a quality agent. Outside of the poor language regarding the QADs, this is an excellent step forward.
Reason: No proposed change submitted
Comment #354Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 38Paragraph / Figure / Table / Note: 905.2.2.4.3Comment Intent: Not an ObjectionComment Type: TechnicalComment: The requirements for QA experience seems a bit skewed based on the percentages of QA required. We propose making them a bit more representative of the current QA percentages. Proposed Change: 905.2.2.43.3 Complete QA Field reviews on a minimum of fifteen ten (105) homes and QA File reviews on a minimum of ten twent-five (1025) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent. Response: Accept Reason: Accept in principle. Changed section to 10 field reviews and 20 file reviews per comment #332
The requirements for QA experience seems a bit skewed based on the percentages of QA required. We propose making them a bit more representative of the current QA percentages.
905.2.2.43.3 Complete QA Field reviews on a minimum of fifteen ten (105) homes and QA File reviews on a minimum of ten twent-five (1025) homes as either a Quality Assurance Designee (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent.
Reason: Accept in principle. Changed section to 10 field reviews and 20 file reviews per comment #332
Comment #355Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 38Paragraph / Figure / Table / Note: 905.2.2.43.3Comment Intent: Not an ObjectionComment Type: TechnicalComment: I believe that previuos certification as a QADD should count towards the experience requirements to become a Quality Agent. Proposed Change: 905.2.2.43.3 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee or Delegate (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent. Response: Accept Reason: reasonable addition considering that the delegate will need to pass the exam and training per section 905.2.2
I believe that previuos certification as a QADD should count towards the experience requirements to become a Quality Agent.
905.2.2.43.3 Complete QA Field reviews on a minimum of fifteen (15) homes and QA File reviews on a minimum of ten (10) homes as either a Quality Assurance Designee or Delegate (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent.
Reason: reasonable addition considering that the delegate will need to pass the exam and training per section 905.2.2
Comment #356Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 38Paragraph / Figure / Table / Note: 905.2.3Comment Intent: ObjectionComment Type: TechnicalComment: I believe the one day in person Quality Agent training is a great idea and should be required (with a virtual option) but do not think that the RESNET Conference should be a hard requirement, since there are always circumstances to where an individual can't afford to go or is not able to travel at that time of year. I suggest that the in person training be held at least twice a year, and one of those should be held before or after the annual RESNET Conference, so that those who choose to go to the RESNET Conference won't have to travel extensive distance again, for the one day in-person training Proposed Change: 905.2.3 Professional Development for Quality Agents 905.2.3.1 All Quality Agents annually shall: complete a two hour RESNET QA Roundtable on current information AND complete one (1) of the following activities: 905.2.3.1.1905.3.1.1 Document 12 hours of attendance at the RESNET Conference; or 12 hours of RESNET approved CEU's and 905.2.3.1.2905.3.1.2 Complete 12 hours of RESNET approved CEU’s; or Participate in a one-day in-person (or virtual) RESNET update and training. Response: Accept Reason: allows for more flexibility in meeting the professional development requirements
I believe the one day in person Quality Agent training is a great idea and should be required (with a virtual option) but do not think that the RESNET Conference should be a hard requirement, since there are always circumstances to where an individual can't afford to go or is not able to travel at that time of year.
I suggest that the in person training be held at least twice a year, and one of those should be held before or after the annual RESNET Conference, so that those who choose to go to the RESNET Conference won't have to travel extensive distance again, for the one day in-person training
905.2.3.1 All Quality Agents annually shall: complete a two hour RESNET QA Roundtable on current information AND complete one (1) of the following activities:
905.2.3.1.1905.3.1.1 Document 12 hours of attendance at the RESNET Conference; or 12 hours of RESNET approved CEU's
and
905.2.3.1.2905.3.1.2 Complete 12 hours of RESNET approved CEU’s; or Participate in a one-day in-person (or virtual) RESNET update and training.
Reason: allows for more flexibility in meeting the professional development requirements
Comment #357Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-16Paragraph / Figure / Table / Note: 905.2.3Comment Intent: ObjectionComment Type: TechnicalComment: I applaud this effort to up the game with QA Agents and their professional development. I think the one day QA focused training is a great idea. However, I have concerns with how restricted these options are. Primarily if someone were not able to attend for extenuating circumstances. For instance, what if someone were pregnant and couldn't attend. That's not fair to take their designation away because they were unable to travel. Illness, family emergencies, conflicts in general... all these things happen and are out of our control. I would like to pose an alternative that provides rigid flexibility. Continual training is the important thing and annually it seems like there are changes that require QA Agents to be on top of their game. The format of that training should be where we have flexibility as an industry. Why not create an open market for training/CEU and allow for flexibility in our options? Online trainings can be as effective or better than live trainings, particularly with complicated updates that require retention to effectively do you job. Live trainings may be preferable at times to (for instance if you are already going to the RESNET Conference). If RESNET had a list of approved QA courses wouldn't that meet the intent in a way that wouldn't put someone in a position to decide between their family/health and being a QA Agent. Proposed Change: 905.2.3..1 All Quality Agents annually shall: 905.2.3.1.1 Document 8 hours of attendance at the a RESNET Approved Conference course related to RESNET Quality Assurance. 905.2.3.1.2 Participate in a one-day in-person RESNET update andQuality Assurance Update and training. Response: Accept Reason: Accept in principle. Changes made per comment #354
I applaud this effort to up the game with QA Agents and their professional development. I think the one day QA focused training is a great idea. However, I have concerns with how restricted these options are. Primarily if someone were not able to attend for extenuating circumstances. For instance, what if someone were pregnant and couldn't attend. That's not fair to take their designation away because they were unable to travel. Illness, family emergencies, conflicts in general... all these things happen and are out of our control.
I would like to pose an alternative that provides rigid flexibility. Continual training is the important thing and annually it seems like there are changes that require QA Agents to be on top of their game. The format of that training should be where we have flexibility as an industry.
Why not create an open market for training/CEU and allow for flexibility in our options? Online trainings can be as effective or better than live trainings, particularly with complicated updates that require retention to effectively do you job. Live trainings may be preferable at times to (for instance if you are already going to the RESNET Conference).
If RESNET had a list of approved QA courses wouldn't that meet the intent in a way that wouldn't put someone in a position to decide between their family/health and being a QA Agent.
905.2.3..1 All Quality Agents annually shall:
905.2.3.1.1 Document 8 hours of attendance at the a RESNET Approved Conference course related to RESNET Quality Assurance.
905.2.3.1.2 Participate in a one-day in-person RESNET update andQuality Assurance Update and training.
Reason: Accept in principle. Changes made per comment #354
Comment #358Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-16Paragraph / Figure / Table / Note: 905.2.3.1Comment Intent: ObjectionComment Type: EditorialComment: we need options to the proposed requirement for Quality Agents to be at the RESNET conference. the conference. what if a QA cant make it or afford the expense of trip? current QA's have the option of attending the roundtable. we should still keep the roundtable format and allow RESNET approved CEUs Proposed Change: 905.2.3.1905.3.1 All Quality Agents annually shall: complete a two hour RESNET QA Roundtable on current information AND complete one (1) of the following activities: 905.2.3.1.1905.3.1.1 Document min 12 hours of attendance at the RESNET Conference; or and 905.2.3.1.2905.3.1.2 Complete 12 24 hours of RESNET approved CEU’s; or Participate in a one-day in-person RESNET update and training. Response: Accept Reason: Accept in principle. Changes made per comment #354
we need options to the proposed requirement for Quality Agents to be at the RESNET conference. the conference. what if a QA cant make it or afford the expense of trip? current QA's have the option of attending the roundtable. we should still keep the roundtable format and allow RESNET approved CEUs
905.2.3.1905.3.1 All Quality Agents annually shall: complete a two hour RESNET QA Roundtable on current information AND complete one (1) of the following activities: 905.2.3.1.1905.3.1.1 Document min 12 hours of attendance at the RESNET Conference; or and 905.2.3.1.2905.3.1.2 Complete 12 24 hours of RESNET approved CEU’s; or Participate in a one-day in-person RESNET update and training.
Comment #359Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-16Paragraph / Figure / Table / Note: 905.2.3.1Comment Intent: Not an ObjectionComment Type: GeneralComment: This will increase the cost to be a Quality Agent since they must attend the RESNET conference every year. Proposed Change: N/A Just an observation Response: Accept Reason: Accept in principle. Changes made per comment #354
This will increase the cost to be a Quality Agent since they must attend the RESNET conference every year.
Comment #360Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-19Paragraph / Figure / Table / Note: 905.2.3.1Comment Intent: Not an ObjectionComment Type: EditorialComment: There is no definition of this topic. Proposed Change: N/A Just an observation Response: Reject Reason: no proposed change
There is no definition of this topic.
Reason: no proposed change
Comment #361Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 38Paragraph / Figure / Table / Note: 905.2.3.1Comment Intent: ObjectionComment Type: TechnicalComment: Attendance at the RESNET Conference should not be required to be a QA Agent. There are many valid reasons why people cannot be in attendance at every single conference every single year, and they shouldn't have to justify it with a note from their doctor. Just because someone cannot attend the conference does not mean that they cannot learn the required material. Also, a robust QA market should include a robust training platform that allows RESNET Training Providers to offer courses related to quality assurance. This process should be more inclusive and allow QA Agents more opportunities to learn, not fewer. Proposed Change: 905.2.3.1905.3.1 All Quality Assurance Agents Designees annually shall: complete a two hour RESNET QA Roundtable on current information AND document 8 hours of attendance at a RESNET approved course(s) related to quality assurance. complete one (1) of the following activities: 905.2.3.1.1905.3.1.1 Document 12 hours of attendance at the RESNET Conference; or and 905.2.3.1.2905.3.1.2 Complete 12 hours of RESNET approved CEU’s; or Participate in a one-day in-person RESNET update and training. Response: Accept Reason: Accept in principle. Changes made per comment #354
Attendance at the RESNET Conference should not be required to be a QA Agent. There are many valid reasons why people cannot be in attendance at every single conference every single year, and they shouldn't have to justify it with a note from their doctor. Just because someone cannot attend the conference does not mean that they cannot learn the required material. Also, a robust QA market should include a robust training platform that allows RESNET Training Providers to offer courses related to quality assurance. This process should be more inclusive and allow QA Agents more opportunities to learn, not fewer.
905.2.3.1905.3.1 All Quality Assurance Agents Designees annually shall: complete a two hour RESNET QA Roundtable on current information AND document 8 hours of attendance at a RESNET approved course(s) related to quality assurance. complete one (1) of the following activities: 905.2.3.1.1905.3.1.1 Document 12 hours of attendance at the RESNET Conference; or and 905.2.3.1.2905.3.1.2 Complete 12 hours of RESNET approved CEU’s; or Participate in a one-day in-person RESNET update and training.
Comment #362Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 38Paragraph / Figure / Table / Note: 905.2.3.1.1Comment Intent: ObjectionComment Type: GeneralComment: I have a problem with the following highlighted language: 905.2.3.1.1 Document attendance at the RESNET Conference; and 905.2.3.1.2 Participate in a one-day in-person RESNET update and training. It should be optional to either attend the RESNET Conference or participate in a one day in-person RESNET update and training, plus you should have the choice to complete 12 RESNET CEUs if you can't make it to the RESNET Conference. Here's my reasoning for why the current language looks bad and doesn't make sense: If the one day in-person training will ONLY be held at the RESNET Conference, it's a given that your attendance is required at the RESNET Conference. It doesn't make sense to blatantly require people to attend the RESNET Conference. On the flip side, the current language suggests that the one-day training will be given throughout the year (quarterly?) at multiple locations- not just at the RESNET Conference. After all, why else would you make it mandatory to attend the conference and the training unless the training was going to be held throughout the year at multiple locations? Finally- if you're trying to require people to attend the RESNET Conference to "meet" the previous requirements to earn CEUs to maintain you certification, that is the definition of a cash grab (source). You are literally taking money from the trainers and other CEU-accredited events (RaterFest, Midwest Regional Energy Conference, etc.) and funneling it straight to RESNET's pockets, no ifs, ands, or buts. It's already an expensive choice, and by requiring attendance you're forcing quality agents to go to the Conference instead of other financially secure decisions (online CEUs, closer conferences). I actually missed this on my first and second read-throughs of the proposed standards, which makes me a little concerned for other stakeholders who may have missed this. This presents some really bad decisions by RESNET. I move to change the language to reflect an actual decision on behalf of the quality agents, as well as reincluding the previous continuing education requirements (if the quality agent chooses that path). My reasoning is that it looks really bad if RESNET is requiring Quality Agents to attend its annual conference and one day training, while removing previous choices from quality agents. Additionally, requiring attendance to the RESNET Conference may be difficult for some people, and letting them substitute attendance for CEU's just makes sense. I also fixed the structure to reflect the choice that quality agents should be able to make. Note: This is solely my opinion, and it does not reflect the opinion of my employer. I write this of my own free will, and if you'd like to debate this with me, please email me directly. Proposed Change: 905.2.3.1.1 Participate in a one-day in-person RESNET update and training. Document attendance at the RESNET Conference; and 905.2.3.1.1.12 Document attendance at the RESNET Conference or Participate in a one-day in-person RESNET update and training. 905.2.3.1.1.2 Complete twelve (12) hours of RESNET-approved continuing education units (CEUs). Response: Accept Reason: Accept in principle. Changes made per comment #354
I have a problem with the following highlighted language:
It should be optional to either attend the RESNET Conference or participate in a one day in-person RESNET update and training, plus you should have the choice to complete 12 RESNET CEUs if you can't make it to the RESNET Conference.
Here's my reasoning for why the current language looks bad and doesn't make sense:
If the one day in-person training will ONLY be held at the RESNET Conference, it's a given that your attendance is required at the RESNET Conference. It doesn't make sense to blatantly require people to attend the RESNET Conference.
On the flip side, the current language suggests that the one-day training will be given throughout the year (quarterly?) at multiple locations- not just at the RESNET Conference. After all, why else would you make it mandatory to attend the conference and the training unless the training was going to be held throughout the year at multiple locations?
Finally- if you're trying to require people to attend the RESNET Conference to "meet" the previous requirements to earn CEUs to maintain you certification, that is the definition of a cash grab (source). You are literally taking money from the trainers and other CEU-accredited events (RaterFest, Midwest Regional Energy Conference, etc.) and funneling it straight to RESNET's pockets, no ifs, ands, or buts. It's already an expensive choice, and by requiring attendance you're forcing quality agents to go to the Conference instead of other financially secure decisions (online CEUs, closer conferences). I actually missed this on my first and second read-throughs of the proposed standards, which makes me a little concerned for other stakeholders who may have missed this.
This presents some really bad decisions by RESNET. I move to change the language to reflect an actual decision on behalf of the quality agents, as well as reincluding the previous continuing education requirements (if the quality agent chooses that path). My reasoning is that it looks really bad if RESNET is requiring Quality Agents to attend its annual conference and one day training, while removing previous choices from quality agents. Additionally, requiring attendance to the RESNET Conference may be difficult for some people, and letting them substitute attendance for CEU's just makes sense.
I also fixed the structure to reflect the choice that quality agents should be able to make.
Note: This is solely my opinion, and it does not reflect the opinion of my employer. I write this of my own free will, and if you'd like to debate this with me, please email me directly.
905.2.3.1.1 Participate in a one-day in-person RESNET update and training. Document attendance at the RESNET Conference; and
905.2.3.1.1.12 Document attendance at the RESNET Conference or Participate in a one-day in-person RESNET update and training.
905.2.3.1.1.2 Complete twelve (12) hours of RESNET-approved continuing education units (CEUs).
Comment #363Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-16Paragraph / Figure / Table / Note: 905.2.3.1.1Comment Intent: ObjectionComment Type: EditorialComment: Miror language proposed for continuing education by RESNET Committee 200 and allow attendance at any RESNET approved conference and not only the RESNET Conference. Proposed Change: 905.2.3.1.1Document attendance at the a RESNET Conference; and Response: Accept Reason: Accept in principle. Changes made per comment #354
Miror language proposed for continuing education by RESNET Committee 200 and allow attendance at any RESNET approved conference and not only the RESNET Conference.
905.2.3.1.1Document attendance at the a RESNET Conference; and
Comment #364Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-16Paragraph / Figure / Table / Note: 905.2.3.1.1Comment Intent: ObjectionComment Type: GeneralComment: Attendance at the annual RESNET conference was an "or" previously, which gave people some leeway in case something came up that prevented attendance. If someone is not able to attend for a legitimate reason (death in the family, serious illness, etc), will they have another option to meet the professional development requirement? Or simply lose their certification? Proposed Change: Add back in an alternative way to meet the professional development requirements, or at least say what will happen if the conference attendance requirement is not met. Response: Accept Reason: Accept in principle. Changes made per comment #354
Attendance at the annual RESNET conference was an "or" previously, which gave people some leeway in case something came up that prevented attendance. If someone is not able to attend for a legitimate reason (death in the family, serious illness, etc), will they have another option to meet the professional development requirement? Or simply lose their certification?
Add back in an alternative way to meet the professional development requirements, or at least say what will happen if the conference attendance requirement is not met.
Comment #365Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 38Paragraph / Figure / Table / Note: 905.2.3.1.2Comment Intent: ObjectionComment Type: TechnicalComment: •905.2.3.1.2 If you attend a RESNET conference this should suffice instead of adding a "one day in person" training. This should also be offered regionally. QA agents may not be able to attend the RESNET conference and then a second meeting annualy, What happenes if your company chooses to be a QA agent, should all of your staff be vacant for the time of training from business? This makes no sense. Proposed Change: 905.2.3.1.2905.3.1.2 Complete 12 hours of RESNET approved CEU’s; or Participate in a one-day in-person RESNET update and training. Participate in a one day in person RESNET update and training class offered at the annual RESNET conference OR offered regionally at predetermined locations so as to fulfill annual accreditation requirements. Response: Accept Reason: Accept in principle. Changes made per comment #354
•905.2.3.1.2
If you attend a RESNET conference this should suffice instead of adding a "one day in person" training. This should also be offered regionally. QA agents may not be able to attend the RESNET conference and then a second meeting annualy, What happenes if your company chooses to be a QA agent, should all of your staff be vacant for the time of training from business? This makes no sense.
905.2.3.1.2905.3.1.2 Complete 12 hours of RESNET approved CEU’s; or Participate in a one-day in-person RESNET update and training.
Participate in a one day in person RESNET update and training class offered at the annual RESNET conference OR offered regionally at predetermined locations so as to fulfill annual accreditation requirements.
Comment #366Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 40 (9-18)Paragraph / Figure / Table / Note: 905.2.4.2.1Comment Intent: ObjectionComment Type: GeneralComment: This provision and the following provision are substantial extra workloads on a QAD, that should be an optional agreement between provider and QAD. Most providorship management can be held to maintain these roles and reduce the extra QAD costs that this language will require. It should be stated somewhere else in the standards that it is the providers responsibility to remain apprised of all changes to the standard. It is his option to pass it on to his hired QAD if he so chooses. Proposed Change: 905.2.4.2.1 Ensure that Rating Quality Assurance Providers are apprised of all changes to the RESNET ANSI and non-ANSI standards as they may occur. Response: Reject Reason: change to- Confirm that Rating Quality Assurance Providers are informed of all changes to the RESNET ANSI and non-ANSI standards.
This provision and the following provision are substantial extra workloads on a QAD, that should be an optional agreement between provider and QAD. Most providorship management can be held to maintain these roles and reduce the extra QAD costs that this language will require. It should be stated somewhere else in the standards that it is the providers responsibility to remain apprised of all changes to the standard. It is his option to pass it on to his hired QAD if he so chooses.
905.2.4.2.1 Ensure that Rating Quality Assurance Providers are apprised of all changes to the RESNET ANSI and non-ANSI standards as they may occur.
Reason: change to- Confirm that Rating Quality Assurance Providers are informed of all changes to the RESNET ANSI and non-ANSI standards.
Comment #367Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-15-18Paragraph / Figure / Table / Note: 905.2.4.2.1Comment Intent: ObjectionComment Type: EditorialComment: This section uses permissive language. Proposed Change: Strike and replace as written: 905.2.4.2.1 Ensure that Rating Quality Assurance Providers are apprised of all changes to the RESNET ANSI and non-ANSI standards as they may occur. Response: Accept Reason: Accept in principle change to- Confirm that Rating Quality Assurance Providers are informed of all changes to the RESNET ANSI and non-ANSI standards.
This section uses permissive language.
Strike and replace as written:
Reason: Accept in principle change to- Confirm that Rating Quality Assurance Providers are informed of all changes to the RESNET ANSI and non-ANSI standards.
Comment #368Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-19Paragraph / Figure / Table / Note: 905.2.4.3Comment Intent: Not an ObjectionComment Type: EditorialComment: There is no definition of this topic. Proposed Change: N/A Just an observation Response: Reject Reason: no proposed change
Comment #369Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 41Paragraph / Figure / Table / Note: 905.2.4.6Comment Intent: ObjectionComment Type: GeneralComment: I take issue with the highlighted text below: 905.2.4.6 Maintain Quality Assurance Records for all confirmed and sampled ratings submitted to the National RESNET Registry, including ratings for IECC Energy Rating Index compliance and tax credit verifications. Again, this has less to do with the goals of the text and more to do with the implementation. Unless the software tools require this information in some sort of input box, there’s no way to enforce this. There’s nothing but punitive action to inspire HERS Raters to inform their quality agent which files are for an ERI compliance, and no easy way currently to insert this information into the RESNET National Registry. I’d suggest getting all the software tools into compliance, and add a function that says “Will this be used to meet the ERI compliance path in the IECC Building Code?”, otherwise it’s useless to try and require us to drag this information out of our Raters. Until then, strike this language until we can actually add a functionality to the software tools that would allow us to have accurate information on which ratings are for the ERI compliance path. Proposed Change: 905.2.4.6 Maintain Quality Assurance Records for all confirmed and sampled ratings submitted to the National RESNET Registry, including ratings for IECC Energy Rating Index compliance and tax credit verifications. Response: Reject Reason: Strike entire section, renumber and replace with Maintain the Quality Assurance Data File for each confirmed or sampled rating that receives quality assurance review at a minimum containing the information required by Section 904.3. The Data Files shall be archived for a minimum of three (3) years.
905.2.4.6 Maintain Quality Assurance Records for all confirmed and sampled ratings submitted to the National RESNET Registry, including ratings for IECC Energy Rating Index compliance and tax credit verifications.
Again, this has less to do with the goals of the text and more to do with the implementation.
Unless the software tools require this information in some sort of input box, there’s no way to enforce this. There’s nothing but punitive action to inspire HERS Raters to inform their quality agent which files are for an ERI compliance, and no easy way currently to insert this information into the RESNET National Registry.
I’d suggest getting all the software tools into compliance, and add a function that says “Will this be used to meet the ERI compliance path in the IECC Building Code?”, otherwise it’s useless to try and require us to drag this information out of our Raters. Until then, strike this language until we can actually add a functionality to the software tools that would allow us to have accurate information on which ratings are for the ERI compliance path.
Reason: Strike entire section, renumber and replace with Maintain the Quality Assurance Data File for each confirmed or sampled rating that receives quality assurance review at a minimum containing the information required by Section 904.3. The Data Files shall be archived for a minimum of three (3) years.
Comment #370Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-19Paragraph / Figure / Table / Note: 905.2.4.6Comment Intent: Not an ObjectionComment Type: EditorialComment: The way this is written conflicts with earlier statements that Providers are not required to give full rating files to Quality Agents for all ratings. I believe the intent is maintenance of records for ratings on which Quality Assurance was performed. Also, EEPs were left out of the list. Proposed Change: 905.2.4.6 Maintain Quality Assurance Records for all quality assurance reviewed confirmed and sampled ratings submitted to the National RESNET Registry, including ratings for EEPs, IECC Energy Rating Index compliance and tax credit verifications. Response: Reject Reason: Language replaced per comment #367
The way this is written conflicts with earlier statements that Providers are not required to give full rating files to Quality Agents for all ratings. I believe the intent is maintenance of records for ratings on which Quality Assurance was performed. Also, EEPs were left out of the list.
905.2.4.6 Maintain Quality Assurance Records for all quality assurance reviewed confirmed and sampled ratings submitted to the National RESNET Registry, including ratings for EEPs, IECC Energy Rating Index compliance and tax credit verifications.
Comment #371Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-19Paragraph / Figure / Table / Note: 905.2.4.6Comment Intent: ObjectionComment Type: TechnicalComment: In Texas where the 2015 IECC has been adopted there are now multiple ERI calculators other than the HERS Index entering the market, one of which is sanctioned by the State and hence should see wide-spread adoption. As a result many Non-HERS Raters are adopting these ERI calculators and providing ERI testing and inspection services for Code compliance. These non-HERS Raters do not operate under the RESNET Quality Assurance umbrella. (While this may change with the adoption of ANSI/RESNET 301 into the 2018 IECC, due to State law the 2018 IECC can't be considered for adoption until 2022 making that change a non-factor in Texas). By requiring that HERS Raters submit all IECC Energy Rating Index Compliance through the RESNET Quality Assurance process, RESNET is putting all HERS Raters at a competive disadvantage in the State of Texas. I proposed that IECC Energ Rating Index Compliance should be struck from the RESNET Quality Assurance Standards until the 2018 IECC starts to be adopted on a national basis. Under the 2018 IECC HERS Raters and non-HERS Raters will be playing under similar rules. Under the 2015 IECC this is unfortunately not the case. Proposed Change: 905.2.4.6 Maintain Quality Assurance Records for all confirmed and sampled ratings submitted to the National RESNET Registry, including ratings for IECC Energy Rating Index compliance and tax credit verifications: Response: Reject Reason: Language replaced per comment #367
905.2.4.6 Maintain Quality Assurance Records for all confirmed and sampled ratings submitted to the National RESNET Registry, including ratings for IECC Energy Rating Index compliance and tax credit verifications:
Comment #372Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-19Paragraph / Figure / Table / Note: 905.2.4.6.1Comment Intent: ObjectionComment Type: EditorialComment: This section refers to currently non-existent capabilities of the National RESNET Registry, and is unenforceable. Once this capability is developed within the Registry, SDC 900 should submit a proposed Standard Amendment to make this element a requirement. Until then, asking Quality Agents to do the impossible seems a bit reckless. Proposed Change: Strike in its entirety: 905.2.4.6.1 Document each QA File and/or Field review by updating the National RESNET Registry for each rating which receives QA quality assurance. Response: Accept Reason: Renumber section after deletion
This section refers to currently non-existent capabilities of the National RESNET Registry, and is unenforceable.
Once this capability is developed within the Registry, SDC 900 should submit a proposed Standard Amendment to make this element a requirement. Until then, asking Quality Agents to do the impossible seems a bit reckless.
Strike in its entirety:
905.2.4.6.1 Document each QA File and/or Field review by updating the National RESNET Registry for each rating which receives QA quality assurance.
Reason: Renumber section after deletion
Comment #373Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-19Paragraph / Figure / Table / Note: 905.2.4.6.1Comment Intent: ObjectionComment Type: TechnicalComment: There is not a field available in the registry for this information. It would be great if we could use the registry as an alternative to our annual reports and have it summarize data for us, however, there is no place other than the notes field at this point in time. The notes field is not an acceptable place to put this information as any quality assurance discussions should be kept between Raters, Rating Providers, Quality Agents and RESNET and should not be part of the publicly available rating file for the property. The fields, contents, entry, reporting, use, etc. of this type of information needs to be a separate project that includes input from Quality Agents and Raters. Once the registry has fields available, then this could be added back to the standards. Proposed Change: 905.2.4.6.1 Document each QA File and/or Field review by updating the National RESNET Registry for each rating which receives quality assurance Response: Accept Reason: Renumber section after deletion
There is not a field available in the registry for this information. It would be great if we could use the registry as an alternative to our annual reports and have it summarize data for us, however, there is no place other than the notes field at this point in time. The notes field is not an acceptable place to put this information as any quality assurance discussions should be kept between Raters, Rating Providers, Quality Agents and RESNET and should not be part of the publicly available rating file for the property. The fields, contents, entry, reporting, use, etc. of this type of information needs to be a separate project that includes input from Quality Agents and Raters. Once the registry has fields available, then this could be added back to the standards.
905.2.4.6.1 Document each QA File and/or Field review by updating the National RESNET Registry for each rating which receives quality assurance
Comment #374Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-20Paragraph / Figure / Table / Note: 905.2.5Comment Intent: ObjectionComment Type: EditorialComment: The language on the Whistle Blower policy needs to be changed such that a Direct Rating Provider can terminate a relationship with a QA Agent without the possibility of this clause being invoked. Whistle Blower policies are meant to protect employees from being fired for doing their jobs. A Direct Rating provider will be in a contractor/sub-contractor relationship with their QA Agent, and should be free to terminate that relationship should it be deemed necessary. Such a termination would not erase any QA results that were previously communicated to RESNET by the QA Agent. To leave the language of this clause as it currently stands would take RESNET oversight too far into the internal business of the Providers. Proposed Change: 905.2.5 QA Designee and Certified Home Energy RaterRESNET Whistle Blower Protection Policy. The protections set forth in this clause shall only apply to employees of Providers, and not to any individual who is in a sub-contractor relationship with a Provider. Response: Reject Reason: This can be covered in the contract with the QA Agent and the provider
The language on the Whistle Blower policy needs to be changed such that a Direct Rating Provider can terminate a relationship with a QA Agent without the possibility of this clause being invoked. Whistle Blower policies are meant to protect employees from being fired for doing their jobs. A Direct Rating provider will be in a contractor/sub-contractor relationship with their QA Agent, and should be free to terminate that relationship should it be deemed necessary. Such a termination would not erase any QA results that were previously communicated to RESNET by the QA Agent. To leave the language of this clause as it currently stands would take RESNET oversight too far into the internal business of the Providers.
905.2.5 QA Designee and Certified Home Energy RaterRESNET Whistle Blower Protection Policy. The protections set forth in this clause shall only apply to employees of Providers, and not to any individual who is in a sub-contractor relationship with a Provider.
Reason: This can be covered in the contract with the QA Agent and the provider
Comment #375Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-20Paragraph / Figure / Table / Note: 905.2.5-905.2.5.2Comment Intent: Not an ObjectionComment Type: GeneralComment: Here's a bit of unintended consequence: if a Rater participates in good faith in any investigation of their activities AND the Provider takes disciplinary action against that Rater, the Provider is in direct violation of RESNET's Whistle Blower Protection Policy as outlined here AND that Provider is subject to disciplinary action by RESNET for violating that policy. I happen to be OK with that- as I've stated in earlier comments, that's exactly the kind of culture we need to develop within RESNET to achieve better compliance. Proposed Change: No proposed change. Response: Reject Reason: No proposed change
Here's a bit of unintended consequence: if a Rater participates in good faith in any investigation of their activities AND the Provider takes disciplinary action against that Rater, the Provider is in direct violation of RESNET's Whistle Blower Protection Policy as outlined here AND that Provider is subject to disciplinary action by RESNET for violating that policy.
I happen to be OK with that- as I've stated in earlier comments, that's exactly the kind of culture we need to develop within RESNET to achieve better compliance.
No proposed change.
Reason: No proposed change
Comment #376Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 40Paragraph / Figure / Table / Note: 905.7Comment Intent: ObjectionComment Type: GeneralComment: • 905.7 please unstrike this entire section. Only QAAs are permitted to perform QA with no assistance? QADDs are currently a vital part of the industry and should remain. QAAs cannot do it all alone, which is why we currently have and need QADDs. This section should be added back, with provisions added to address any potential conflict of interest, as well as QAA oversight of QAAD’s work. Proposed Change: 905.7 Quality Assurance Designee Delegate (QA Delegate) QA Designee’s may have the file review and on-site inspection responsibilities performed by a Quality Assurance Designee Delegate. The QA Designee, however, remains responsible for the accuracy and compliance of the Provider’s quality assurance program, including reviews and inspections completed by a QA Delegate. 905.7.1 A QA Delegate must be a certified Home Energy Rater and have completed, on a minimum of twenty-five (25) homes, the portion of the inspection or rating process for which the individual is performing quality assurance tasks. In other words, if the QA Delegate is repeating on-site testing and inspections as part of the QA process, that individual must have at least performed these tasks on a minimum of twenty five (25) homes. 905.7.2 The QA Designee is responsible for ensuring that the QA Delegate meets and maintains their qualifications to be a QA Delegate, contained in 905.7.1. 905.2.4905.8 Responsibilities of a Quality Agents Designee. Responsibilities of the QA Designee shall include: Response: Reject Reason: For consistency, all individuals doing quality assurance reviews must be trained, certified and report to RESNET
• 905.7 please unstrike this entire section. Only QAAs are permitted to perform QA with no assistance? QADDs are currently a vital part of the industry and should remain. QAAs cannot do it all alone, which is why we currently have and need QADDs. This section should be added back, with provisions added to address any potential conflict of interest, as well as QAA oversight of QAAD’s work.
905.7 Quality Assurance Designee Delegate (QA Delegate) QA Designee’s may have the file review and on-site inspection responsibilities performed by a Quality Assurance Designee Delegate. The QA Designee, however, remains responsible for the accuracy and compliance of the Provider’s quality assurance program, including reviews and inspections completed by a QA Delegate. 905.7.1 A QA Delegate must be a certified Home Energy Rater and have completed, on a minimum of twenty-five (25) homes, the portion of the inspection or rating process for which the individual is performing quality assurance tasks. In other words, if the QA Delegate is repeating on-site testing and inspections as part of the QA process, that individual must have at least performed these tasks on a minimum of twenty five (25) homes. 905.7.2 The QA Designee is responsible for ensuring that the QA Delegate meets and maintains their qualifications to be a QA Delegate, contained in 905.7.1. 905.2.4905.8 Responsibilities of a Quality Agents Designee. Responsibilities of the QA Designee shall include:
Reason: For consistency, all individuals doing quality assurance reviews must be trained, certified and report to RESNET
Comment #377Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-21Paragraph / Figure / Table / Note: 906.2Comment Intent: Not an ObjectionComment Type: TechnicalComment: If RESNET has formal agreements with EEPs, then their QA requirements become the responsibility of Quality Agents. This obligation should be stated explicitly in these Standards. Proposed Change: 906.2 Quality Assurance, as specified in Section 904, may be provided by QA Designees for EEP’s by Quality Agents as part of the RESNET Quality Assurance process when RESNET and the EEP enter into a formal agreement. Where EEP Quality Assurance requirements are greater than specified in Section 904, those Quality Assurance requirements shall be specified in writing by an EEP and provided to RESNET for approval in order to be included in the RESNET QAQuality Assurance process. It is the responsibility of Quality Agents to be aware of and enforce these requirements. Response: Reject Reason: The addition of the sentence is redundant
If RESNET has formal agreements with EEPs, then their QA requirements become the responsibility of Quality Agents. This obligation should be stated explicitly in these Standards.
906.2 Quality Assurance, as specified in Section 904, may be provided by QA Designees for EEP’s by Quality Agents as part of the RESNET Quality Assurance process when RESNET and the EEP enter into a formal agreement. Where EEP Quality Assurance requirements are greater than specified in Section 904, those Quality Assurance requirements shall be specified in writing by an EEP and provided to RESNET for approval in order to be included in the RESNET QAQuality Assurance process. It is the responsibility of Quality Agents to be aware of and enforce these requirements.
Reason: The addition of the sentence is redundant
Comment #378Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-22-29Paragraph / Figure / Table / Note: 907Comment Intent: ObjectionComment Type: EditorialComment: Throughout this section, the term "Auditor" is used. RESNET has no such designation or certification, so this term must be removed from the Standard. It is impossible to perform quality management on an individual who doesn't have a RESNET certification- it is outside the scope and authority of RESNET. Proposed Change: Remove all references to "Auditor" in this Standard. Response: Accept Reason: Auditor should be removed
Throughout this section, the term "Auditor" is used. RESNET has no such designation or certification, so this term must be removed from the Standard. It is impossible to perform quality management on an individual who doesn't have a RESNET certification- it is outside the scope and authority of RESNET.
Remove all references to "Auditor" in this Standard.
Reason: Auditor should be removed
Comment #379Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-23Paragraph / Figure / Table / Note: 907.1.6.1, 2, 3Comment Intent: Not an ObjectionComment Type: EditorialComment: Move these items to section 907.3. Proposed Change: 907.1.6.1 Resolve the complaint in forty-five (45) calendar days. 907.1.6.2 A complaint will be considered resolved once a Complaint Resolution Form has been submitted, signed by the party who filed the complaint and the CEQ Provider. 907.1.6.3 A log of unresolved complaints shall be maintained by the RESNET Executive Director. Response: Reject Reason: Current placement of section is reasonable and does not need to moved
Move these items to section 907.3.
907.1.6.1 Resolve the complaint in forty-five (45) calendar days. 907.1.6.2 A complaint will be considered resolved once a Complaint Resolution Form has been submitted, signed by the party who filed the complaint and the CEQ Provider. 907.1.6.3 A log of unresolved complaints shall be maintained by the RESNET Executive Director.
Reason: Current placement of section is reasonable and does not need to moved
Comment #380Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-24Paragraph / Figure / Table / Note: 907.3.4.3.1Comment Intent: ObjectionComment Type: GeneralComment: The addition inside of the parenthetical is to add clarity to the type of $500 that is being addressed. It just needs to be more clear. $500 materials? $500 labor? $500 damage unrelated to the original project? Durability is critical to energy efficient homes. If a contractor installs a bath fan and doesn't install the flashing properly, then it leaks and causes roof damage, the contractor should be held accountable for their faulty installation. Proposed Change: 907.3.4.3.1 Be related to either structural or major deficiencies (resulting in over $500 of repairs for the homeowner) and must impact the energy efficiency and/or the durability of the home. Response: Accept Reason: accept in principle “add damages” 907.3.4.3.1 Be related to either structural or major deficiencies (resulting in over $500 of repairs or damages for the homeowner) and must impact the energy efficiency and/or the durability of the home.
The addition inside of the parenthetical is to add clarity to the type of $500 that is being addressed. It just needs to be more clear. $500 materials? $500 labor? $500 damage unrelated to the original project?
Durability is critical to energy efficient homes. If a contractor installs a bath fan and doesn't install the flashing properly, then it leaks and causes roof damage, the contractor should be held accountable for their faulty installation.
907.3.4.3.1 Be related to either structural or major deficiencies (resulting in over $500 of repairs for the homeowner) and must impact the energy efficiency and/or the durability of the home.
Reason: accept in principle “add damages”
907.3.4.3.1 Be related to either structural or major deficiencies (resulting in over $500 of repairs or damages for the homeowner) and must impact the energy efficiency and/or the durability of the home.
Comment #381Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-28Paragraph / Figure / Table / Note: 907.4.3.4.2Comment Intent: Not an ObjectionComment Type: EditorialComment: Missed an "s". Proposed Change: down 2 points and up 3 points, for Response: Reject Reason: this section will be replaced with the new QA review checklist under development
Missed an "s".
Comment #382Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-29Paragraph / Figure / Table / Note: 908Comment Intent: ObjectionComment Type: GeneralComment: I have an issue with the highlighted text: 908 ETHICS AND APPEALS COMMITTEE The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider’s accreditation has been suspended or revoked. The Committee shall report to the RESNET Executive Director. Frankly speaking, no. This is such a simple, yet twisted change that would not accurately meet the processes that eliminates chokepoints and bias in decision-making. The Executive Director is supposed to answer to the Board of Directors, which the committee is made up of, not the other way around. Additionally, by having the Executive Director be in charge of reports made by the Ethics & Appeals Committee it gives the appearance that whoever is in the Executive Director position can veto, hide, or ignore any ethics complaints. The Ethics & Appeals Committee should continue to report to the Board of Directors. Proposed Change: 908 ETHICS AND APPEALS COMMITTEE The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider’s accreditation has been suspended or revoked. The Committee shall report to the RESNET Board of Directors Executive Director. Response: Reject Reason: consistent with section 912 and the executive director acts a means communication between the committee and appealing party
908 ETHICS AND APPEALS COMMITTEE
The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider’s accreditation has been suspended or revoked. The Committee shall report to the RESNET Executive Director.
Frankly speaking, no. This is such a simple, yet twisted change that would not accurately meet the processes that eliminates chokepoints and bias in decision-making.
The Executive Director is supposed to answer to the Board of Directors, which the committee is made up of, not the other way around. Additionally, by having the Executive Director be in charge of reports made by the Ethics & Appeals Committee it gives the appearance that whoever is in the Executive Director position can veto, hide, or ignore any ethics complaints.
The Ethics & Appeals Committee should continue to report to the Board of Directors.
The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider’s accreditation has been suspended or revoked. The Committee shall report to the RESNET Board of Directors Executive Director.
Reason: consistent with section 912 and the executive director acts a means communication between the committee and appealing party
Comment #383Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-22-29Paragraph / Figure / Table / Note: 908Comment Intent: ObjectionComment Type: TechnicalComment: The Ethics and Appeals Committee is a standing committee of the Board of Directors, and as such does not report to the Executive Director but to the Board of Directors. There is no provision in the RESNET by-laws for the Executive Director to usurp the role of the Board of Directors in providing governance and fiduciary oversight to the organization. Proposed Change: Strike the following in its entirety: 908 QUALITY ASSURANCE COMMITTEE AND ETHICS AND APPEALS COMMITTEE 908.1 908.1.1 Quality Assurance Committee Committee Membership. The Quality Assurance Committee (QA Committee) shall be chaired by a member of the RESNET Board of Directors. The Chair shall be approved by the RESNET Board. Nominations of Committee members shall be made by the Chair. 908.1.2 Committee Responsibilities. The QA Committee shall have: 908.1.2.1 Oversight of RESNET’s rating quality assurance program as defined in this chapter. The Committee shall report to the RESNET Board of Directors. 908.2 Ethics and Appeals Committee The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider’s accreditation has been suspended or revoked. The Committee shall report to the RESNET Board of Directors Executive Director. Replace with: 908 ETHICS AND APPEALS COMMITTEE The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider's accreditation has been suspended or revoked. The Committee shall report to the RESNET Board of Directors. Response: Reject Reason: the ethics committee makes a ruling and the executive director communicates the decision to the party but doesn’t not make final decision. Addendum 18 creates a new appeals panel effective October 15, 2016 so if the appellant wants to appeal the decision they may.
The Ethics and Appeals Committee is a standing committee of the Board of Directors, and as such does not report to the Executive Director but to the Board of Directors. There is no provision in the RESNET by-laws for the Executive Director to usurp the role of the Board of Directors in providing governance and fiduciary oversight to the organization.
908 QUALITY ASSURANCE COMMITTEE AND ETHICS AND APPEALS COMMITTEE 908.1 908.1.1 Quality Assurance Committee Committee Membership. The Quality Assurance Committee (QA Committee) shall be chaired by a member of the RESNET Board of Directors. The Chair shall be approved by the RESNET Board. Nominations of Committee members shall be made by the Chair. 908.1.2 Committee Responsibilities. The QA Committee shall have: 908.1.2.1 Oversight of RESNET’s rating quality assurance program as defined in this chapter. The Committee shall report to the RESNET Board of Directors. 908.2 Ethics and Appeals Committee The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider’s accreditation has been suspended or revoked. The Committee shall report to the RESNET Board of Directors Executive Director.
The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider's accreditation has been suspended or revoked. The Committee shall report to the RESNET Board of Directors.
Reason: the ethics committee makes a ruling and the executive director communicates the decision to the party but doesn’t not make final decision. Addendum 18 creates a new appeals panel effective October 15, 2016 so if the appellant wants to appeal the decision they may.
Comment #384Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-29Paragraph / Figure / Table / Note: 908Comment Intent: ObjectionComment Type: EditorialComment: This change to having everything funnel to a single person does seems to undermine to goals of building consistency, transparency and confidence in the RESNET Ratings Industry. Proposed Change: 908 ETHICS AND APPEALS COMMITTEE The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider’s accreditation has been suspended or revoked. The Committee shall report to the RESNET Board of Directors Executive Director. Response: Reject Reason: the ethics committee makes a ruling and the executive director communicates the decision to the party but doesn’t not make final decision. Addendum 18 creates a new appeals panel effective October 15, 2016 so if the appellant wants to appeal the decision they may.
This change to having everything funnel to a single person does seems to undermine to goals of building consistency, transparency and confidence in the RESNET Ratings Industry.
Comment #385Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-29Paragraph / Figure / Table / Note: 908Comment Intent: ObjectionComment Type: GeneralComment: The ethics and appeals committee should not report to one individual. This committee is determining the on-going livlihood of other companies. There is no justification for changing the reporting relationship and introducing potential individual bias instead of maintaining transparency and oversight. The committee should continue to report ot the board of directors. Proposed Change: The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider’s accreditation has been suspended or revoked. The Committee shall report to the RESNET Board of Directors Executive Director. Response: Reject Reason: the ethics committee makes a ruling and the executive director communicates the decision to the party but doesn’t not make final decision. Addendum 18 creates a new appeals panel effective October 15, 2016 so if the appellant wants to appeal the decision they may.
The ethics and appeals committee should not report to one individual. This committee is determining the on-going livlihood of other companies. There is no justification for changing the reporting relationship and introducing potential individual bias instead of maintaining transparency and oversight. The committee should continue to report ot the board of directors.
Comment #386Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-29Paragraph / Figure / Table / Note: 908Comment Intent: ObjectionComment Type: GeneralComment: The Ethics and Appeals Committee shall be appointed by the RESNET Board of Directors and shall report back to the RESNET Board of Directors. RESNET Staff (including the Executive Director) has no place in evaluating ethics violations. Proposed Change: 908 ETHICS AND APPEALS COMMITTEE The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints. It shall also hear and hearing appeals of denied an Applications or Renewal Applications that has been denied, or if a Provider has been placed on probation, and suspension of or if a Provider’s accreditation has been suspended or revoked. The Committee shall report to the RESNET Board of Directors Executive Director. Response: Reject Reason: the ethics committee makes a ruling and the executive director communicates the decision to the party but doesn’t not make final decision. Addendum 18 creates a new appeals panel effective October 15, 2016 so if the appellant wants to appeal the decision they may.
The Ethics and Appeals Committee shall be appointed by the RESNET Board of Directors and shall report back to the RESNET Board of Directors.
RESNET Staff (including the Executive Director) has no place in evaluating ethics violations.
The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints. It shall also hear and hearing appeals of denied an Applications or Renewal Applications that has been denied, or if a Provider has been placed on probation, and suspension of or if a Provider’s accreditation has been suspended or revoked. The Committee shall report to the RESNET Board of Directors Executive Director.
Comment #387Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-29Paragraph / Figure / Table / Note: 908.1Comment Intent: ObjectionComment Type: TechnicalComment: I feel the RESNET Board of Directors should approve the Committee members. The wording allows the Chairman the power to approve any member he wants. Proposed Change: 908.2.1 Committee membership. The Ethics and Appeals Committee shall be chaired by a member of the RESNET Board of Directors. The Chair shall be approved by the RESNET Board. Nomination of Committee members shall be made by the Chairman.[D1] The Committee shall be composed of a minimum of five (5) members, but no more than seven (7) members including the chairman. The Committee shall consist of a minimum of two (2) Home EnergyHERS Raters and a minimum of two (2) representatives of Provider organizations. [D1]and approved by the RESNET Board of Directors Response: Reject Reason: Change “nomination” to “appointment” per RESNET Board Policy 003- All standing Committee chairs shall be appointed by and be current members of the RESNET Board of Directors, all Committee members shall be appointed by their respective Committee chair.
I feel the RESNET Board of Directors should approve the Committee members. The wording allows the Chairman the power to approve any member he wants.
908.2.1 Committee membership. The Ethics and Appeals Committee shall be chaired by a member of the RESNET Board of Directors. The Chair shall be approved by the RESNET Board. Nomination of Committee members shall be made by the Chairman.[D1]
The Committee shall be composed of a minimum of five (5) members, but no more than seven (7) members including the chairman. The Committee shall consist of a minimum of two (2) Home EnergyHERS Raters and a minimum of two (2) representatives of Provider organizations.
[D1]and approved by the RESNET Board of Directors
Reason: Change “nomination” to “appointment” per RESNET Board Policy 003- All standing Committee chairs shall be appointed by and be current members of the RESNET Board of Directors, all Committee members shall be appointed by their respective Committee chair.
Comment #388Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-29Paragraph / Figure / Table / Note: 909Comment Intent: ObjectionComment Type: TechnicalComment: It doesn't appear that the Ethics and Appeals Committee has any duties in the investigation process even though 908.2 states they they are responsible for investigating ethics and consumer compaints and hearing appeals. Proposed Change: I'm not sure what items to include since the Committee is not mentioned in any of the subtopics. Response: Reject Reason: details specific to the investigation do not belong in standards language since every investigation may be different
It doesn't appear that the Ethics and Appeals Committee has any duties in the investigation process even though 908.2 states they they are responsible for investigating ethics and consumer compaints and hearing appeals.
I'm not sure what items to include since the Committee is not mentioned in any of the subtopics.
Reason: details specific to the investigation do not belong in standards language since every investigation may be different
Comment #389Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-30Paragraph / Figure / Table / Note: 909.1.3 and subsectionsComment Intent: ObjectionComment Type: GeneralComment: The requirements set forth in this section present a huge obstacle to filing any ethics complaints. They stipulate that all pertinent information must be available and complete and that the person filing the complaint must cite the specific section of the Code of Ethics or the RESNET Standard. If, for example, an RFI feels that he is put up to some sort of misinterpretation of the facts, then this person, who is very familiiar with how the Standards work in practice but who is unfamiliar with the language of the 300+ page document, cannot file a complaint until he figures out exactly which provision is being violated by his HERS Rater or employer. Additionally, some ethics complaints may be suspicions but may not be able to be confirmed by the party that observed the potential problems. If I see another HERS Rater in my market do something unethical or hear a suspicious story about them or their employer, I may not have access to enough information that would allow me to report them under this procedure. Yes, I'm sure RESNET staff would have an easier time evaluating complaints if all of this information were in order but if the barrier to reporting ethics violations is too high, then few people will be motivated enough to report them. I believe all ethics complaints should be evaluated. Proposed Change: 909.1.3 Complaints shall document the alleged violation(s) or compliance issue(s). The complaint shall also be specific about which section(s) of the Code of Ethics or the RESNET Standards have been violated. To be considered, the full and complete complaint shall be submitted on the RESNET’s online ethics or compliance complaint form, which is posted on the RESNET web-site, and contain the following information: 909.1.3.1 The name of the complainant and contact information; 909.1.3.2 The name of the party that is the subject of the complaint; 909.1.3.3 A complete description of the alleged violation(s); 909.1.3.4 A recitation of all the facts documenting the complaint; 909.1.3.5 Copies of all relevant documents. Response: Reject Reason: specific language about what section of the RESNET standards or code of ethics has been violated is needed.
The requirements set forth in this section present a huge obstacle to filing any ethics complaints. They stipulate that all pertinent information must be available and complete and that the person filing the complaint must cite the specific section of the Code of Ethics or the RESNET Standard.
If, for example, an RFI feels that he is put up to some sort of misinterpretation of the facts, then this person, who is very familiiar with how the Standards work in practice but who is unfamiliar with the language of the 300+ page document, cannot file a complaint until he figures out exactly which provision is being violated by his HERS Rater or employer.
Additionally, some ethics complaints may be suspicions but may not be able to be confirmed by the party that observed the potential problems. If I see another HERS Rater in my market do something unethical or hear a suspicious story about them or their employer, I may not have access to enough information that would allow me to report them under this procedure.
Yes, I'm sure RESNET staff would have an easier time evaluating complaints if all of this information were in order but if the barrier to reporting ethics violations is too high, then few people will be motivated enough to report them.
I believe all ethics complaints should be evaluated.
909.1.3 Complaints shall document the alleged violation(s) or compliance issue(s). The complaint shall also be specific about which section(s) of the Code of Ethics or the RESNET Standards have been violated. To be considered, the full and complete complaint shall be submitted on the RESNET’s online ethics or compliance complaint form, which is posted on the RESNET web-site, and contain the following information:
909.1.3.1 The name of the complainant and contact information;
909.1.3.2 The name of the party that is the subject of the complaint;
909.1.3.3 A complete description of the alleged violation(s);
909.1.3.4 A recitation of all the facts documenting the complaint;
909.1.3.5 Copies of all relevant documents.
Reason: specific language about what section of the RESNET standards or code of ethics has been violated is needed.
Comment #390Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-30Paragraph / Figure / Table / Note: 909.2Comment Intent: ObjectionComment Type: TechnicalComment: I feel that the Committee should also play a role in reviewing the evidence rather than just leaving it in the hands of RESNET staff. Proposed Change: 909.2.1 Upon receipt of a complaint, the RESNET Executive Deputy Director shall assign a case number and RESNET staff shall review the evidence submitted. The Chair of the Ethics and Appeals Committee shall be informed. RESNET staff shall consider the documentation contained in 909.1.23 in making a decision whether to proceed or dismiss the complaint.[D1] [D1]The Committee should also review the evidence submitted Response: Reject Reason: RESNET staff providing the review of the complaint submission and parties always have the right to appeal
I feel that the Committee should also play a role in reviewing the evidence rather than just leaving it in the hands of RESNET staff.
909.2.1 Upon receipt of a complaint, the RESNET Executive Deputy Director shall assign a case number and RESNET staff shall review the evidence submitted. The Chair of the Ethics and Appeals Committee shall be informed. RESNET staff shall consider the documentation contained in 909.1.23 in making a decision whether to proceed or dismiss the complaint.[D1]
[D1]The Committee should also review the evidence submitted
Reason: RESNET staff providing the review of the complaint submission and parties always have the right to appeal
Comment #391Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-30Paragraph / Figure / Table / Note: 909.2.4Comment Intent: ObjectionComment Type: GeneralComment: The Ethics and Appeals Committee has been removed from all investigation of complaints and RESNET has been given the sole ability to determine and take action. The Ethics and Appeals Committee should be the body to handle ethics complaints and appeals to ensure fair and representative consideration. Proposed Change: 909.2.4 Upon receipt of the response, RESNET shall immediately forward the response to the RESNET Ethics and Appeals Committee for consideration and action. Wwithin thirty (30) business days of receiving the complaint, the Ethics and Appeals Committee shall take action on the complaint. 909.2.5 All parties to the complaint shall be informed by electronic mail of the Ethics and Appeals Committee’s RESNET’s action. Response: Reject Reason: This reflects current complaint process Reword section to include the three-tiered process of RESNET, Ethics and Appeals Committee and Appeals Panel
The Ethics and Appeals Committee has been removed from all investigation of complaints and RESNET has been given the sole ability to determine and take action. The Ethics and Appeals Committee should be the body to handle ethics complaints and appeals to ensure fair and representative consideration.
909.2.4 Upon receipt of the response, RESNET shall immediately forward the response to the RESNET Ethics and Appeals Committee for consideration and action. Wwithin thirty (30) business days of receiving the complaint, the Ethics and Appeals Committee shall take action on the complaint.
909.2.5 All parties to the complaint shall be informed by electronic mail of the Ethics and Appeals Committee’s RESNET’s action.
Reason: This reflects current complaint process Reword section to include the three-tiered process of RESNET, Ethics and Appeals Committee and Appeals Panel
Comment #392Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-34Paragraph / Figure / Table / Note: 910Comment Intent: ObjectionComment Type: EditorialComment: "Accreditation" is spelled in this document as "Accrediation". Proposed Change: Strike and replace the following as written: 910 PROBATION, SUSPENSION, AND REVOCATION OF ACCREDIATION ACCREDITATION Response: Accept
"Accreditation" is spelled in this document as "Accrediation".
Strike and replace the following as written:
910 PROBATION, SUSPENSION, AND REVOCATION OF ACCREDIATION ACCREDITATION
Comment #393Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-36, 9-37Paragraph / Figure / Table / Note: 910.2.1.2.9, 910.3.5.3Comment Intent: ObjectionComment Type: GeneralComment: These sections address the fining of a Rating Quality Assurance Provider as part of disciplinary action by RESNET. This action in itself is not objectionable. However, the amount of the fine is undetermined and set by the Board of Directors. These provisions appear arbitrary and non-transparent. Although no proposed changes are made, modifications to these sections are requested in order to be less arbitrary and more transparent. Response: Reject Reason: specific amount of the fine decided by the board of directors should not be in standards
These sections address the fining of a Rating Quality Assurance Provider as part of disciplinary action by RESNET. This action in itself is not objectionable. However, the amount of the fine is undetermined and set by the Board of Directors.
These provisions appear arbitrary and non-transparent. Although no proposed changes are made, modifications to these sections are requested in order to be less arbitrary and more transparent.
Reason: specific amount of the fine decided by the board of directors should not be in standards
Comment #394Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-37Paragraph / Figure / Table / Note: 910.3.5.3Comment Intent: ObjectionComment Type: GeneralComment: Current text reads: Rating Quality Assurance Providers suspended by RESNET who wish to be re-instated must pay a fine set by the RESNET Board of Directors. Suggestd text: Rating Quality Assurance Providers suspended by RESNET who wish to be re-instated must pay a fine set by the RESNET Board of Directors. The schedule of possible fines related to transgressions is set in Table 910.3.5.3 and cannot exceed $xxxx for multiple past occurences I think the fines should be pre-determined for offense types and frequency of occurrence. I think the arbitrary leveling of fines against providers by the Board is too much power for a member based organization. Response: Reject Reason: specific amount of the fine decided by the board of directors should not be in standards
Current text reads: Rating Quality Assurance Providers suspended by RESNET who wish to be re-instated must pay a fine set by the RESNET Board of Directors.
Suggestd text: Rating Quality Assurance Providers suspended by RESNET who wish to be re-instated must pay a fine set by the RESNET Board of Directors. The schedule of possible fines related to transgressions is set in Table 910.3.5.3 and cannot exceed $xxxx for multiple past occurences
I think the fines should be pre-determined for offense types and frequency of occurrence. I think the arbitrary leveling of fines against providers by the Board is too much power for a member based organization.
Comment #395Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 59Paragraph / Figure / Table / Note: 910.3.5.3Comment Intent: ObjectionComment Type: TechnicalComment: This needs to be defined as to what the fine is intended to cover and what the limits are, or deleted from the amendment. Currently too broad and vague to consider including. Proposed Change: 9102.3.5.3 Rating Quality Assurance Providers Suspended by RESNET who wish to be reinstated must pay a fine set by the RESNET Board of Directors. Response: Reject Reason: specific amount of the fine decided by the board of directors should not be in standards
This needs to be defined as to what the fine is intended to cover and what the limits are, or deleted from the amendment. Currently too broad and vague to consider including.
9102.3.5.3 Rating Quality Assurance Providers Suspended by RESNET who wish to be reinstated must pay a fine set by the RESNET Board of Directors.
Comment #396Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 59Paragraph / Figure / Table / Note: 910.3.5.3Comment Intent: ObjectionComment Type: GeneralComment: This needs to be defined as to what the fine is intended to cover and what the limits are, or deleted from the amendment. Currently too broad and vague to consider including. Proposed Change: 9102.3.5.3 Rating Quality Assurance Providers Suspended by RESNET who wish to be reinstated must pay a fine set by the RESNET Board of Directors. Response: Reject Reason: specific amount of the fine decided by the board of directors should not be in standards
Comment #397Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-37Paragraph / Figure / Table / Note: 910.4.1.7Comment Intent: ObjectionComment Type: GeneralComment: This has nothing to do with enhancing quality oversight or rating consistency and can place RESNET in a position to be liable in lawsuits claiming discrimination. This may violate Title VII/EEOC. The use of blanket screening policies is against the law in many states. If a Providership is revoked, it should be clear in the standards that RESNET is the body making the determination that the revocation was required. This paragraph should either be completely removed or clarified as below. Proposed Change: 910.4.1.7 A Principle of the organization has been convicted of or has admitted to a felony or is listed on any state or federal sex offenders list, when deemed to impact performance or industry reputation. OR 910.4.1.7 A Principle of the organization has been convicted of or has admitted to a felony or is listed on any state or federal sex offenders list, when deemed by RESNET to impact performance or industry reputation. Response: Accept
This has nothing to do with enhancing quality oversight or rating consistency and can place RESNET in a position to be liable in lawsuits claiming discrimination. This may violate Title VII/EEOC. The use of blanket screening policies is against the law in many states.
If a Providership is revoked, it should be clear in the standards that RESNET is the body making the determination that the revocation was required.
This paragraph should either be completely removed or clarified as below.
910.4.1.7 A Principle of the organization has been convicted of or has admitted to a felony or is listed on any state or federal sex offenders list, when deemed to impact performance or industry reputation.
910.4.1.7 A Principle of the organization has been convicted of or has admitted to a felony or is listed on any state or federal sex offenders list, when deemed by RESNET to impact performance or industry reputation.
Comment #398Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-38Paragraph / Figure / Table / Note: 910.4.3Comment Intent: ObjectionComment Type: GeneralComment: Revocation of Provider status should never be removed. Revocation should be permanent. Please review the circumstances under which Providers may have their accreditation revoked: multiple disciplinary probation violations within a single year, terms of a suspension not remedied, fraud, etc. Any organization that finds themselves in one of those situations had every opportunity to correct any mistakes. In addition, the list of Providers whose accreditation has been revoked should be posted publicly so that HERS Raters will know that requests to associate with them or any new Ratings identified in the field are fraudulent. Proposed Change: 910.4.3 RESNET shall publicly post a list of Providers whose accreditation has been revoked on its professional website. The Providers revocation listing shall be removed when the Provider successfully complies with the terms of the revocation. Response: Reject Reason: if the provider meets the requirements for the terms of revocation they should be removed from the list
Revocation of Provider status should never be removed. Revocation should be permanent.
Please review the circumstances under which Providers may have their accreditation revoked: multiple disciplinary probation violations within a single year, terms of a suspension not remedied, fraud, etc. Any organization that finds themselves in one of those situations had every opportunity to correct any mistakes.
In addition, the list of Providers whose accreditation has been revoked should be posted publicly so that HERS Raters will know that requests to associate with them or any new Ratings identified in the field are fraudulent.
910.4.3 RESNET shall publicly post a list of Providers whose accreditation has been revoked on its professional website. The Providers revocation listing shall be removed when the Provider successfully complies with the terms of the revocation.
Reason: if the provider meets the requirements for the terms of revocation they should be removed from the list
Comment #399Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 58Paragraph / Figure / Table / Note: 9102.2.1.2.9Comment Intent: ObjectionComment Type: TechnicalComment: • 911.3.1.2.9 – Inclusion of fines should not be in the standard baseline language. This statement is too vague to be considered for inclusion and should be more specific and well defined for its inclusion. In addition, it needs to be defined exactly what the fine is intended for. Is this to cover additional administrative fees? Will the fines be different if field QA by RESNET Staff is required? Proposed Change: 9102.2.1.2.9 Rating Quality Assurance Providers placed on Disciplinary Compliance Probation by RESNET will be subject to a fine set by the RESNET Board of Directors. Response: Reject Reason: specific amount and reasons for the fine decided by the board of directors should not be in standards
• 911.3.1.2.9 – Inclusion of fines should not be in the standard baseline language. This statement is too vague to be considered for inclusion and should be more specific and well defined for its inclusion. In addition, it needs to be defined exactly what the fine is intended for. Is this to cover additional administrative fees? Will the fines be different if field QA by RESNET Staff is required?
9102.2.1.2.9 Rating Quality Assurance Providers placed on Disciplinary Compliance Probation by RESNET will be subject to a fine set by the RESNET Board of Directors.
Reason: specific amount and reasons for the fine decided by the board of directors should not be in standards
Comment #400Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-38Paragraph / Figure / Table / Note: 9102.4.3Comment Intent: ObjectionComment Type: GeneralComment: RESNET should be held to the same time constraints as a Rater/Provider. 30 business days to report. I suggest the review/standards committee scan entire document for consistency and timeliness in reporting and utilize the 30 business days for responses/comments/notices, etc... Proposed Change: 9102.4.3 RESNET shall post Providers whose accreditation has been revoked within 30 business days after a decision by the committee . The Providers revocation listing shall be removed when the Provider successfully complies with the terms of the revocation. 9102.4.4 RESNET shall electronically inform accredited QARating Quality Assurance Providers, Quality Assurance Contractors , HERS Rating Software Providers, Rater Trainers Instructors/Assessors and Home Energy HER Raters of a QA Provider’s accreditation revocation within 30 business days after a decision by the committee. Response: Accept Reason: 30 days to post is a reasonable deadline
RESNET should be held to the same time constraints as a Rater/Provider. 30 business days to report. I suggest the review/standards committee scan entire document for consistency and timeliness in reporting and utilize the 30 business days for responses/comments/notices, etc...
9102.4.3 RESNET shall post Providers whose accreditation has been revoked within 30 business days after a decision by the committee . The Providers revocation listing shall be removed when the Provider successfully complies with the terms of the revocation. 9102.4.4 RESNET shall electronically inform accredited QARating Quality Assurance Providers, Quality Assurance Contractors , HERS Rating Software Providers, Rater Trainers Instructors/Assessors and Home Energy HER Raters of a QA Provider’s accreditation revocation within 30 business days after a decision by the committee.
Reason: 30 days to post is a reasonable deadline
Comment #401Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-38Paragraph / Figure / Table / Note: 911Comment Intent: ObjectionComment Type: GeneralComment: This section contradicts an earlier section. This type of inconsistency renders both sections unenforceable. Proposed Change: Strike following in its entirety: 911.1913.1 Appeals of Provider and RESNET actions shall be made first to the RESNET Executive Director, then to the RESNET Ethics and Appeals Committee, then to the RESNET Board of Directors. Replace with: 911.1 Appeals of Provider and RESNET actions shall be made first to the RESNET Ethics and Appeals Committee, then to the RESNET Board of Directors. Response: Accept Reason: Accept in principle- Addendum 18 effective in October 2016 adding the appeal panel supersedes changes to this section
This section contradicts an earlier section. This type of inconsistency renders both sections unenforceable.
Strike following in its entirety:
911.1913.1 Appeals of Provider and RESNET actions shall be made first to the RESNET Executive Director, then to the RESNET Ethics and Appeals Committee, then to the RESNET Board of Directors.
911.1 Appeals of Provider and RESNET actions shall be made first to the RESNET Ethics and Appeals Committee, then to the RESNET Board of Directors.
Reason: Accept in principle- Addendum 18 effective in October 2016 adding the appeal panel supersedes changes to this section
Comment #402Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-38 and 9-38Paragraph / Figure / Table / Note: 911Comment Intent: ObjectionComment Type: GeneralComment: A committee should oversee all appeals of Provider and RESNET actions. The committee should be appointed by the Board, and the Board should oversee the committee. It is a conflict of interest for the Executive Director to oversee appeals to decisions made by the small staff within his organization. Why would he ever allow them to be appealed and move on to the Board-appointed committee? Even if he argues he would, it is best practice to have these types of decisions made by groups of people -- and our industry is all about implementing best practices! Additionally, "appealable action" must be defined, perhaps to include only procedural errors, substantive errors, or new information. This section is very basic and barely provides enough detail to ensure consistent, fair implementation. Response: Accept Reason: Accept in principle- Addendum 18 effective in October 2016 adding the appeal panel supersedes changes to this section
A committee should oversee all appeals of Provider and RESNET actions. The committee should be appointed by the Board, and the Board should oversee the committee.
It is a conflict of interest for the Executive Director to oversee appeals to decisions made by the small staff within his organization. Why would he ever allow them to be appealed and move on to the Board-appointed committee? Even if he argues he would, it is best practice to have these types of decisions made by groups of people -- and our industry is all about implementing best practices!
Additionally, "appealable action" must be defined, perhaps to include only procedural errors, substantive errors, or new information.
This section is very basic and barely provides enough detail to ensure consistent, fair implementation.
Comment #403Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-38Paragraph / Figure / Table / Note: 911.1Comment Intent: ObjectionComment Type: GeneralComment: I have a huge problem with the highlighted text: 911.1 Appeals of Provider and RESNET actions shall be made first to the RESNET Executive Director, then to the RESNET Ethics and Appeals Committee, then to the RESNET Board of Directors. Why is the Executive Director being involved in a decision that really needs multiple voices and opinions? Why is the Executive Director a chokepoint for all appeals to Provider and RESNET actions? I can't overstate how important it is that the ethics appeals go through the current process, without involvement from the Executive Director. I move to strike the language that involves the Executive Director and leave the current process to eliminate the potential and appearance of bias within the appeals process. Proposed Change: 911.1 Appeals of Provider and RESNET actions shall be made first to the RESNET Executive Director, then to the RESNET Ethics and Appeals Committee, then to the RESNET Board of Directors. Response: Accept Reason: Accept in principle- Addendum 18 effective in October 2016 adding the appeal panel supersedes changes to this section
I have a huge problem with the highlighted text:
911.1 Appeals of Provider and RESNET actions shall be made first to the RESNET Executive Director, then to the RESNET Ethics and Appeals Committee, then to the RESNET Board of Directors.
Why is the Executive Director being involved in a decision that really needs multiple voices and opinions? Why is the Executive Director a chokepoint for all appeals to Provider and RESNET actions? I can't overstate how important it is that the ethics appeals go through the current process, without involvement from the Executive Director.
I move to strike the language that involves the Executive Director and leave the current process to eliminate the potential and appearance of bias within the appeals process.
Comment #404Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 60Paragraph / Figure / Table / Note: 911.1Comment Intent: ObjectionComment Type: GeneralComment: Why is the Executive Director being involved in a decision that really needs multiple voices and opinions? Why is the Executive Director a chokepoint for all appeals to Provider and RESNET actions? I can't overstate how important it is that the ethics appeals go through the current process, without involvement from the Executive Director. Proposed Change: 911.1 Appeals of Provider and RESNET actions shall be made first to the RESNET Executive Director, then to the RESNET Ethics and Appeals Committee, then to the RESNET Board of Directors. Response: Accept Reason: Accept in principle- Addendum 18 effective in October 2016 adding the appeal panel supersedes changes to this section
Comment #405Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 60Paragraph / Figure / Table / Note: 911.1Comment Intent: ObjectionComment Type: TechnicalComment: It is not the role of the Executive Director to handle appeals. This is the reason there is a committee and that is to handle appeals. Proposed Change: 911.1913.1 Appeals of Provider and RESNET actions shall be made first to the RESNET Executive Director, then to the RESNET Ethics and Appeals Committee, then to the RESNET Board of Directors. Response: Accept Reason: Accept in principle- Addendum 18 effective in October 2016 adding the appeal panel supersedes changes to this section
It is not the role of the Executive Director to handle appeals. This is the reason there is a committee and that is to handle appeals.
Comment #406Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 60Paragraph / Figure / Table / Note: 911.2Comment Intent: ObjectionComment Type: TechnicalComment: It is not the role of the Executive Director to handle appeals. This is the reason there is a committee. Proposed Change: 911.2913.2 Within five (5) business days after receipt of an appealable action by RESNET, the Appellant shall notify the RESNET Executive Director Ethics and Appeals Committee of their intent to appeal. The Working Draft WD-02 Chapter Nine RESNET Standards 9-39 Appellant shall then have tenfifteen (150) business days after the date of notice to submit appeal documentation to the RESNET Executive Director Ethics and Appeals Committee. Response: Reject Reason: logistics that staff can handle rather than a committee
It is not the role of the Executive Director to handle appeals. This is the reason there is a committee.
911.2913.2 Within five (5) business days after receipt of an appealable action by RESNET, the Appellant shall notify the RESNET Executive Director Ethics and Appeals Committee of their intent to appeal. The Working Draft WD-02 Chapter Nine RESNET Standards 9-39 Appellant shall then have tenfifteen (150) business days after the date of notice to submit appeal documentation to the RESNET Executive Director Ethics and Appeals Committee.
Reason: logistics that staff can handle rather than a committee
Comment #407Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 38Paragraph / Figure / Table / Note: 911.2.1.2.7Comment Intent: ObjectionComment Type: TechnicalComment: 911.2.1.2.7 Willful misconduct; This section is too vague, needs definition to have any meaning. Providers will not suspend a rater for this reason. Proposed Change: 9102.2.1.2.7 Willful misconduct; Response: Reject Reason: the standards cannot capture all reason for misconduct so this allows for flexibility. There are levels of due process in place to appeal
911.2.1.2.7 Willful misconduct;
This section is too vague, needs definition to have any meaning. Providers will not suspend a rater for this reason.
9102.2.1.2.7 Willful misconduct;
Reason: the standards cannot capture all reason for misconduct so this allows for flexibility. There are levels of due process in place to appeal
Comment #408Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-39Paragraph / Figure / Table / Note: 911.4Comment Intent: ObjectionComment Type: GeneralComment: I have a huge problem with the appearance of bias in the highlighted section: 911.4 During the appeals process, all parties to the appeal may petition the body hearing the appeal (i.e. RESNET Executive Director, the RESNET Ethics and Appeals Committee, or RESNET Board of Directors) for a stay of action on suspension or revocation upon expiration of the appeals process. A decision on the petition shall be rendered by the hearing body not later than ten (10) business days after receipt of the petition. In the event that additional information is requested, an extension of ten (10) business days may be applied in order to allow the appellant sufficient time to respond. As I have stated several times already, by including the RESNET Executive Director in any ethics complaints and appeals, you give the appearance of bias, and don't keep the structure meant to eliminate bias supported. I move to strike the RESNET Executive Director as a part of the body hearing appeals. Proposed Change: 911.4 During the appeals process, all parties to the appeal may petition the body hearing the appeal (i.e. RESNET Executive Director, the RESNET Ethics and Appeals Committee, or RESNET Board of Directors) for a stay of action on suspension or revocation upon expiration of the appeals process. A decision on the petition shall be rendered by the hearing body not later than ten (10) business days after receipt of the petition. In the event that additional information is requested, an extension of ten (10) business days may be applied in order to allow the appellant sufficient time to respond. Response: Accept Reason: Accept in principle remove “(i.e. RESNET Executive Director, the RESNET Ethics and Appeals Committee, or RESNET Board of Directors)”
I have a huge problem with the appearance of bias in the highlighted section:
911.4 During the appeals process, all parties to the appeal may petition the body hearing the appeal (i.e. RESNET Executive Director, the RESNET Ethics and Appeals Committee, or RESNET Board of Directors) for a stay of action on suspension or revocation upon expiration of the appeals process. A decision on the petition shall be rendered by the hearing body not later than ten (10) business days after receipt of the petition. In the event that additional information is requested, an extension of ten (10) business days may be applied in order to allow the appellant sufficient time to respond.
As I have stated several times already, by including the RESNET Executive Director in any ethics complaints and appeals, you give the appearance of bias, and don't keep the structure meant to eliminate bias supported.
I move to strike the RESNET Executive Director as a part of the body hearing appeals.
Reason: Accept in principle remove “(i.e. RESNET Executive Director, the RESNET Ethics and Appeals Committee, or RESNET Board of Directors)”
Comment #409Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-39Paragraph / Figure / Table / Note: 911.4Comment Intent: ObjectionComment Type: GeneralComment: It is a violation of RESNET's due process for the Executive Director to be a hearing body on an appeal. This contradicts earlier standards, rendering both unenforceable. Proposed Change: Strike and replace the following as written: 911.4913.4 During the appeals process, all parties to the appeal may petition the body hearing the appeal (i.e. RESNET StaffExecutive Director, the RESNET Ethics and Appeals Committee, or RESNET Board of Directors) for a stay of action on suspension or revocation upon expiration of the appeals process. A decision on the petition shall be rendered by the hearing body not later than ten (10) business days after receipt of the petition. In the event that additional information is requested, an extension of ten (10) business days may be applied in order to allow the appellant sufficient time to respond. Response: Accept Reason: Accept in principle remove “(i.e. RESNET Executive Director, the RESNET Ethics and Appeals Committee, or RESNET Board of Directors)”
It is a violation of RESNET's due process for the Executive Director to be a hearing body on an appeal. This contradicts earlier standards, rendering both unenforceable.
911.4913.4 During the appeals process, all parties to the appeal may petition the body hearing the appeal (i.e. RESNET StaffExecutive Director, the RESNET Ethics and Appeals Committee, or RESNET Board of Directors) for a stay of action on suspension or revocation upon expiration of the appeals process. A decision on the petition shall be rendered by the hearing body not later than ten (10) business days after receipt of the petition. In the event that additional information is requested, an extension of ten (10) business days may be applied in order to allow the appellant sufficient time to respond.
Comment #410Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-39Paragraph / Figure / Table / Note: 911.5Comment Intent: ObjectionComment Type: GeneralComment: I have an issue with the highlighted text below: 911.5 Within twenty (20) business days of receiving the appeal, RESNET Executive Director, the Ethics and Appeals Committee, or RESNET Board of Directors shall render a decision on the appeal. In the event that additional information is requested, a one-time extension of ten (10) business days may be applied in order to allow the appellant sufficient time to respond. Just a recap of all the reasons why this is a bad decision: 1) The Executive Director answers to the Board of Directors, up to five of which make up the Ethics & Appeals Committee. The Executive Director should have no say in the matters that would appear before the Board of Directors and Ethics & Appeaks Committee in the process of an ethics complaint and/or appeal. 2) Allowing the Executive DIrector to be included in the Ethics & Appeals structure indicates that the process can be decided by an individual, rather than a majority vote from the complaintant's and/or appellant's representatives. No one person should have that power- it allows too much bias to play in a decision-making process which should be as free as possible from bias. 3) In many of the proposed standards where the Executive Director has been included, it leads to a chokepoint of the decision making process. If the Executive Director remains in the process, his/her workload may hold up the complaint and/or appeal process. To make it a fast-moving and fair as possible, the Executive Director should be included in this process. Proposed Change: 911.5 Within twenty (20) business days of receiving the appeal, RESNET Executive Director, the Ethics and Appeals Committee, or RESNET Board of Directors shall render a decision on the appeal. In the event that additional information is requested, a one-time extension of ten (10) business days may be applied in order to allow the appellant sufficient time to respond. Response: Accept Reason: Also change Board of Directors to RESNET Appeals Panel
911.5 Within twenty (20) business days of receiving the appeal, RESNET Executive Director, the Ethics and Appeals Committee, or RESNET Board of Directors shall render a decision on the appeal. In the event that additional information is requested, a one-time extension of ten (10) business days may be applied in order to allow the appellant sufficient time to respond.
Just a recap of all the reasons why this is a bad decision:
1) The Executive Director answers to the Board of Directors, up to five of which make up the Ethics & Appeals Committee. The Executive Director should have no say in the matters that would appear before the Board of Directors and Ethics & Appeaks Committee in the process of an ethics complaint and/or appeal.
2) Allowing the Executive DIrector to be included in the Ethics & Appeals structure indicates that the process can be decided by an individual, rather than a majority vote from the complaintant's and/or appellant's representatives. No one person should have that power- it allows too much bias to play in a decision-making process which should be as free as possible from bias.
3) In many of the proposed standards where the Executive Director has been included, it leads to a chokepoint of the decision making process. If the Executive Director remains in the process, his/her workload may hold up the complaint and/or appeal process. To make it a fast-moving and fair as possible, the Executive Director should be included in this process.
Reason: Also change Board of Directors to RESNET Appeals Panel
Comment #411Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-39Paragraph / Figure / Table / Note: 911.5Comment Intent: ObjectionComment Type: GeneralComment: It is a violation of RESNET's due process for the Executive Director to be a hearing body on an appeal. This contradicts earlier standards, rendering both unenforceable. Proposed Change: Strike and replace the following as written: 911.5 Within twenty (20) business days of receiving the appeal, or the date of a hearing, the Ethics and Appeals Committee, or RESNET Board of Directors shall render a decision on the appeal. In the event that additional information is requested, a one-time extension of ten (10) business days may be applied in order to allow the appellant sufficient time to respond. Response: Accept Reason: Accept in principle remove “(i.e. RESNET Executive Director, the RESNET Ethics and Appeals Committee, or RESNET Board of Directors)”
911.5 Within twenty (20) business days of receiving the appeal, or the date of a hearing, the Ethics and Appeals Committee, or RESNET Board of Directors shall render a decision on the appeal. In the event that additional information is requested, a one-time extension of ten (10) business days may be applied in order to allow the appellant sufficient time to respond.
Comment #412Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 61Paragraph / Figure / Table / Note: 911.5Comment Intent: ObjectionComment Type: TechnicalComment: RESNET Staff, including the Executive Director, has no place in evaluating appeals or ethics violations. This is a conflict of interest and completely unacceptable that one person has the ability to render a decision without due process. This undermines the entire process and purpose of having an ethics and appeals committe appointed by the BOD. RESNET Staff should play no role in this process whatsoever. Proposed Change: 911.5913.6 Within twenty ten (210) business days of receiving the appeal, or the date of a hearing, RESNET Executive Director, the Ethics and Appeals Committee, or RESNET Board of Directors shall render a decision on the appeal. In the event that additional information is requested, a one-time extension of ten (10) business days may be applied in order to allow the appellant sufficient time to respond. Response: Accept Reason: Accept in principle remove executive director and also change Board of Directors to RESNET Appeals Panel Do not accept changing back to 10 business days
RESNET Staff, including the Executive Director, has no place in evaluating appeals or ethics violations. This is a conflict of interest and completely unacceptable that one person has the ability to render a decision without due process. This undermines the entire process and purpose of having an ethics and appeals committe appointed by the BOD. RESNET Staff should play no role in this process whatsoever.
911.5913.6 Within twenty ten (210) business days of receiving the appeal, or the date of a hearing, RESNET Executive Director, the Ethics and Appeals Committee, or RESNET Board of Directors shall render a decision on the appeal. In the event that additional information is requested, a one-time extension of ten (10) business days may be applied in order to allow the appellant sufficient time to respond.
Reason: Accept in principle remove executive director and also change Board of Directors to RESNET Appeals Panel Do not accept changing back to 10 business days
Comment #413Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 61Paragraph / Figure / Table / Note: 911.7Comment Intent: ObjectionComment Type: TechnicalComment: RESNET Staff should play no role in the Ethics and Appeals process, including the handling of documentation. There is conflict of interest. This is why there is an ethics and appeals committee appointed by the BOD. Proposed Change: 911.7913.8 All appeals documentation received by RESNET shall be handled in strict confidence by RESNET staff, the Ethics and Appeals Committee, and the RESNET Board of Directors. Response: Reject Reason: RESNET Staff gathers documentation to send to committee and panel Note: change board of directors to appeals panels
RESNET Staff should play no role in the Ethics and Appeals process, including the handling of documentation. There is conflict of interest. This is why there is an ethics and appeals committee appointed by the BOD.
911.7913.8 All appeals documentation received by RESNET shall be handled in strict confidence by RESNET staff, the Ethics and Appeals Committee, and the RESNET Board of Directors.
Reason: RESNET Staff gathers documentation to send to committee and panel Note: change board of directors to appeals panels
Comment #414Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: AllParagraph / Figure / Table / Note: AllComment Intent: ObjectionComment Type: EditorialComment: It is very confusing to use the term "Quality Assurance" in so many places and so often. While it is clear that Rating Providers must take responsibility for the quality of the ratings generated through their providership, the standardized Quality Assurance is being performed by Quality Agents and Quality Assurance Contractors. I agree with others and propose that "Quality Assurance" be removed from the titles for Direct Rating Providers and Third Party Rating Providers. Then, be consistent wherever each type of provider is being discussed. Just use the entire title. This will help to clarify the entire document. The changes will need to be made throughout the document. Proposed Change: Direct Rating Quality Assurance Provider Direct Rating Provider Quality Assurance Provider Third-party Rating Quality Assurance Provider Third-party Rating Provider Response: Accept Reason: Accept in principle. Terms will be Direct Rating Provider and Third-party provider. Decided at the September 12th board meeting
It is very confusing to use the term "Quality Assurance" in so many places and so often. While it is clear that Rating Providers must take responsibility for the quality of the ratings generated through their providership, the standardized Quality Assurance is being performed by Quality Agents and Quality Assurance Contractors.
I agree with others and propose that "Quality Assurance" be removed from the titles for Direct Rating Providers and Third Party Rating Providers. Then, be consistent wherever each type of provider is being discussed. Just use the entire title. This will help to clarify the entire document.
The changes will need to be made throughout the document.
Direct Rating Quality Assurance Provider
Direct Rating Provider
Quality Assurance Provider
Third-party Rating Quality Assurance Provider
Third-party Rating Provider
Reason: Accept in principle. Terms will be Direct Rating Provider and Third-party provider. Decided at the September 12th board meeting
Comment #415Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 62Paragraph / Figure / Table / Note: Appendix B-201xComment Intent: Not an ObjectionComment Type: TechnicalComment: The definition of a Confirmed Rating in the ANSI/RESNET 301- 2014 standards does not include ERI Code Compliance or tax credit ratings. There is conflicting information within Chapter 9 related to which types of ratings are subject to quality assurance. This needs to be addressed by adding ERI Code Compliance and tax credit ratings to the definition in order to provide consistency related to which ratings are required to be registered and subject to quality assurance. Proposed Change: Confirmed Rating – A Rating accomplished using data gathered from verification of all rated features of the home in accordance with Section 303.8 and Chapter 8 of this Standard (e.g., onsite visual inspections, on-site diagnostic test results or default values for envelope air leakage rates and distribution system efficiencies) See ANSI/RESNET 301- 2014. Also, any rating performed for the purpose of the 45L tax credit or IECC ERI code compliance calculation. Response: Reject Reason: There is no need to add 45L tax credits or IECC code compliance to RESNET Standards because RESNET has no control over these entities
The definition of a Confirmed Rating in the ANSI/RESNET 301- 2014 standards does not include ERI Code Compliance or tax credit ratings. There is conflicting information within Chapter 9 related to which types of ratings are subject to quality assurance. This needs to be addressed by adding ERI Code Compliance and tax credit ratings to the definition in order to provide consistency related to which ratings are required to be registered and subject to quality assurance.
Confirmed Rating – A Rating accomplished using data gathered from verification of all rated features of the home in accordance with Section 303.8 and Chapter 8 of this Standard (e.g., onsite visual inspections, on-site diagnostic test results or default values for envelope air leakage rates and distribution system efficiencies) See ANSI/RESNET 301- 2014. Also, any rating performed for the purpose of the 45L tax credit or IECC ERI code compliance calculation.
Reason: There is no need to add 45L tax credits or IECC code compliance to RESNET Standards because RESNET has no control over these entities
Comment #416Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: B 1Paragraph / Figure / Table / Note: Appendix B-201x Glossary of TermsComment Intent: Not an ObjectionComment Type: EditorialComment: Section 104.3.1.5 requires that "Date of the Rating" be entered into National RESNET Registry for each rated home. Section 904.3.1.1 states that, for the purpose of Quality Assurance of ratings, the date submitted to the National RESNET Registry will be used to define the completion date of the rating. The proposed inclusion of "Date of the Rating" in the Glossary of Terms is intended to clarify that these two sections reference the same date. Proposed Change: Date of the Rating - For the purpose of determining RESNET QA requirements and reporting confirmed rating dates in the National RESNET Registry, the date that the rating is submitted to the National RESNET Registry will be used. Response: Reject Reason: the definition adds confusion to date rated and date submitted to the Registry
Section 104.3.1.5 requires that "Date of the Rating" be entered into National RESNET Registry for each rated home.
Section 904.3.1.1 states that, for the purpose of Quality Assurance of ratings, the date submitted to the National RESNET Registry will be used to define the completion date of the rating.
The proposed inclusion of "Date of the Rating" in the Glossary of Terms is intended to clarify that these two sections reference the same date.
Date of the Rating - For the purpose of determining RESNET QA requirements and reporting confirmed rating dates in the National RESNET Registry, the date that the rating is submitted to the National RESNET Registry will be used.
Reason: the definition adds confusion to date rated and date submitted to the Registry
Comment #417Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 1-11Paragraph / Figure / Table / Note: Conflict of Interest - Section 103.4.9.2.2Comment Intent: Not an ObjectionComment Type: EditorialComment: I am a professional engineer and HERS Rater. I commonly design the structural, civil and/or mechanical systems for a building which I am also the HERS Rater. I want to confirm that professional engineers are excluded from this provision since we prepare the plans and do not construct the building. Proposed Change: 103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings exclusive of design/engineering services for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply. Response: Reject Reason: standards cannot provide a specific list of who is excluded from this section
I am a professional engineer and HERS Rater. I commonly design the structural, civil and/or mechanical systems for a building which I am also the HERS Rater. I want to confirm that professional engineers are excluded from this provision since we prepare the plans and do not construct the building.
103.4.9.2.2 Home builders and their employees are not allowed to conduct ratings on the homes they build or for which they have a financial interest. Companies (including their employees) and individuals who own, provide funding for and/or are directly engaged in the construction of or general contracting of services for the construction of homes or buildings exclusive of design/engineering services for which HERS rating are provided, shall not conduct ratings on any homes or buildings for which any of the above designations apply.
Reason: standards cannot provide a specific list of who is excluded from this section
Comment #418Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 63Paragraph / Figure / Table / Note: DefinitionsComment Intent: ObjectionComment Type: GeneralComment: RESNETS creation of the Quality Assurance Contractor/Agent should in no way affect the ability of said contractor/agent from utilizing a QA Delegate. Similar to a Rater utilizing and RFI the QA contractor/Agent would have to take full ownership of the Quality assurance review. Having better definitions of how one can be a delegate and how they are used should remain in the standard. This is a cost effective solution volume and demand issue and in particular is needed to maintain a rating presence in rural areas. Proposed Change: Definitions Quality Assurance Designee Contractor Delegate (QA Delegate) – An individual certified as a Home Energy Rater , appointed by a Quality Assurance Designee Contractor to complete a portion of the Quality Assurance process, who has met the requirements of section……. 905.3 of this Chapter. Response: Reject Reason: all individuals conducted QA must be trained agents of RESNET so delegates will not be allowed
RESNETS creation of the Quality Assurance Contractor/Agent should in no way affect the ability of said contractor/agent from utilizing a QA Delegate. Similar to a Rater utilizing and RFI the QA contractor/Agent would have to take full ownership of the Quality assurance review. Having better definitions of how one can be a delegate and how they are used should remain in the standard. This is a cost effective solution volume and demand issue and in particular is needed to maintain a rating presence in rural areas.
Definitions
Quality Assurance Designee Contractor Delegate (QA Delegate) – An individual certified as a Home Energy Rater , appointed by a Quality Assurance Designee Contractor to complete a portion of the Quality Assurance process, who has met the requirements of section……. 905.3 of this Chapter.
Reason: all individuals conducted QA must be trained agents of RESNET so delegates will not be allowed
Comment #419Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: B-1Paragraph / Figure / Table / Note: Direct Rating Quality Assurance ProviderComment Intent: ObjectionComment Type: GeneralComment: This is NOT the definition adopted by the RESNET Board of Directors at the November 2014 Board meeting. Proposed Change: Strike the following in its entirety: Direct Rating Quality Assurance Provider (Direct Provider) – A Rating Quality Assurance Provider who receives fees for rating work completed by third-party Rating Companies and/or whose staff conducts all or a portion of the work for a rating. Replace with: Direct Rating Provider: A Provider who either receives fees for the rating or whose staff conduct any portion of the rating. Response: Accept
This is NOT the definition adopted by the RESNET Board of Directors at the November 2014 Board meeting.
Direct Rating Provider: A Provider who either receives fees for the rating or whose staff conduct any portion of the rating.
Comment #420Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: B-1Paragraph / Figure / Table / Note: GlossaryComment Intent: ObjectionComment Type: TechnicalComment: Currently only Confirmed files can be now be uploaded to the registry. Numerous large providers in the past have been uploading files which are NOT a confimed rating but rather a projected rating meeting certain threshold performance requirements. It needs to be noted in the QA Chapter 9 that only confirmed ratings are uploaded to the registry and QA will be perfomed on confirmed ratings not ratings meeting threshold requirements. In the future if other types of ratings are allowed to be input in the REGISTRY then additional language can be put into Chapter 9 to deal with these other types of ratings. Proposed Change: Energy Simulation File – The complete set of input data used by a RESNET-accredited rating software tool to determine the Confirmed Home Energy Rating for the specified home as listed in Section 102.1.4.11Chapter 3 of these Standards and uploaded to the National RESNET Registry as a Confirmed file. Response: Reject Reason: keeping it just home energy rating captures both confirmed and sampled ratings as well as well as any other future rating type
Currently only Confirmed files can be now be uploaded to the registry. Numerous large providers in the past have been uploading files which are NOT a confimed rating but rather a projected rating meeting certain threshold performance requirements. It needs to be noted in the QA Chapter 9 that only confirmed ratings are uploaded to the registry and QA will be perfomed on confirmed ratings not ratings meeting threshold requirements.
In the future if other types of ratings are allowed to be input in the REGISTRY then additional language can be put into Chapter 9 to deal with these other types of ratings.
Energy Simulation File – The complete set of input data used by a RESNET-accredited rating software tool to determine the Confirmed Home Energy Rating for the specified home as listed in Section 102.1.4.11Chapter 3 of these Standards and uploaded to the National RESNET Registry as a Confirmed file.
Reason: keeping it just home energy rating captures both confirmed and sampled ratings as well as well as any other future rating type
Comment #421Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 63Paragraph / Figure / Table / Note: Projected RatingComment Intent: ObjectionComment Type: EditorialComment: Projected Ratings loophole, undermines efforts to increase Quality Assurance: Definition and requirements related to "Projected Ratings" have been removed from this draft. Referencing ANSI/RESNET 301-2014, the use of projected ratings remains subjective. The intent of increasing Quality outlined in this document is comprismised without further defining Projected Ratings' parameters. ie, projected ratings are not clearly stated as being invaild as a final product for builders/clients. If not clearly oultned in this revision, some Rating Providers may continue to choose to use the Projected Rating loophole and forgo the Quality Assurance requirements outlined in this draft. Cost/time savings related to Quality Assurance and RESNET fees may incentivize Rating Providers to deliver projected ratings instead of confirmed or sampled ratings. Without clear parameters of how a projected rating may be used, I do not believe RESNET will meet their intent. Please consider adding definitions and parameters related to the proper use of Projected Ratings. -Daniel Proposed Change: Projected Rating Definition: Do not delete the definition of what a projected rating is. Add parameters of what a projected rating can be. Clearly state what a projected rating may not be used for (not a final product, certification, or marketing material for builder clients). -I'll leave it to you to put it in the proper language. Response: Reject Reason: the official definition of a projected rating is in 301 and the enforcement of how projected ratings are used is not a function of quality assurance
Projected Ratings loophole, undermines efforts to increase Quality Assurance:
Definition and requirements related to "Projected Ratings" have been removed from this draft. Referencing ANSI/RESNET 301-2014, the use of projected ratings remains subjective. The intent of increasing Quality outlined in this document is comprismised without further defining Projected Ratings' parameters. ie, projected ratings are not clearly stated as being invaild as a final product for builders/clients. If not clearly oultned in this revision, some Rating Providers may continue to choose to use the Projected Rating loophole and forgo the Quality Assurance requirements outlined in this draft. Cost/time savings related to Quality Assurance and RESNET fees may incentivize Rating Providers to deliver projected ratings instead of confirmed or sampled ratings.
Without clear parameters of how a projected rating may be used, I do not believe RESNET will meet their intent. Please consider adding definitions and parameters related to the proper use of Projected Ratings.
-Daniel
Projected Rating Definition: Do not delete the definition of what a projected rating is. Add parameters of what a projected rating can be. Clearly state what a projected rating may not be used for (not a final product, certification, or marketing material for builder clients).
-I'll leave it to you to put it in the proper language.
Reason: the official definition of a projected rating is in 301 and the enforcement of how projected ratings are used is not a function of quality assurance
Comment #422Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 905.7Paragraph / Figure / Table / Note: QAD DelegateComment Intent: ObjectionComment Type: TechnicalComment: 905.7 and 905.7.1. QAD-D personnel are Provider-qualified personnel that assist the QAD immensely throughout the year in the quality oversight of Active Raters, in near and far geographic areas. QAD-D personnel allow additional qualified Provider-QAD direction into Rater field activities at scheduled times, which allows the Provider-QAD more opportunities for oversight that was only seen once per year in the past. All QAD-Ds are required to comply with all expectations of their assigned QAD. The RESNET Providers across the USA rely on this additional field-support structure, since this presence brings reality to the building industry changes and product upgrades experienced by the Raters, directly back to the Provider-QAD. This in turn allows for proper review and approvals back to the Rater businesses. Removing this section serves no purpose to RESNET, breaks up a strong team of proven qualified Quality Assurance groups across the USA, and is highly objected to by this RESNET Provider. Proposed Change: Keep as is. High-quality RESNET Quality Assurance will suffer without this. Response: Reject Reason: all individuals conducted QA must be trained agents of RESNET so delegates will not be allowed
905.7 and 905.7.1.
QAD-D personnel are Provider-qualified personnel that assist the QAD immensely throughout the year in the quality oversight of Active Raters, in near and far geographic areas.
QAD-D personnel allow additional qualified Provider-QAD direction into Rater field activities at scheduled times, which allows the Provider-QAD more opportunities for oversight that was only seen once per year in the past. All QAD-Ds are required to comply with all expectations of their assigned QAD.
The RESNET Providers across the USA rely on this additional field-support structure, since this presence brings reality to the building industry changes and product upgrades experienced by the Raters, directly back to the Provider-QAD. This in turn allows for proper review and approvals back to the Rater businesses.
Removing this section serves no purpose to RESNET, breaks up a strong team of proven qualified Quality Assurance groups across the USA, and is highly objected to by this RESNET Provider.
Keep as is. High-quality RESNET Quality Assurance will suffer without this.
Comment #423Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-4Paragraph / Figure / Table / Note: Section 904.3.1.1Comment Intent: Not an ObjectionComment Type: EditorialComment: For QA File and QA Field reviews, it is being proposed that the HERS Rater's “annual total of ratings” be considered as all ratings entered into the National RESNET Registry (based on “date submitted”) for a calendar year, i.e. the twelve month period from January 1st through December 31st (Section 904.3.1.1). The Registry does not have a “date submitted” category. Recommend language is aligned to the Registry’s language, “Date Registered” or “Date Rated” and I recommend “Date Registered” best aligns with the intent of "date submitted" Alternatively, change the registry text to align with your proposed langauge Proposed Change: 904.3.1.1 For QA File and QA Field reviews, the HERS Rater's “annual total of ratings” shall mean all ratings entered into the National RESNET Registry (based on “date submitted registered”) for a calendar year, i.e. the twelve month period from January 1st through December 31st . Response: Accept
For QA File and QA Field reviews, it is being proposed that the HERS Rater's “annual total of ratings” be considered as all ratings entered into the National RESNET Registry (based on “date submitted”) for a calendar year, i.e. the twelve month period from January 1st through December 31st (Section 904.3.1.1).
904.3.1.1 For QA File and QA Field reviews, the HERS Rater's “annual total of ratings” shall mean all ratings entered into the National RESNET Registry (based on “date submitted registered”) for a calendar year, i.e. the twelve month period from January 1st through December 31st .
Comment #424Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: 9-18Paragraph / Figure / Table / Note: Section 905.7Comment Intent: ObjectionComment Type: GeneralComment: I recommend that the QA Delegates not be removed from the Standards. They could be renamed as Quality Agent Delegates (QA Delegates?). I think the Quality Agent Delegates can play an important role in keeping QA Field Review costs down for HERS Raters and RESNET Rating Providers. As long as the Quality Agent Delegates have financial independence from the HERS Raters and Quality Agents that they serve, it allows the RESNET QAD network in more rural and smaller states to have a local qualified person available to do QA Inspections onsite for reasonable cost. This helps to keep the costs down for HERS Raters and RESNET Providers; as opposed to paying our Rating Providers for out-of-state Quality Agents to come to the rural or small states to do QA Field Reviews of HERS Ratings. (Example: As a LEED for Homes Green Rater, I have to pay for travel expenses for a LEED QAD to travel to Utah from out of state for my annual QA visits. This is an overhead expense that drives up my LEED for Homes fees; sometimes to the point that potential clients opt out due to cost.) At a time when RESNET Is hoping to expand into rural areas, it seems wise to maintain a Quality Assurance network that can act locally to keep HERS Rating overhead costs down. Here in Utah, the HERS Rater community already has a hard time selling RESNET services to a reluctant and skeptical builder community. If our fees have to increase to cover our increased overhead costs, it seems that RESNET will further lose traction in these types of areas in the country. Proposed Change: 905.7 Quality Agent Delegate (QA Delegate) Quality Agents may have the file review and on-site inspection responsibilities performed by a Quality Agent Delegate. The Quality Agent, however, remains responsible for the accuracy and compliance of the quality assurance program, including reviews and inspections completed by a QA Delegate. 905.7.1 A QA Delegate must be a certified Home Energy Rater and have completed, on a minimum of fifty (50) homes, the portion of the inspection or rating process for which the individual is performing quality assurance tasks. In other words, if the QA Delegate is repeating on-site testing and inspections as part of the QA process, that individual must have at least performed these tasks on a minimum of fifty (50) homes. 905.7.2 The Quality Agent is responsible for ensuring that the QA Delegate meets and maintains their qualifications to be a QA Delegate, contained in 905.7.1. Response: Reject Reason: all individuals conducted QA must be trained agents of RESNET so delegates will not be allowed
I recommend that the QA Delegates not be removed from the Standards. They could be renamed as Quality Agent Delegates (QA Delegates?). I think the Quality Agent Delegates can play an important role in keeping QA Field Review costs down for HERS Raters and RESNET Rating Providers. As long as the Quality Agent Delegates have financial independence from the HERS Raters and Quality Agents that they serve, it allows the RESNET QAD network in more rural and smaller states to have a local qualified person available to do QA Inspections onsite for reasonable cost. This helps to keep the costs down for HERS Raters and RESNET Providers; as opposed to paying our Rating Providers for out-of-state Quality Agents to come to the rural or small states to do QA Field Reviews of HERS Ratings. (Example: As a LEED for Homes Green Rater, I have to pay for travel expenses for a LEED QAD to travel to Utah from out of state for my annual QA visits. This is an overhead expense that drives up my LEED for Homes fees; sometimes to the point that potential clients opt out due to cost.) At a time when RESNET Is hoping to expand into rural areas, it seems wise to maintain a Quality Assurance network that can act locally to keep HERS Rating overhead costs down. Here in Utah, the HERS Rater community already has a hard time selling RESNET services to a reluctant and skeptical builder community. If our fees have to increase to cover our increased overhead costs, it seems that RESNET will further lose traction in these types of areas in the country.
905.7 Quality Agent Delegate (QA Delegate) Quality Agents may have the file review and on-site inspection responsibilities performed by a Quality Agent Delegate. The Quality Agent, however, remains responsible for the accuracy and compliance of the quality assurance program, including reviews and inspections completed by a QA Delegate.
905.7.1 A QA Delegate must be a certified Home Energy Rater and have completed, on a minimum of fifty (50) homes, the portion of the inspection or rating process for which the individual is performing quality assurance tasks. In other words, if the QA Delegate is repeating on-site testing and inspections as part of the QA process, that individual must have at least performed these tasks on a minimum of fifty (50) homes.
905.7.2 The Quality Agent is responsible for ensuring that the QA Delegate meets and maintains their qualifications to be a QA Delegate, contained in 905.7.1.
Comment #425Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: B-1Paragraph / Figure / Table / Note: Third-party Rating Quality Assurance ProviderComment Intent: ObjectionComment Type: GeneralComment: This is NOT the definition adopted by the RESNET Board of Directors at the November 2014 Board meeting. Proposed Change: Strike the following in its entirety: Third-party Rating Quality Assurance Provider (Third-party Provider) - A Rating Quality Assurance Provider whose employees are not allowed to conduct any portion of the work for a HERS rating but who may receive fees for performing quality assurance work as outlined in these Standards, quality assurance oversight, certification and other Quality Assurance Provider related duties. Replace with: Third-party Provider: Providers who do not receive fees for the rating and whose staff do not conduct any portion of the rating. Response: Accept
Third-party Rating Quality Assurance Provider (Third-party Provider) - A Rating Quality Assurance Provider whose employees are not allowed to conduct any portion of the work for a HERS rating but who may receive fees for performing quality assurance work as outlined in these Standards, quality assurance oversight, certification and other Quality Assurance Provider related duties.
Third-party Provider: Providers who do not receive fees for the rating and whose staff do not conduct any portion of the rating.
Comment #426Amendment: Proposed Amendment to HERS Rating Quality Assurance Oversight StandardPage Number: unsureParagraph / Figure / Table / Note: unsureComment Intent: Not an ObjectionComment Type: GeneralComment: RESNET is putting a lot of firewalls up in an attempt to keep conflicts of interests from occuring within the industry. RESNET should be asking the same thing of themselves and their board members. Update conflict of interest provisions, it doesn’t appear to cover RESNET (employee or board of directors) financial affiliation with rating software company’s that could profit (or otherwise benefit via penalties to competitors) via shifts in future standards. Standards that are called for by Board decisions and adopted by the Board. This actually could go beyond software companies to QA Providers and Direct Providers as well since decisions by the Board can and do position some Providers for financial gain above others. It would not be acceptable if a member of the Board angles for financial advantage using their position of power. We are not at all suggesting this is occurring, but the Board should rule itself in a similar manner as it expects Providers to engage with its clients. Proposed Change: Update conflict of interest provisions, it doesn’t appear to cover RESNET (employee or board of directors) financial affiliation with rating software company’s that could profit (or otherwise benefit via penalties to competitors) via shifts in future standards. Standards that are called for by Board decisions and adopted by the Board. This actually could go beyond software companies to QA Providers and Direct Providers as well since decisions by the Board can and do position some Providers for financial gain above others. It would not be acceptable if a member of the Board angles for financial advantage using their position of power. We are not at all suggesting this is occurring, but the Board should rule itself in a similar manner as it expects Providers to engage with its clients. Response: Accept Reason: Accept in principle. RESNET Board of Director is currently reviewing and approving a new conflict of interest policy
RESNET is putting a lot of firewalls up in an attempt to keep conflicts of interests from occuring within the industry. RESNET should be asking the same thing of themselves and their board members.
Update conflict of interest provisions, it doesn’t appear to cover RESNET (employee or board of directors) financial affiliation with rating software company’s that could profit (or otherwise benefit via penalties to competitors) via shifts in future standards. Standards that are called for by Board decisions and adopted by the Board. This actually could go beyond software companies to QA Providers and Direct Providers as well since decisions by the Board can and do position some Providers for financial gain above others. It would not be acceptable if a member of the Board angles for financial advantage using their position of power. We are not at all suggesting this is occurring, but the Board should rule itself in a similar manner as it expects Providers to engage with its clients.
Reason: Accept in principle. RESNET Board of Director is currently reviewing and approving a new conflict of interest policy
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