Comment #1Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 1, 2Paragraph / Figure / Table / Note: 903.1.2Comment Intent: Not an ObjectionComment Type: EditorialComment: The RESNET Quality Assurance Report Submittal Checklist intended for use as of January 1st of each year should be provided to Rating QA Providers in advance to allow time for comments, changes, or discussion ahead of adoption. In addition, the language regarding changes that are made throughout the course of the year is vauge. Changes or additions should be communicated to QA Providers at least 30 days prior to the beginning of the quarter in which the changes/additions will take effect. Proposed Change: 903.1.2 Annual REVIEW OF Rating Quality Assurance Provider Report Submission And Enhanced Quality Assurance REVIEWS Monitoring Of QA Providers 903.1.2.1 RESNET shall provide a “RESNET Quality Assurance Report Submittal Checklist” that lists the required contents of the annual submittal report. 903.1.2.1.1 This checklist shall be provided to Rating Quality Assurance Providers by January 1st of each year . This checklist shall be provided to Rating Quality Assurance Providers by October 1st of each year to allow time for review and changes or clarifications. Final drafts shall be available by December 1st of each year, and uUpdated checklists shall be implemented on January 1st of each year. 903.1.2.1.2 In the case of new required records retention or tracking item deemed by RESNET to be required which has not previously been communicated, notice of the new requirement shall be delivered to Rating Quality Assurance Providers with a reasonable deadline at least 30 days prior to the quarter in which for initiating this tracking will be initiated. RESNET shall not require the item for the time frame prior to this deadline notification.
The RESNET Quality Assurance Report Submittal Checklist intended for use as of January 1st of each year should be provided to Rating QA Providers in advance to allow time for comments, changes, or discussion ahead of adoption. In addition, the language regarding changes that are made throughout the course of the year is vauge. Changes or additions should be communicated to QA Providers at least 30 days prior to the beginning of the quarter in which the changes/additions will take effect.
903.1.2 Annual REVIEW OF Rating Quality Assurance Provider Report Submission And Enhanced Quality Assurance REVIEWS Monitoring Of QA Providers
903.1.2.1 RESNET shall provide a “RESNET Quality Assurance Report Submittal Checklist” that lists the required contents of the annual submittal report.
903.1.2.1.1 This checklist shall be provided to Rating Quality Assurance Providers by January 1st of each year . This checklist shall be provided to Rating Quality Assurance Providers by October 1st of each year to allow time for review and changes or clarifications. Final drafts shall be available by December 1st of each year, and uUpdated checklists shall be implemented on January 1st of each year.
903.1.2.1.2 In the case of new required records retention or tracking item deemed by RESNET to be required which has not previously been communicated, notice of the new requirement shall be delivered to Rating Quality Assurance Providers with a reasonable deadline at least 30 days prior to the quarter in which for initiating this tracking will be initiated. RESNET shall not require the item for the time frame prior to this deadline notification.
Comment #2Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: 903.1.2.2Comment Intent: Not an ObjectionComment Type: EditorialComment: The language regarding detailed review should state clearly that at least 25% of QA Providers will be chosen on an annual basis. Proposed Change: 903.1.2.2 RESNET shall review 100% of the annual Rating Quality Assurance Provider Quality Assurance Reports submitted by Quality Assurance Designees. Quality Assurance Providers 903.1.2.2.1 In addition, RESNET shall select a minimum of 25% of accredited QA Providers on an annual basis and conduct a more detailed review of their Quality Assurance process . 903.1.2.2.2 This QA review may be enhanced monitoring of QA Provider files and quality assurance process done remotely, an on-site field review, or any combination of these. 903.1.2.2.3 903.3 Quality Assurance File Review RESNET will centrally administer quality assurance review of ratings using data in the National RESNET Registry.
The language regarding detailed review should state clearly that at least 25% of QA Providers will be chosen on an annual basis.
903.1.2.2 RESNET shall review 100% of the annual Rating Quality Assurance Provider Quality Assurance Reports submitted by Quality Assurance Designees. Quality Assurance Providers
903.1.2.2.1 In addition, RESNET shall select a minimum of 25% of accredited QA Providers on an annual basis and conduct a more detailed review of their Quality Assurance process .
903.1.2.2.2 This QA review may be enhanced monitoring of QA Provider files and quality assurance process done remotely, an on-site field review, or any combination of these.
903.1.2.2.3 903.3 Quality Assurance File Review RESNET will centrally administer quality assurance review of ratings using data in the National RESNET Registry.
Comment #3Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: 903.1.2.3Comment Intent: Not an ObjectionComment Type: EditorialComment: New providers will benefit from enhanced review of their initial submissions, not just generally throughout their first 12 months. This is a practice sucessfully adopted by other programs, and we suggest RESNET adopt it as well. Proposed Change: 903.1.2.3 RESNET Staff shall review the first five submissions made byconduct enhanced review of newly accredited Rating Quality Assurance Providers. In addition, RESNET staff shall conduct an enhanced review as noted below within twelve months of accreditation .
New providers will benefit from enhanced review of their initial submissions, not just generally throughout their first 12 months. This is a practice sucessfully adopted by other programs, and we suggest RESNET adopt it as well.
903.1.2.3 RESNET Staff shall review the first five submissions made byconduct enhanced review of newly accredited Rating Quality Assurance Providers. In addition, RESNET staff shall conduct an enhanced review as noted below within twelve months of accreditation .
Comment #4Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: 903.1.2.4Comment Intent: Not an ObjectionComment Type: EditorialComment: Enhanced review of Rating Quality Assurance Providers should be done at a rate equivalent to the rate of File and Field QA conducted by the QA Provider. We also suggest that the items included for this review include photos and other documentation required by RESNET/ANSI 301-2018 Addendum B for file reviews. Rater agreements made between the Provider and their clients should not be included in this review. Proposed Change: 903.1.2.4.1 Records reviewedEnhanced review by RESNET may include, but are is not limited to 1% of a Provider’s Field QA and 10% of File QA submissions, and shall include, a representative sample of the following: 903.1.2.4.1.1 Rating electronic files; 903.1.2.4.1.2 Photo and/or video documentation associated with rating files; 903.1.2.4.1.32 Rating quality assurance records including, but not limited to the following: 903.1.2.4.1.32.1 Photo and/or video documentation from on-site field reviews; 903.1.2.4.1.32.2 The Rating Quality Assurance Provider’s file review reports of findings submitted to Raters; 903.1.2.4.1.32.3 The Rating Quality Assurance Provider’s field review of rating results that show a comparison with original ratings selected for on-site QA review; 903.1.2.4.1.32.4 If remedial action is required, the Rating Quality Assurance Provider’s plan of action to correct for non-compliance with the RESNET Standards and results of any action taken; 903.1.2.4.1.32.5 Complaint files; 903.1.2.4.1.2.6 Rater agreements ; 903.1.2.4.1.2.7 Rater registry ; 903.1.2.4.1.2.8 Disclosure files; 903.1.2.4.1.2.9 Certification and Training documents.
Enhanced review of Rating Quality Assurance Providers should be done at a rate equivalent to the rate of File and Field QA conducted by the QA Provider. We also suggest that the items included for this review include photos and other documentation required by RESNET/ANSI 301-2018 Addendum B for file reviews. Rater agreements made between the Provider and their clients should not be included in this review.
903.1.2.4.1 Records reviewedEnhanced review by RESNET may include, but are is not limited to 1% of a Provider’s Field QA and 10% of File QA submissions, and shall include, a representative sample of the following:
903.1.2.4.1.1 Rating electronic files;
903.1.2.4.1.2 Photo and/or video documentation associated with rating files;
903.1.2.4.1.32 Rating quality assurance records including, but not limited to the following:
903.1.2.4.1.32.1 Photo and/or video documentation from on-site field reviews;
903.1.2.4.1.32.2 The Rating Quality Assurance Provider’s file review reports of findings submitted to Raters;
903.1.2.4.1.32.3 The Rating Quality Assurance Provider’s field review of rating results that show a comparison with original ratings selected for on-site QA review; 903.1.2.4.1.32.4 If remedial action is required, the Rating Quality Assurance Provider’s plan of action to correct for non-compliance with the RESNET Standards and results of any action taken;
903.1.2.4.1.32.5 Complaint files;
903.1.2.4.1.2.6 Rater agreements ;
903.1.2.4.1.2.7 Rater registry ;
903.1.2.4.1.2.8 Disclosure files;
903.1.2.4.1.2.9 Certification and Training documents.
Comment #5Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 3Paragraph / Figure / Table / Note: 903.1.2.5Comment Intent: Not an ObjectionComment Type: EditorialComment: The language in section 903.1.2.5 regarding inconsistencies and errors found during the enhanced review of QA Providers is vague. A percentage, as is defined for Raters, and/or a list of "significant inconsistencies" should be provided by RESNET to standardize this process and provide consistency, as well as to set expectations for QA Providers. Proposed Change: 903.1.2.5 Significant inconsistencies or errors in electronic records reviewed, as defined below may result in an on-site review by RESNET . 903.1.2.5.1 Missing photo and/or video documentation 903.1.2.5.2 Inconsistencies or errors in file review reports 903.1.2.5.3 Incomplete or missing complaint files 903.1.2.5.3.4 Incomplete or missing disclosure files 903.1.2.5.3.5 Incomplete, inaccurate or missing certification and training documents
The language in section 903.1.2.5 regarding inconsistencies and errors found during the enhanced review of QA Providers is vague. A percentage, as is defined for Raters, and/or a list of "significant inconsistencies" should be provided by RESNET to standardize this process and provide consistency, as well as to set expectations for QA Providers.
903.1.2.5 Significant inconsistencies or errors in electronic records reviewed, as defined below may result in an on-site review by RESNET .
903.1.2.5.1 Missing photo and/or video documentation
903.1.2.5.2 Inconsistencies or errors in file review reports
903.1.2.5.3 Incomplete or missing complaint files
903.1.2.5.3.4 Incomplete or missing disclosure files
903.1.2.5.3.5 Incomplete, inaccurate or missing certification and training documents
Comment #6Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 3Paragraph / Figure / Table / Note: 903.1.3.1Comment Intent: Not an ObjectionComment Type: EditorialComment: The timeline for taking corrective action should be shortened, except where the action is to submit quarterly documentation or other documentation by a certain date. In addition, the notice should always include the associated disciplinary status, regardless of the severity of the incident. Proposed Change: 903.1.3.1 NOTIFICATION OF DISCIPLINARY ACTION If RESNET determines at any time that a Rating Quality Assurance Provider has failed to adhere to the requirements set forth in these Standards, RESNET shall notify by email, or other method which provides evidence of delivery, the Rating Quality Assurance Provider and Primary Quality Assurance Designee of the non-compliance and decisions under this section. Notification shall include: 903.1.3.1.1 Entire basis and justification for the disciplinary action; 903.1.3.1.2 Clarification of the procedures as stipulated in this Standard, and include, where applicable, a Statement of the Rating Quality Assurance Provider’s rights to appeal under Section 912 of this chapter. 903.1.3.1.3 Specific corrective action required to be taken no later than twenty (20) five (5) business days after the date set forth in such notification , unless otherwise specified (ex. requirement for quarterly submissions by date specified); 903.1.3.1.4 Notice of disciplinary action may or may not shall include disciplinary status as detailed in Section 904.6, depending on the severity of the incident .
The timeline for taking corrective action should be shortened, except where the action is to submit quarterly documentation or other documentation by a certain date. In addition, the notice should always include the associated disciplinary status, regardless of the severity of the incident.
903.1.3.1 NOTIFICATION OF DISCIPLINARY ACTION If RESNET determines at any time that a Rating Quality Assurance Provider has failed to adhere to the requirements set forth in these Standards, RESNET shall notify by email, or other method which provides evidence of delivery, the Rating Quality Assurance Provider and Primary Quality Assurance Designee of the non-compliance and decisions under this section. Notification shall include:
903.1.3.1.1 Entire basis and justification for the disciplinary action;
903.1.3.1.2 Clarification of the procedures as stipulated in this Standard, and include, where applicable, a Statement of the Rating Quality Assurance Provider’s rights to appeal under Section 912 of this chapter.
903.1.3.1.3 Specific corrective action required to be taken no later than twenty (20) five (5) business days after the date set forth in such notification , unless otherwise specified (ex. requirement for quarterly submissions by date specified);
903.1.3.1.4 Notice of disciplinary action may or may not shall include disciplinary status as detailed in Section 904.6, depending on the severity of the incident .
Comment #7Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 3, 4Paragraph / Figure / Table / Note: 903.1.3.2Comment Intent: Not an ObjectionComment Type: EditorialComment: Further oversight at the expense of the Quality Assurance Provider should be capped, and something that both parties agree on. Other changes to this section are suggested to improve clarity in the process and language. Proposed Change: 903.1.3.2 Disciplinary Action Options Failure of a Rating Quality Assurance Provider to properly fulfill their responsibilities or an outcome of RESNET’s annual report, online review, on-site visit or complaint review as specified in these Standards may include one or more of the following actions by RESNET: 903.1.3.2.1 The QA Provider being placed in the disciplinary status of probation or suspension as defined in Section 904.7 and Section 904.8, respectively; 903.1.3.2.24 At the Rating Quality Assurance Provider’s expense, further oversight by RESNET . Such expense shall be agreed upon in advance by both parties, and capped at $5,000. 903.1.3.2.23 Revocation of the Accreditation of a Rating Quality Assurance Provider. 903.1.3.2.34 Removal of the QA Provider from the RESNET Directory of accredited Providers; 903.1.3.2.4 At the Rating Quality Assurance Provider’s expense, further oversight by RESNET .
Further oversight at the expense of the Quality Assurance Provider should be capped, and something that both parties agree on. Other changes to this section are suggested to improve clarity in the process and language.
903.1.3.2 Disciplinary Action Options Failure of a Rating Quality Assurance Provider to properly fulfill their responsibilities or an outcome of RESNET’s annual report, online review, on-site visit or complaint review as specified in these Standards may include one or more of the following actions by RESNET:
903.1.3.2.1 The QA Provider being placed in the disciplinary status of probation or suspension as defined in Section 904.7 and Section 904.8, respectively;
903.1.3.2.24 At the Rating Quality Assurance Provider’s expense, further oversight by RESNET . Such expense shall be agreed upon in advance by both parties, and capped at $5,000.
903.1.3.2.23 Revocation of the Accreditation of a Rating Quality Assurance Provider.
903.1.3.2.34 Removal of the QA Provider from the RESNET Directory of accredited Providers;
903.1.3.2.4 At the Rating Quality Assurance Provider’s expense, further oversight by RESNET .
Comment #8Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 4Paragraph / Figure / Table / Note: 903.1.3.3Comment Intent: Not an ObjectionComment Type: EditorialComment: Language in the section regarding Probation is redundant. We also do not see a need for probationary status to be made public. Should the situation escalate to suspension or revocation, there is language in place at that point to make information public as necessary. Probationary status should be used as an opportunity to improve operations. Proposed Change: 903.1.3.3 Probation 903.1.3.3.1 Administrative probation resulting from violations defined in this chapter shall remain confidential between the Rating Quality Assurance Provider and RESNET. RESNET shall determine the length of administrative probation not to exceed 12 months. 903.1.3.3.2 RESNET shall, at its discretion, make a final determination regarding the necessity of posting a disciplinary probation on the RESNET web site . 903.1.3.3.3 RESNET shall determine the length of disciplinary probation resulting from violations defined in this chapter not to exceed 12 months .
Language in the section regarding Probation is redundant. We also do not see a need for probationary status to be made public. Should the situation escalate to suspension or revocation, there is language in place at that point to make information public as necessary. Probationary status should be used as an opportunity to improve operations.
903.1.3.3 Probation
903.1.3.3.1 Administrative probation resulting from violations defined in this chapter shall remain confidential between the Rating Quality Assurance Provider and RESNET. RESNET shall determine the length of administrative probation not to exceed 12 months.
903.1.3.3.2 RESNET shall, at its discretion, make a final determination regarding the necessity of posting a disciplinary probation on the RESNET web site .
903.1.3.3.3 RESNET shall determine the length of disciplinary probation resulting from violations defined in this chapter not to exceed 12 months .
Comment #9Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 4Paragraph / Figure / Table / Note: 903.1.3.4Comment Intent: Not an ObjectionComment Type: EditorialComment: The length of a Provider's Suspension or Reovcation should be based on the severity of the incident. In addition, the timeframe for removing the listing once the Provider has successfully complied with the terms of suspension or revocation should be shortened. Proposed Change: 903.1.3.4 Suspension or Revocation 903.1.3.4.1 RESNET shall determine the length of the Rating Quality Assurance Provider’s suspension not to exceed 12 months based on the severity of the incident as defined in Section 904.8. 903.1.3.4.2 RESNET shall remove the Rating Quality Assurance Provider from the appropriate RESNET Directory when accreditation is suspended or revoked, pending the results of any appeal per Section 912. 903.1.3.4.3 RESNET shall prohibit the provider from uploading rating files to the RESNET Building Registry until the Provider successfully complies with the terms of the suspension or revocation. 903.1.3.4.4 RESNET shall post on its website, pending the results of any appeal, Rating Quality Assurance Providers whose accreditation has been suspended or revoked. The Rating Quality Assurance Provider suspension or revocation listing shall be removed when they have successfully complied with the terms of the suspension or revocation, within 105 business days of successfully resolving the issue . 903.1.3.4.5 RESNET shall electronically inform a Rating Quality Assurance Provider’s known client(s), other accredited Providers, program administrators, rating software suppliers, Quality Assurance Designees, Home Energy Raters, Rating Field Inspectors, and any affected EEPs of the Rating Quality Assurance Provider’s suspended or revoked status. To the extent feasible, the Rating Quality Assurance Provider and Quality Assurance Designees shall assist RESNET with notifications.
The length of a Provider's Suspension or Reovcation should be based on the severity of the incident. In addition, the timeframe for removing the listing once the Provider has successfully complied with the terms of suspension or revocation should be shortened.
903.1.3.4 Suspension or Revocation
903.1.3.4.1 RESNET shall determine the length of the Rating Quality Assurance Provider’s suspension not to exceed 12 months based on the severity of the incident as defined in Section 904.8.
903.1.3.4.2 RESNET shall remove the Rating Quality Assurance Provider from the appropriate RESNET Directory when accreditation is suspended or revoked, pending the results of any appeal per Section 912.
903.1.3.4.3 RESNET shall prohibit the provider from uploading rating files to the RESNET Building Registry until the Provider successfully complies with the terms of the suspension or revocation.
903.1.3.4.4 RESNET shall post on its website, pending the results of any appeal, Rating Quality Assurance Providers whose accreditation has been suspended or revoked. The Rating Quality Assurance Provider suspension or revocation listing shall be removed when they have successfully complied with the terms of the suspension or revocation, within 105 business days of successfully resolving the issue .
903.1.3.4.5 RESNET shall electronically inform a Rating Quality Assurance Provider’s known client(s), other accredited Providers, program administrators, rating software suppliers, Quality Assurance Designees, Home Energy Raters, Rating Field Inspectors, and any affected EEPs of the Rating Quality Assurance Provider’s suspended or revoked status. To the extent feasible, the Rating Quality Assurance Provider and Quality Assurance Designees shall assist RESNET with notifications.
Comment #10Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 4Paragraph / Figure / Table / Note: 903.1.3.5Comment Intent: Not an ObjectionComment Type: EditorialComment: The timeframe for receiving a response should be shortened to allow for expedited resolution of issues. Proposed Change: 903.1.3.5 Right to Challenge An accredited Rating Quality Assurance Provider has the right to challenge the findings of a RESNET Quality Assurance review. The Appeals Procedures shall apply to the submission and consideration of a challenge to Quality Assurance findings . 903.1.3.5.1 RESNET shall respond within 20 10 business days to the written notification on whether or not the Rating Quality Assurance Provider will be reinstated to the registry or if other action will be required .
The timeframe for receiving a response should be shortened to allow for expedited resolution of issues.
903.1.3.5 Right to Challenge
An accredited Rating Quality Assurance Provider has the right to challenge the findings of a RESNET Quality Assurance review. The Appeals Procedures shall apply to the submission and consideration of a challenge to Quality Assurance findings .
903.1.3.5.1 RESNET shall respond within 20 10 business days to the written notification on whether or not the Rating Quality Assurance Provider will be reinstated to the registry or if other action will be required .
Comment #11Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 5Paragraph / Figure / Table / Note: 903.2.2Comment Intent: Not an ObjectionComment Type: EditorialComment: As with the Provider's Disciplinary section above, the timeframe for corrective action to be taken by a QAD should be shortened, unless there is a specific date associated with the corrective action. This will also provide consistency within the process relating to timing. Proposed Change: 903.2.2.1 NOTIFICATION OF DISCIPLINARY ACTION If RESNET determines at any time that a Quality Assurance Designee has failed to adhere to the requirements set forth in these Standards, RESNET shall notify the Quality Assurance Designee and the Rating Quality Assurance Provider by email, or other method which provides evidence of delivery, of the non-compliance and decisions under this section. Notification shall include: 903.2.2.1.1 Entire basis and justification for the disciplinary action; 903.2.2.1.2 Clarification of the procedures as stipulated in this Standard, and include, where applicable, a Statement of the Quality Assurance Designee’s rights to appeal under Section 912 of this chapter. 903.2.2.1.3 Specific corrective action required to be taken no later than twenty (20)five (5) business days after the date set forth in such notification, unless otherwise specified ; 903.2.2.1.4 Notice of disciplinary action may or may not shall include disciplinary status, depending on the severity of the incident.
As with the Provider's Disciplinary section above, the timeframe for corrective action to be taken by a QAD should be shortened, unless there is a specific date associated with the corrective action. This will also provide consistency within the process relating to timing.
903.2.2.1 NOTIFICATION OF DISCIPLINARY ACTION
If RESNET determines at any time that a Quality Assurance Designee has failed to adhere to the requirements set forth in these Standards, RESNET shall notify the Quality Assurance Designee and the Rating Quality Assurance Provider by email, or other method which provides evidence of delivery, of the non-compliance and decisions under this section. Notification shall include:
903.2.2.1.1 Entire basis and justification for the disciplinary action;
903.2.2.1.2 Clarification of the procedures as stipulated in this Standard, and include, where applicable, a Statement of the Quality Assurance Designee’s rights to appeal under Section 912 of this chapter.
903.2.2.1.3 Specific corrective action required to be taken no later than twenty (20)five (5) business days after the date set forth in such notification, unless otherwise specified ;
903.2.2.1.4 Notice of disciplinary action may or may not shall include disciplinary status, depending on the severity of the incident.
Comment #12Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 5Paragraph / Figure / Table / Note: 903.2.2.2Comment Intent: Not an ObjectionComment Type: EditorialComment: A person's ability to perform as a QAD may or may not pertain to their abilities as a Home Energy Rater. Unless the failure by a QAD is due to fradulent or malicious activity, actions taken against them should not include losing recognition as a HERS Rater. Proposed Change: 903.2.2.2 DISCIPLINARY ACTION OPTIONS. Failure of a Quality Assurance Designee to properly fulfill their responsibilities as specified in these Standards may include one or more of the following actions by RESNET: 903.2.2.2.1 The QAD being placed on probation or suspension; 903.2.2.2.2 Revocation of QAD certification; 903.2.2.2.3 Removal of the QAD from the RESNET Directory of certified QADs; 903.2.2.2.4 RESNET no longer recognizing the QAD as a Home Energy Rater ; 903.2.2.2.5 At the Rating Quality Assurance Provider’s expense, further oversight by RESNET of the QAD and the Provider’s processes and procedures;
A person's ability to perform as a QAD may or may not pertain to their abilities as a Home Energy Rater. Unless the failure by a QAD is due to fradulent or malicious activity, actions taken against them should not include losing recognition as a HERS Rater.
903.2.2.2 DISCIPLINARY ACTION OPTIONS. Failure of a Quality Assurance Designee to properly fulfill their responsibilities as specified in these Standards may include one or more of the following actions by RESNET:
903.2.2.2.1 The QAD being placed on probation or suspension;
903.2.2.2.2 Revocation of QAD certification;
903.2.2.2.3 Removal of the QAD from the RESNET Directory of certified QADs;
903.2.2.2.4 RESNET no longer recognizing the QAD as a Home Energy Rater ;
903.2.2.2.5 At the Rating Quality Assurance Provider’s expense, further oversight by RESNET of the QAD and the Provider’s processes and procedures;
Comment #13Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 6Paragraph / Figure / Table / Note: 903.2.2.3Comment Intent: Not an ObjectionComment Type: EditorialComment: As with a section above, language in the sub-section is redundant, and Probationary status should not be made public. Proposed Change: 903.2.2.3 PROBATION 903.2.2.3.1 Administrative probation resulting from violations defined in this chapter shall remain confidential between the QAD, Rating Quality Assurance Provider, and RESNET. RESNET shall determine the length of administrative probation not to exceed 12 months . 903.2.2.3.2 RESNET shall, at its discretion, make a final determination regarding the necessity of posting a disciplinary probation resulting from violations on the RESNET web site . 903.2.2.3.3 RESNET shall determine the length of disciplinary probation resulting from violations defined in this chapter not to exceed 12 months.
As with a section above, language in the sub-section is redundant, and Probationary status should not be made public.
903.2.2.3 PROBATION 903.2.2.3.1 Administrative probation resulting from violations defined in this chapter shall remain confidential between the QAD, Rating Quality Assurance Provider, and RESNET. RESNET shall determine the length of administrative probation not to exceed 12 months .
903.2.2.3.2 RESNET shall, at its discretion, make a final determination regarding the necessity of posting a disciplinary probation resulting from violations on the RESNET web site .
903.2.2.3.3 RESNET shall determine the length of disciplinary probation resulting from violations defined in this chapter not to exceed 12 months.
Comment #14Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 6Paragraph / Figure / Table / Note: 903.2.2.5Comment Intent: Not an ObjectionComment Type: EditorialComment: The timeframe for response to a challenge should be shortened in order to expedite resolution of issues. Proposed Change: 903.2.2.5 RIGHT TO CHALLENGE A certified Quality Assurance Designee has the right to challenge the findings of a RESNET Quality Assurance review. The Appeals Procedures in Section 912 shall apply to the submission and consideration of a challenge to Quality Assurance findings. 903.2.2.5.1 RESNET shall respond within 20 10 business days to the written notification on whether or not the Quality Assurance Designee will be reinstated to the registry or if other action will be required .
The timeframe for response to a challenge should be shortened in order to expedite resolution of issues.
903.2.2.5 RIGHT TO CHALLENGE A certified Quality Assurance Designee has the right to challenge the findings of a RESNET Quality Assurance review. The Appeals Procedures in Section 912 shall apply to the submission and consideration of a challenge to Quality Assurance findings.
903.2.2.5.1 RESNET shall respond within 20 10 business days to the written notification on whether or not the Quality Assurance Designee will be reinstated to the registry or if other action will be required .
Comment #15Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 7Paragraph / Figure / Table / Note: 904.1Comment Intent: Not an ObjectionComment Type: GeneralComment: RESNET should create a policy around discipline regarding Providers, QADs and Raters to ensure consistency throughout the industry. Proposed Change: 904.1 General Responsibilities For Rating Quality Assurance Providers 904.1.1 Maintain knowledge of current RESNET Standards 904.1.2 Submit accurate and current Rating files to the RESNET Registry 904.1.3 Document Rating Quality Assurance Provider Policies and Procedures per Chapter 1 of these standards. 904.1.4 Enforce the Policies and Procedures of the Rating Quality Assurance Provider. 904.1.5 Document disciplinary action policies and procedures for Raters and Rating Field Inspectors (RFIs) within their rating providership. A QA Provider shall work with their QAD to jointly decide on appropriate disciplinary action based on the QA Provider’s policy and procedures manual. Disciplinary action is a documented step in the progressive disciplinary process of a Rating Quality Assurance Provider or RESNET. Disciplinary actions, as defined by RESNET, follow the progression of Probation, Suspension, and Revocation as detailed in these standards . 904.1.6 A Rating Quality Assurance Provider shall enforce disciplinary action against Raters or RFIs when non-compliance is found. 904.1.7 To the extent feasible, the Rating Quality Assurance Provider and their Quality Assurance Designee(s) shall assist RESNET with notifications to known clients when any Rating Quality Assurance Providers, QADs, Raters, or RFIs have their accreditation or certification revoked or suspended.
RESNET should create a policy around discipline regarding Providers, QADs and Raters to ensure consistency throughout the industry.
904.1 General Responsibilities For Rating Quality Assurance Providers
904.1.1 Maintain knowledge of current RESNET Standards
904.1.2 Submit accurate and current Rating files to the RESNET Registry
904.1.3 Document Rating Quality Assurance Provider Policies and Procedures per Chapter 1 of these standards.
904.1.4 Enforce the Policies and Procedures of the Rating Quality Assurance Provider.
904.1.5 Document disciplinary action policies and procedures for Raters and Rating Field Inspectors (RFIs) within their rating providership. A QA Provider shall work with their QAD to jointly decide on appropriate disciplinary action based on the QA Provider’s policy and procedures manual. Disciplinary action is a documented step in the progressive disciplinary process of a Rating Quality Assurance Provider or RESNET. Disciplinary actions, as defined by RESNET, follow the progression of Probation, Suspension, and Revocation as detailed in these standards .
904.1.6 A Rating Quality Assurance Provider shall enforce disciplinary action against Raters or RFIs when non-compliance is found.
904.1.7 To the extent feasible, the Rating Quality Assurance Provider and their Quality Assurance Designee(s) shall assist RESNET with notifications to known clients when any Rating Quality Assurance Providers, QADs, Raters, or RFIs have their accreditation or certification revoked or suspended.
Comment #16Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 7Paragraph / Figure / Table / Note: 904.2Comment Intent: Not an ObjectionComment Type: EditorialComment: The timeframe for a change in Primary QAD should be extended to allow the Provider adequate time to secure a replacement. When notifying RESNET of non-compliance issues, the timeframe should be shortened to expedite resolution of the issue. Proposed Change: 904.2 Rating Quality Assurance Provider Qad QAD Assignment A Provider shall designate a single RESNET certified officer, employee, or contractor to be the Primary Quality Assurance Designee (QAD) for the Quality Assurance Provider’s organization. The Primary QAD is responsible for quality assurance within the organization. This does not preclude a Provider from having more than one QAD on staff or as a contractor, as may be necessary for business models, such as where QADs perform Ratings. 904.2.1 Changes to a Rating Quality Assurance Provider’s QAD(s) 904.2.1.1 If a Rating Quality Assurance Provider changes the Primary QAD, or a Rating Quality Assurance Provider’s Primary QAD leaves the organization, is terminated as an outside contractor, or is no longer eligible, the following steps shall be taken: 904.2.1.1.1 Within five (5) business days of the Primary QAD change, departure, termination, or knowledge of ineligibility, the QA Provider shall inform RESNET of the change, departure, termination, or ineligibility; 904.2.1.1.2 In the case of a change in Primary QAD as a result of departure, termination, or ineligibility, the QA Provider shall have twenty (20)thirty (30) business days from the date of departure, termination, or knowledge of ineligibility to appoint a replacement Primary QAD and notify RESNET of the newly designated officer, employee, or contractor, including proof of qualifications . 904.2.1.1.3 If a Rating Quality Assurance Provider with multiple QADs adds or removes a QAD, the Rating Quality Assurance Provider shall inform RESNET within five (5) business days of the change. 904.2.1.1.4 If a Rating Quality Assurance Provider becomes aware of any significant non-compliance of the requirements set in these standards by a Quality Assurance Designee, the Provider shall inform RESNET in writing of the specific instance in a timely manner within five (5) business days with as much detail as possible .
The timeframe for a change in Primary QAD should be extended to allow the Provider adequate time to secure a replacement.
When notifying RESNET of non-compliance issues, the timeframe should be shortened to expedite resolution of the issue.
904.2 Rating Quality Assurance Provider Qad QAD Assignment A Provider shall designate a single RESNET certified officer, employee, or contractor to be the Primary Quality Assurance Designee (QAD) for the Quality Assurance Provider’s organization. The Primary QAD is responsible for quality assurance within the organization. This does not preclude a Provider from having more than one QAD on staff or as a contractor, as may be necessary for business models, such as where QADs perform Ratings.
904.2.1 Changes to a Rating Quality Assurance Provider’s QAD(s)
904.2.1.1 If a Rating Quality Assurance Provider changes the Primary QAD, or a Rating Quality Assurance Provider’s Primary QAD leaves the organization, is terminated as an outside contractor, or is no longer eligible, the following steps shall be taken:
904.2.1.1.1 Within five (5) business days of the Primary QAD change, departure, termination, or knowledge of ineligibility, the QA Provider shall inform RESNET of the change, departure, termination, or ineligibility;
904.2.1.1.2 In the case of a change in Primary QAD as a result of departure, termination, or ineligibility, the QA Provider shall have twenty (20)thirty (30) business days from the date of departure, termination, or knowledge of ineligibility to appoint a replacement Primary QAD and notify RESNET of the newly designated officer, employee, or contractor, including proof of qualifications .
904.2.1.1.3 If a Rating Quality Assurance Provider with multiple QADs adds or removes a QAD, the Rating Quality Assurance Provider shall inform RESNET within five (5) business days of the change.
904.2.1.1.4 If a Rating Quality Assurance Provider becomes aware of any significant non-compliance of the requirements set in these standards by a Quality Assurance Designee, the Provider shall inform RESNET in writing of the specific instance in a timely manner within five (5) business days with as much detail as possible .
Comment #17Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 12Paragraph / Figure / Table / Note: 904.3.5Comment Intent: Not an ObjectionComment Type: EditorialComment: The suggested edits below for this section are to remove redundant language and increase clarity within the section. Proposed Change: 904.3.5 QA Provider Disciplinary Action for Raters and RFIs In the case of nNon-compliance of a reviewed rating or misconduct of a HERS Rater or RFI, Rating Quality Assurance Providers are obligated to shall trigger corrective enforce disciplinary action if corrective action outlined by the Quality Assurance Designee is not effective. 904.3.5.14 The Provider shall work jointly with QAD to initiate appropriate disciplinary action on the HERS Rater/RFI in accordance with the Provider’s written HERS Rater/RFI disciplinary procedures . 904.3.5.2 A Provider shall enforce disciplinary action against Raters or RFIs when non-compliance is found, and corrective action is ineffective . 904.3.5.32 If a Rater or RFI refuses disciplinary action, Rating Quality Assurance Providers are required to report any non-compliance to RESNET Registry , as defined in 904.4.1.3.5.
The suggested edits below for this section are to remove redundant language and increase clarity within the section.
904.3.5 QA Provider Disciplinary Action for Raters and RFIs In the case of nNon-compliance of a reviewed rating or misconduct of a HERS Rater or RFI, Rating Quality Assurance Providers are obligated to shall trigger corrective enforce disciplinary action if corrective action outlined by the Quality Assurance Designee is not effective.
904.3.5.14 The Provider shall work jointly with QAD to initiate appropriate disciplinary action on the HERS Rater/RFI in accordance with the Provider’s written HERS Rater/RFI disciplinary procedures .
904.3.5.2 A Provider shall enforce disciplinary action against Raters or RFIs when non-compliance is found, and corrective action is ineffective .
904.3.5.32 If a Rater or RFI refuses disciplinary action, Rating Quality Assurance Providers are required to report any non-compliance to RESNET Registry , as defined in 904.4.1.3.5.
Comment #18Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 13Paragraph / Figure / Table / Note: 904.4.1.3Comment Intent: Not an ObjectionComment Type: EditorialComment: If a Rater chooses to switch Providers while under a disciplinary status, the disciplinary status should not be changed until documentation of satisfactory resolution has been submitted and reviewed by the Provider/QAD that requested the corrective action or RESNET. Proposed Change: 904.4.1.3 Ensuring any status change and/or disciplinary action of a Rater or RFI is accurate and current in the RESNET Registry, including, but not limited to: 904.4.1.3.1 When a Rater or RFI establishes a new relationship with the Providership; 904.4.1.3.2 Changing the Rater or RFI to “active” when the Rater or RFI completes their probationary activities; 904.4.1.3.3 Changing the Rater or RFI to “inactive” when the Rater or RFI is no longer conducting ratings; 904.4.1.3.4 If a Rater or RFI is in any step of the disciplinary action process or has satisfied the requirements to be removed from the disciplinary action process; 904.4.1.3.5 If a Quality Assurance Designee reports that a Rater or RFI refused corrective action, the Provider shall place the Rater or RFI under disciplinary probation and update the Rater or RFI’s profile in the RESNET Registry to reflect the status change . Probation status shall not be changed until documentation of satisfactory resolution has been submitted and reviewed by the Provider or QAD that requested corrective action or RESNET itself, should the Rater or RFI change Providers while under probation;
If a Rater chooses to switch Providers while under a disciplinary status, the disciplinary status should not be changed until documentation of satisfactory resolution has been submitted and reviewed by the Provider/QAD that requested the corrective action or RESNET.
904.4.1.3 Ensuring any status change and/or disciplinary action of a Rater or RFI is accurate and current in the RESNET Registry, including, but not limited to: 904.4.1.3.1 When a Rater or RFI establishes a new relationship with the Providership;
904.4.1.3.2 Changing the Rater or RFI to “active” when the Rater or RFI completes their probationary activities;
904.4.1.3.3 Changing the Rater or RFI to “inactive” when the Rater or RFI is no longer conducting ratings;
904.4.1.3.4 If a Rater or RFI is in any step of the disciplinary action process or has satisfied the requirements to be removed from the disciplinary action process;
904.4.1.3.5 If a Quality Assurance Designee reports that a Rater or RFI refused corrective action, the Provider shall place the Rater or RFI under disciplinary probation and update the Rater or RFI’s profile in the RESNET Registry to reflect the status change . Probation status shall not be changed until documentation of satisfactory resolution has been submitted and reviewed by the Provider or QAD that requested corrective action or RESNET itself, should the Rater or RFI change Providers while under probation;
Comment #19Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 13Paragraph / Figure / Table / Note: 904.4.1.4Comment Intent: Not an ObjectionComment Type: EditorialComment: The timeframe for changing the registry to reflect a change in status should be shortened to expedite resolution of issues. Proposed Change: 904.4.1.4 QA Providers shall update the registry within twenty (20)five (5) business days of a change in fact for any status changes and/or disciplinary action.
The timeframe for changing the registry to reflect a change in status should be shortened to expedite resolution of issues.
904.4.1.4 QA Providers shall update the registry within twenty (20)five (5) business days of a change in fact for any status changes and/or disciplinary action.
Comment #20Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 14Paragraph / Figure / Table / Note: 904.4.2.4.4Comment Intent: Not an ObjectionComment Type: EditorialComment: The current standard for maintaining documentation is 3 years. If the requirement for maintaing records is going to be extended, it should be clarified that such change will be made effective as of the date this standard is adopted, so as not to penalize Providers. Proposed Change: 904.4.2.4.4 The QA Record for each home shall be maintained for a minimum of seven (7) years as of the effective date of this standard .
The current standard for maintaining documentation is 3 years. If the requirement for maintaing records is going to be extended, it should be clarified that such change will be made effective as of the date this standard is adopted, so as not to penalize Providers.
904.4.2.4.4 The QA Record for each home shall be maintained for a minimum of seven (7) years as of the effective date of this standard .
Comment #21Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 17Paragraph / Figure / Table / Note: 904.8Comment Intent: Not an ObjectionComment Type: EditorialComment: The language for Suspension as a result of having been on Disciplinary Probation should be clarified to state that suspension will occur if the Provider has been on disciplinary probation for the same violation within a three-year period. It is possible for different issues to arise over the period of three years that could result in the need for probationary status. Proposed Change: 904.8 Suspension Of A Rating Quality Assurance Provider 904.8.1 Any accredited Rating Quality Assurance Provider may have their accreditation suspended. These violations may include, but are not limited to: 904.8.1.1 A Provider has had more than one (1) Disciplinary Probation for the same violation within a three-year period ; 904.8.1.2 Failure to correct the terms of a Disciplinary Probation during the time period defined in the notice of probation; 904.8.1.3 Submission of false information to RESNET in accordance with obtaining or maintaining accreditation or certification; 904.8.1.4 Misrepresentation of any accreditation status in marketing materials, or services offered or provided, for which the Rating Quality Assurance Provider organization does not possess the appropriate RESNET accreditation or affiliated individuals do not possess the appropriate RESNET certification; 904.8.1.5 Knowingly registering fraudulent ratings to the RESNET Registry; 904.8.1.6 Willful Misconduct by Rating Quality Assurance Provider, defined as an intentional disregard of any provision of the RESNET Standards, which a Party knew or should have known if it was acting as a reasonable person, but shall not include any error of judgment or mistake made in good faith. 904.8.1.7 Violation of RESNET’s Whistle Blower Protection Policy as specified in section 911. 904.8.2 Prior to reinstatement, the Rating Quality Assurance Provider shall successfully resolve the issue(s) that resulted in the Rating Quality Assurance Provider being suspended and inform RESNET in writing as follows: 904.8.2.1 That the issue(s) has (have) been successfully resolved; 904.8.2.2 State the steps taken to resolve the issue(s); 904.8.2.3 State the steps that will be taken to prevent the issue(s) from occurring again in the future.
The language for Suspension as a result of having been on Disciplinary Probation should be clarified to state that suspension will occur if the Provider has been on disciplinary probation for the same violation within a three-year period. It is possible for different issues to arise over the period of three years that could result in the need for probationary status.
904.8 Suspension Of A Rating Quality Assurance Provider
904.8.1 Any accredited Rating Quality Assurance Provider may have their accreditation suspended. These violations may include, but are not limited to:
904.8.1.1 A Provider has had more than one (1) Disciplinary Probation for the same violation within a three-year period ;
904.8.1.2 Failure to correct the terms of a Disciplinary Probation during the time period defined in the notice of probation;
904.8.1.3 Submission of false information to RESNET in accordance with obtaining or maintaining accreditation or certification;
904.8.1.4 Misrepresentation of any accreditation status in marketing materials, or services offered or provided, for which the Rating Quality Assurance Provider organization does not possess the appropriate RESNET accreditation or affiliated individuals do not possess the appropriate RESNET certification;
904.8.1.5 Knowingly registering fraudulent ratings to the RESNET Registry;
904.8.1.6 Willful Misconduct by Rating Quality Assurance Provider, defined as an intentional disregard of any provision of the RESNET Standards, which a Party knew or should have known if it was acting as a reasonable person, but shall not include any error of judgment or mistake made in good faith.
904.8.1.7 Violation of RESNET’s Whistle Blower Protection Policy as specified in section 911.
904.8.2 Prior to reinstatement, the Rating Quality Assurance Provider shall successfully resolve the issue(s) that resulted in the Rating Quality Assurance Provider being suspended and inform RESNET in writing as follows:
904.8.2.1 That the issue(s) has (have) been successfully resolved; 904.8.2.2 State the steps taken to resolve the issue(s); 904.8.2.3 State the steps that will be taken to prevent the issue(s) from occurring again in the future.
Comment #22Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 17Paragraph / Figure / Table / Note: 904.9Comment Intent: Not an ObjectionComment Type: EditorialComment: As with Suspension, revocation based on previous disciplinary action should be based on the same violation. Proposed Change: 904.9 Revocation Of Rating Quality Assurance Provider Any accredited Rating Quality Assurance Provider may have their accreditation revoked in any of the following circumstances: 904.9.1 A Rating Quality Assurance Provider has had more than one (1) suspension for the same violation within a five-year period ; 904.9.2 In the event that deficiencies stipulated in a notice of suspension have not been remedied within the period set forth in such notice; 904.9.3 Accredited Rating Quality Assurance Providers that elect not to renew or fail to meet renewal requirements; 904.9.4 Rating Quality Assurance Provider goes out of business; 904.9.5 Fraudulent Activity involving RESNET, including but not limited to: 904.9.5.1 Falsifying inspections; 904.9.5.2 Falsifying data, files reports, and any other documents; 904.9.5.3 Registering other program ratings, knowing that inspections were not completed as required by the program. For example: program required inspection(s) and/or checklist(s) were not completed, but the address was registered as ENERGY STAR qualified"; 904.9.5.4 Knowingly allowing “non-certified” persons to perform inspections, testing, quality assurance, or ratings; 904.9.5.5 Knowingly allowing Raters or RFI’s to perform inspections, testing and/or ratings while on any RESNET disciplinary actions barring them from doing so; 904.9.5.6 Colluding with any Provider(s), such as other QA providers, software providers, etc. to by-pass RESNET requirements; 904.9.5.7 Colluding with other QA Provider(s) to fix pricing; 904.9.6 Non-payment per RESNET’s Fee Payment Policy for QA Providers; 904.9.7 Severe violation of the Code of Ethics ; 904.9.8 Upon the expiration of the notice to appeal period, failure to submit appeal documentation as stipulated in these standards, or the conclusion of the appeals process in which a Rating Quality Assurance Provider appeals are unsuccessful.
As with Suspension, revocation based on previous disciplinary action should be based on the same violation.
904.9 Revocation Of Rating Quality Assurance Provider Any accredited Rating Quality Assurance Provider may have their accreditation revoked in any of the following circumstances:
904.9.1 A Rating Quality Assurance Provider has had more than one (1) suspension for the same violation within a five-year period ;
904.9.2 In the event that deficiencies stipulated in a notice of suspension have not been remedied within the period set forth in such notice; 904.9.3 Accredited Rating Quality Assurance Providers that elect not to renew or fail to meet renewal requirements; 904.9.4 Rating Quality Assurance Provider goes out of business; 904.9.5 Fraudulent Activity involving RESNET, including but not limited to: 904.9.5.1 Falsifying inspections; 904.9.5.2 Falsifying data, files reports, and any other documents; 904.9.5.3 Registering other program ratings, knowing that inspections were not completed as required by the program. For example: program required inspection(s) and/or checklist(s) were not completed, but the address was registered as ENERGY STAR qualified"; 904.9.5.4 Knowingly allowing “non-certified” persons to perform inspections, testing, quality assurance, or ratings; 904.9.5.5 Knowingly allowing Raters or RFI’s to perform inspections, testing and/or ratings while on any RESNET disciplinary actions barring them from doing so; 904.9.5.6 Colluding with any Provider(s), such as other QA providers, software providers, etc. to by-pass RESNET requirements; 904.9.5.7 Colluding with other QA Provider(s) to fix pricing; 904.9.6 Non-payment per RESNET’s Fee Payment Policy for QA Providers; 904.9.7 Severe violation of the Code of Ethics ; 904.9.8 Upon the expiration of the notice to appeal period, failure to submit appeal documentation as stipulated in these standards, or the conclusion of the appeals process in which a Rating Quality Assurance Provider appeals are unsuccessful.
Comment #23Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 19Paragraph / Figure / Table / Note: 905.2.2Comment Intent: Not an ObjectionComment Type: EditorialComment: It is not clear in the language provided if the RESNET Roundtable is part of, or in addition to the in-person or remove QAD update and training sessions. An option for attending the RESNET Roundtable remotely should be provided to prevent undue burden on the QAD. Proposed Change: 905.2.3 Professional Development For Quality Assurance Designees 905.2.1905.2.3.1 All Quality Assurance Designees annually shall: 905.2.1.1 905.2.3.1.1 Document attendance at the RESNET Conference or 12 hours of RESNET approved CEUs; and 905.2.1.2 Attend a RESNET Roundtable in person at the RESNET Conference or remotely; and 905.2.1.3 905.2.3.1.2 Attend (either in-person or by reviewing the recording) all RESNET in-person or remote QAD update and training sessions. Participate in a one-day in-person (or virtual) RESNET update and training.
It is not clear in the language provided if the RESNET Roundtable is part of, or in addition to the in-person or remove QAD update and training sessions. An option for attending the RESNET Roundtable remotely should be provided to prevent undue burden on the QAD.
905.2.3 Professional Development For Quality Assurance Designees 905.2.1905.2.3.1 All Quality Assurance Designees annually shall:
905.2.1.1 905.2.3.1.1 Document attendance at the RESNET Conference or 12 hours of RESNET approved CEUs; and
905.2.1.2 Attend a RESNET Roundtable in person at the RESNET Conference or remotely; and
905.2.1.3 905.2.3.1.2 Attend (either in-person or by reviewing the recording) all RESNET in-person or remote QAD update and training sessions. Participate in a one-day in-person (or virtual) RESNET update and training.
Comment #24Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 19Paragraph / Figure / Table / Note: 905.2.2 and 905.3Comment Intent: Not an ObjectionComment Type: EditorialComment: The suggested edits below are for formatting and clarity in the section. Proposed Change: 905.2.3.2 A Quality Assurance Designee must renew annually with RESNET to maintain certification. 905.2.2.1 A QAD that does not complete the renewal for a given calendar year must have QAD annual Professional Development requirements verified with RESNET in accordance with these standards prior to reinstatement. 905.2.2.2 If two years have lapsed without a QAD completing the renewal requirements, the QAD must retake and pass the RESNET Quality Assurance Designee Test and complete a new application prior to reinstatement. 905.3 Quality Assurance Designee Relationship To Qa QA Provider 905.3.1 All Quality Assurance Designees shall have a signed agreement with the QA Provider to be the QA Provider’s Quality Assurance Designee. 905.3.2 The Primary Quality Assurance Designee shall have an agreement that clearly indicates that they are accepting the role and responsibilities as Primary Quality Assurance Designee.
The suggested edits below are for formatting and clarity in the section.
905.2.3.2 A Quality Assurance Designee must renew annually with RESNET to maintain certification.
905.2.2.1 A QAD that does not complete the renewal for a given calendar year must have QAD annual Professional Development requirements verified with RESNET in accordance with these standards prior to reinstatement.
905.2.2.2 If two years have lapsed without a QAD completing the renewal requirements, the QAD must retake and pass the RESNET Quality Assurance Designee Test and complete a new application prior to reinstatement.
905.3 Quality Assurance Designee Relationship To Qa QA Provider
905.3.1 All Quality Assurance Designees shall have a signed agreement with the QA Provider to be the QA Provider’s Quality Assurance Designee.
905.3.2 The Primary Quality Assurance Designee shall have an agreement that clearly indicates that they are accepting the role and responsibilities as Primary Quality Assurance Designee.
Comment #25Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 21Paragraph / Figure / Table / Note: 905.6.2Comment Intent: Not an ObjectionComment Type: EditorialComment: Refusal of corrective action should result in an immediate disciplinary status change on the registry for the recipient. Proposed Change: 905.6.2 If the recipient refuses to take corrective action, the requested action may be taken by the requestor to ensure rating files are accurate and the recipient shall be placed on disciplinary probation on the RESNET Registry.
Refusal of corrective action should result in an immediate disciplinary status change on the registry for the recipient.
905.6.2 If the recipient refuses to take corrective action, the requested action may be taken by the requestor to ensure rating files are accurate and the recipient shall be placed on disciplinary probation on the RESNET Registry.
Comment #26Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 21-22Paragraph / Figure / Table / Note: 905.6.4-905.6.6Comment Intent: Not an ObjectionComment Type: EditorialComment: The language in this section should be clarified to define what teh 5% non-compliance is based on. In addition, while we agree that additional review should be required for non-compliance, assigning a higher percentage of review for non-compliance on a general basis will result in inequity between high and low volume Raters and undue burden on the Provider. We suggest instead requiring a specific number of reviews be adopted instead of the percentages noted. The thresholds noted in later parts of this section are confusing and redundant. Proposed Change: 905.6.4 When in the course of quality assurance file or field review, in a twelve (12) month period from January 1st through December 31st, ratings are found to be out of compliance by more than 5% based on the Index and/or three or more significant errors or omissions are found, or the Quality Assurance Designee determines that field work (e.g. testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 905.6.4.1 The Rater shall be placed on probation; 905.5.4.2 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 ;next five ratings submitted shall receive QA File review. 905.6.4.3 WhenWhere appropriatepossible (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 Assurance Designee on the rating(s) that were out of compliance by more than 5 % based on the Index or contained more than three significant errors or omissions. Where QA Field review of the specific dwelling is not possible, the next available unit shall receive a QA Field review; 905.6.4.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI’s Field QA shall be increased to 2% or 2 ratings whichever is larger for the next twelve (12) consecutive months. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 2% = 1 means that 2 QA Field reviews shall be completed by 1 rating for low-volume Raters/RFIs or 2 ratings for high-volume Raters/RFIs. 905.6.5 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 ”; 905.6.6 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, whichever is greater”;
The language in this section should be clarified to define what teh 5% non-compliance is based on. In addition, while we agree that additional review should be required for non-compliance, assigning a higher percentage of review for non-compliance on a general basis will result in inequity between high and low volume Raters and undue burden on the Provider. We suggest instead requiring a specific number of reviews be adopted instead of the percentages noted.
The thresholds noted in later parts of this section are confusing and redundant.
905.6.4 When in the course of quality assurance file or field review, in a twelve (12) month period from January 1st through December 31st, ratings are found to be out of compliance by more than 5% based on the Index and/or three or more significant errors or omissions are found, or the Quality Assurance Designee determines that field work (e.g. testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur:
905.6.4.1 The Rater shall be placed on probation;
905.5.4.2 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 ;next five ratings submitted shall receive QA File review.
905.6.4.3 WhenWhere appropriatepossible (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 Assurance Designee on the rating(s) that were out of compliance by more than 5 % based on the Index or contained more than three significant errors or omissions. Where QA Field review of the specific dwelling is not possible, the next available unit shall receive a QA Field review;
905.6.4.4 If the noncompliant ratings are due to inaccurate or incomplete field work, the Rater and/or RFI’s Field QA shall be increased to 2% or 2 ratings whichever is larger for the next twelve (12) consecutive months. Round up to the next whole number when the percentage calculation yields a decimal point, e.g. 50 ratings x 2% = 1 means that 2 QA Field reviews shall be completed by 1 rating for low-volume Raters/RFIs or 2 ratings for high-volume Raters/RFIs.
905.6.5 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 ”;
905.6.6 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, whichever is greater”;
Comment #27Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 23Paragraph / Figure / Table / Note: 905.6.10.3Comment Intent: Not an ObjectionComment Type: EditorialComment: If a Rater or RFI refuses corrective action, their disciplinary status on the Registry should be changed immediately. Proposed Change: 905.6.10.3 If a Rater or RFI refuses corrective action, Quality Assurance Designees are required to report any non-compliance to the Provider and report it to the RESNET Registry and the Rater/RFI’s status shall be changed to disciplinary probation.
If a Rater or RFI refuses corrective action, their disciplinary status on the Registry should be changed immediately.
905.6.10.3 If a Rater or RFI refuses corrective action, Quality Assurance Designees are required to report any non-compliance to the Provider and report it to the RESNET Registry and the Rater/RFI’s status shall be changed to disciplinary probation.
Comment #28Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 23Paragraph / Figure / Table / Note: 905.7.1Comment Intent: Not an ObjectionComment Type: EditorialComment: The language in this section is vague. Where possible, wording such as "multiple requirements" should be clarified to ensure consistency among Providers, QADs, and RESNET. Proposed Change: 905.7.1 Significant non-compliance by Quality Assurance Designees shall include, but not be limited to, the following : 905.7.1.1 Failure to comply with multiple two or more individual requirements for QADs as defined in Section 905.4, or requirements impacting multiple Raters, RFIs, and/or ratings, as set forth in the RESNET Standards and enumerated in a RESNET Quality Assurance Checklist ; 905.7.1.2 Failure of a Quality Assurance Designee to comply with the RESNET Standards of Practice, Code of Ethics, or Conflict of Interest Disclosure; 905.7.1.3 Failure to follow a Provider’s written Rater and RFI disciplinary procedures, as defined by RESNET, for known or obvious non-compliance with the RESNET Standards, Standards of Practice, Code of Ethics, or Conflict of Interest Disclosure; 905.7.1.4 Failure to report significant non-compliance to RESNET.
The language in this section is vague. Where possible, wording such as "multiple requirements" should be clarified to ensure consistency among Providers, QADs, and RESNET.
905.7.1 Significant non-compliance by Quality Assurance Designees shall include, but not be limited to, the following : 905.7.1.1 Failure to comply with multiple two or more individual requirements for QADs as defined in Section 905.4, or requirements impacting multiple Raters, RFIs, and/or ratings, as set forth in the RESNET Standards and enumerated in a RESNET Quality Assurance Checklist ;
905.7.1.2 Failure of a Quality Assurance Designee to comply with the RESNET Standards of Practice, Code of Ethics, or Conflict of Interest Disclosure;
905.7.1.3 Failure to follow a Provider’s written Rater and RFI disciplinary procedures, as defined by RESNET, for known or obvious non-compliance with the RESNET Standards, Standards of Practice, Code of Ethics, or Conflict of Interest Disclosure;
905.7.1.4 Failure to report significant non-compliance to RESNET.
Comment #29Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 24Paragraph / Figure / Table / Note: 905.8.2Comment Intent: Not an ObjectionComment Type: EditorialComment: Any deliberate failure or non-compliance should result in immediate suspension or revocation, not probation. Proposed Change: 905.8.2 Disciplinary Compliance Probation. More serious compliance violations found through a Quality Assurance Designee’s QA process, RESNET quality assurance monitoring or through the RESNET complaint resolution process. These violations may include but are not limited to: 905.8.2.1 Failure to correct the terms of a confidential administrative probation during the time period defined in the issuance of probation; 905.8.2.2 Deliberate failure to report non-compliance of QA Providers, Raters, and/or RFIs to RESNET ; 905.8.2.3 Ethics or compliance complaint(s) investigated and validated by RESNET against a Quality Assurance Designee; 905.8.2.4 Failure to follow complaint resolution process and/or disciplinary procedures; 905.8.2.5 Failure to correct the terms of a confidential administrative probation during the time period defined in the issuance of probation;(redundant) 905.8.2.5 Deliberate failure to follow a Provider’s Rater and RFI Disciplinary procedures . 905.8.2.6 Deliberate failure to apply the appropriate RESNET Standards while performing QAD responsibilities;
Any deliberate failure or non-compliance should result in immediate suspension or revocation, not probation.
905.8.2 Disciplinary Compliance Probation. More serious compliance violations found through a Quality Assurance Designee’s QA process, RESNET quality assurance monitoring or through the RESNET complaint resolution process. These violations may include but are not limited to:
905.8.2.1 Failure to correct the terms of a confidential administrative probation during the time period defined in the issuance of probation;
905.8.2.2 Deliberate failure to report non-compliance of QA Providers, Raters, and/or RFIs to RESNET ;
905.8.2.3 Ethics or compliance complaint(s) investigated and validated by RESNET against a Quality Assurance Designee;
905.8.2.4 Failure to follow complaint resolution process and/or disciplinary procedures;
905.8.2.5 Failure to correct the terms of a confidential administrative probation during the time period defined in the issuance of probation;(redundant)
905.8.2.5 Deliberate failure to follow a Provider’s Rater and RFI Disciplinary procedures .
905.8.2.6 Deliberate failure to apply the appropriate RESNET Standards while performing QAD responsibilities;
Comment #30Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 24-25Paragraph / Figure / Table / Note: 904.9Comment Intent: Not an ObjectionComment Type: EditorialComment: Deliberate failures noted in the disciplinary probation section should be moved to suspension. In addition, as with Providers, enhanced disciplinary action against a QAD should be the result of the same violation. Proposed Change: 905.9 Suspension Of Quality Assurance Designees 905.9.1 Any certified Quality Assurance Designee may have their certification suspended. These violations may include, but are not limited to: 905.9.1.1 Quality Assurance Designee has had more than one (1) Disciplinary Probation for the same violation within a three-year period; 905.9.1.2 Deliberate failure to report significant non-compliance of QA Providers, QADs, Raters, and/or RFIs to RESNET; 905.8.2.5 905.9.1.3 Deliberate failure to follow a Provider’s Rater and RFI Disciplinary procedures . 905.8.2.6 905.9.1.4 Deliberate failure to apply the appropriate RESNET Standards while performing QAD responsibilities; 905.9.1.34 Failure to correct the terms of a Disciplinary Probation during the time period defined in the notice of probation; 905.9.1.45 Failure to adhere to requirements for quality assurance of Raters and/or RFIs that causes a major deficiency in the QA of one or more Raters and/or RFIs, such as falsifying records, or misrepresentation of qualifications for RESNET approved programs; 905.9.1.5 6Submission of false information to RESNET in accordance with obtaining or maintaining certification of QADs, Raters, or RFIs and/or accreditation of QA Providers; 905.9.1.67 Misrepresentation of any certification status in marketing materials, or services offered or provided, for which the QAD does not possess the appropriate RESNET accreditation or certification ; 905.9.1.7 8 Knowingly registering fraudulent ratings to the RESNET Registry; 905.9.1.89 Willful misconduct by QAD, defined as an intentional disregard of any provision of the RESNET Standards, which a Party knew or should have known if it was acting as a reasonable person, but shall not include any error of judgment or mistake made in good faith. 904.9.1.910 Violation of RESNET’s Whistle Blower Protection Policy as specified in section 911. 905.9.2 A Quality Assurance Designee shall at a minimum be placed on suspension if they have any Disciplinary Probation violations within twelve months of reinstatement from a suspension. 905.9.3 Prior to reinstatement, the Quality Assurance Designee shall successfully resolve the issue(s) that resulted in the Quality Assurance Designee being suspended and inform RESNET in writing as follows: 905.9.3.1 That the issue(s) has(have) been successfully resolved; 905.9.3.2 State the steps taken to resolve the issue(s); 905.9.3.3 State the steps that will be taken to prevent the issue(s) from occurring again in the future.
Deliberate failures noted in the disciplinary probation section should be moved to suspension. In addition, as with Providers, enhanced disciplinary action against a QAD should be the result of the same violation.
905.9 Suspension Of Quality Assurance Designees
905.9.1 Any certified Quality Assurance Designee may have their certification suspended. These violations may include, but are not limited to: 905.9.1.1 Quality Assurance Designee has had more than one (1) Disciplinary Probation for the same violation within a three-year period;
905.9.1.2 Deliberate failure to report significant non-compliance of QA Providers, QADs, Raters, and/or RFIs to RESNET; 905.8.2.5 905.9.1.3 Deliberate failure to follow a Provider’s Rater and RFI Disciplinary procedures . 905.8.2.6 905.9.1.4 Deliberate failure to apply the appropriate RESNET Standards while performing QAD responsibilities;
905.9.1.34 Failure to correct the terms of a Disciplinary Probation during the time period defined in the notice of probation; 905.9.1.45 Failure to adhere to requirements for quality assurance of Raters and/or RFIs that causes a major deficiency in the QA of one or more Raters and/or RFIs, such as falsifying records, or misrepresentation of qualifications for RESNET approved programs; 905.9.1.5 6Submission of false information to RESNET in accordance with obtaining or maintaining certification of QADs, Raters, or RFIs and/or accreditation of QA Providers; 905.9.1.67 Misrepresentation of any certification status in marketing materials, or services offered or provided, for which the QAD does not possess the appropriate RESNET accreditation or certification ; 905.9.1.7 8 Knowingly registering fraudulent ratings to the RESNET Registry;
905.9.1.89 Willful misconduct by QAD, defined as an intentional disregard of any provision of the RESNET Standards, which a Party knew or should have known if it was acting as a reasonable person, but shall not include any error of judgment or mistake made in good faith.
904.9.1.910 Violation of RESNET’s Whistle Blower Protection Policy as specified in section 911.
905.9.2 A Quality Assurance Designee shall at a minimum be placed on suspension if they have any Disciplinary Probation violations within twelve months of reinstatement from a suspension. 905.9.3 Prior to reinstatement, the Quality Assurance Designee shall successfully resolve the issue(s) that resulted in the Quality Assurance Designee being suspended and inform RESNET in writing as follows: 905.9.3.1 That the issue(s) has(have) been successfully resolved; 905.9.3.2 State the steps taken to resolve the issue(s); 905.9.3.3 State the steps that will be taken to prevent the issue(s) from occurring again in the future.
Comment #31Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 25-26Paragraph / Figure / Table / Note: 905.10Comment Intent: Not an ObjectionComment Type: EditorialComment: QAD going out of business should be removed from the list of reasons for revocation of status. A person could transition from being an independent Provider/QAD to working as a QAD for a different company. They could also transition from one business of their own to another. Neither of these conditions is relevant to their status as a QAD as long as they are maintaining their credentials as required. Proposed Change: 905.10 Revocation Of Quality Assurance Designees 905.10.1 Any Quality Assurance Designee certified by RESNET may have their certification revoked in any of the following circumstances: 905.10.1.1 A Quality Assurance Designee has had more than one (1) Disciplinary ProbationSuspension for the same violation within a five-year period ; 905.10.1.2 In the event that deficiencies stipulated in a notice of suspension have not been remedied within the period set forth in such notice; 905.10.1.3 Quality Assurance Designee that elects not to renew or fails to meet renewal requirements; 905.10.1.4 Quality Assurance Designee goes out of business ; 905.10.1.5 Upon expiration of a QA Designee’s right to appeal a suspension of certification pursuant to Section 912 of this chapter or the conclusion of the appeals process in which a Quality Assurance Designee’s appeals are unsuccessful; 905.10.1.6 Fraudulent Activity, including but not limited to: 905.10.1.6.1 Falsifying inspections, data, files, reports and other documents or information; 905.10.1.6.2 Registering ratings for EEPs or other programs knowing that inspections were not completed as required by the program (example – checklist inspection not completed, but registering the home as ENERGY STAR qualified); 905.10.1.6.3 Deliberately allowing non-certified persons to perform inspections, testing and ratings; 905.10.1.6.4 Deliberately allowing suspended or revoked Raters or RFIs to perform inspections, testing and/or ratings; 905.10.1.6.5 Colluding with Provider(s) or other QAD(s) to by-pass RESNET requirements; 905.10.1.6.6 Colluding with QA Provider(s) or other QAD(s) to price fix 905.10.1.6.7 Severe violation of the Code of Ethics;
QAD going out of business should be removed from the list of reasons for revocation of status. A person could transition from being an independent Provider/QAD to working as a QAD for a different company. They could also transition from one business of their own to another. Neither of these conditions is relevant to their status as a QAD as long as they are maintaining their credentials as required.
905.10 Revocation Of Quality Assurance Designees 905.10.1 Any Quality Assurance Designee certified by RESNET may have their certification revoked in any of the following circumstances:
905.10.1.1 A Quality Assurance Designee has had more than one (1) Disciplinary ProbationSuspension for the same violation within a five-year period ;
905.10.1.2 In the event that deficiencies stipulated in a notice of suspension have not been remedied within the period set forth in such notice;
905.10.1.3 Quality Assurance Designee that elects not to renew or fails to meet renewal requirements;
905.10.1.4 Quality Assurance Designee goes out of business ;
905.10.1.5 Upon expiration of a QA Designee’s right to appeal a suspension of certification pursuant to Section 912 of this chapter or the conclusion of the appeals process in which a Quality Assurance Designee’s appeals are unsuccessful;
905.10.1.6 Fraudulent Activity, including but not limited to:
905.10.1.6.1 Falsifying inspections, data, files, reports and other documents or information;
905.10.1.6.2 Registering ratings for EEPs or other programs knowing that inspections were not completed as required by the program (example – checklist inspection not completed, but registering the home as ENERGY STAR qualified);
905.10.1.6.3 Deliberately allowing non-certified persons to perform inspections, testing and ratings;
905.10.1.6.4 Deliberately allowing suspended or revoked Raters or RFIs to perform inspections, testing and/or ratings;
905.10.1.6.5 Colluding with Provider(s) or other QAD(s) to by-pass RESNET requirements;
905.10.1.6.6 Colluding with QA Provider(s) or other QAD(s) to price fix 905.10.1.6.7 Severe violation of the Code of Ethics;
Comment #32Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: 34-35Paragraph / Figure / Table / Note: 910.1Comment Intent: Not an ObjectionComment Type: EditorialComment: As noted in sections above, the timeframe for corrective action should be shortened both to expedite the resolution of issues and for consistency. Similarly, the notice of disciplinary action should always include the status, regardless of the severity of the indicent. Proposed Change: 910.1 Notification. If RESNET determines at any time that an accredited Provider failed to adhere to the requirements set forth in these Standards, RESNET shall provide written notification to the Providers of any decisions under this section. All notices shall be sent by certified e-mail, or other method which provides evidence of delivery. All notices shall include : 910.1.1 Entire basis and justification for the disciplinary action; 910.1.2 clarify Clarification of the procedures being followed, as stipulated in this Standard, and; 910.1.3 Iinclude, where applicable, a statement of the Provider’s rights to appeal under Section 9121 of this Chapter;. 910.1.4 Specific corrective action required to be taken no later than twenty (20)five (5) business days after the date set forth in such notification, unless otherwise specified ; 910.1.5 Notice of disciplinary action may or may notshall include disciplinary status, depending on the severity of the incident .
As noted in sections above, the timeframe for corrective action should be shortened both to expedite the resolution of issues and for consistency. Similarly, the notice of disciplinary action should always include the status, regardless of the severity of the indicent.
910.1 Notification. If RESNET determines at any time that an accredited Provider failed to adhere to the requirements set forth in these Standards, RESNET shall provide written notification to the Providers of any decisions under this section. All notices shall be sent by certified e-mail, or other method which provides evidence of delivery. All notices shall include
: 910.1.1 Entire basis and justification for the disciplinary action;
910.1.2 clarify Clarification of the procedures being followed, as stipulated in this Standard, and;
910.1.3 Iinclude, where applicable, a statement of the Provider’s rights to appeal under Section 9121 of this Chapter;.
910.1.4 Specific corrective action required to be taken no later than twenty (20)five (5) business days after the date set forth in such notification, unless otherwise specified ;
910.1.5 Notice of disciplinary action may or may notshall include disciplinary status, depending on the severity of the incident .
Comment #33Amendment: Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01Page Number: AllComment Intent: ObjectionComment Type: GeneralComment: As a HERS rater, this extension feels unneccesary as builders have continued their building practices including air tightness testing which has led to improved home savings that our clients desire. Allowing raters to continue to put in default values sets a bad precedent for future HERS ratings and lessens the need for builders to want this service. As an essential industry, we have been able to continue proper testing and change our social distancing practices to allow for this testing to continue in a safe manner. It is my opinion that RESNET should be wanting to promote this science and not fall off of it for convenience as it will be used just to not have to put the work in. We should instead focus our efforts on how to test safely during a pandemic instead of going down a path that could make the HERS rating less important for builders.
As a HERS rater, this extension feels unneccesary as builders have continued their building practices including air tightness testing which has led to improved home savings that our clients desire. Allowing raters to continue to put in default values sets a bad precedent for future HERS ratings and lessens the need for builders to want this service. As an essential industry, we have been able to continue proper testing and change our social distancing practices to allow for this testing to continue in a safe manner. It is my opinion that RESNET should be wanting to promote this science and not fall off of it for convenience as it will be used just to not have to put the work in. We should instead focus our efforts on how to test safely during a pandemic instead of going down a path that could make the HERS rating less important for builders.
Return to Proposed MINHERS Addendum 37, QAD Disciplinary Actions, Draft PDS-01