Comment #1Amendment: Proposed MINHERS Addendum 29Page Number: 3Paragraph / Figure / Table / Note: 905.2.2.1.3Comment Intent: ObjectionComment Type: EditorialComment: While I understand the intent of this paragraph, in reality anyone who has NOT YET worked as a QA Designee or Delegate and completed the requisite number of field and file reviews, I don't think would be able to now qualify. Example: I meet the qualifications for a new Quality Agent in paragraph 905.2.2.1.1 and 905.2.2.1.2 BUT if I now take and pass the QA competancy test, I won't be able to work under my current provider as a QAD to gain the required field experience on raters under my rating company due to the new financial separation restrictions. There needs to be some time for those of us who wish to pursue this option to get the required file and field QA experience under the old rules in my opinion. Or can the "supervision and mentorship of another Quality Agent" be someone from my current Direct Rating provider and my current QA Provider (both the same company)?
While I understand the intent of this paragraph, in reality anyone who has NOT YET worked as a QA Designee or Delegate and completed the requisite number of field and file reviews, I don't think would be able to now qualify.
Example:
I meet the qualifications for a new Quality Agent in paragraph 905.2.2.1.1 and 905.2.2.1.2 BUT if I now take and pass the QA competancy test, I won't be able to work under my current provider as a QAD to gain the required field experience on raters under my rating company due to the new financial separation restrictions.
There needs to be some time for those of us who wish to pursue this option to get the required file and field QA experience under the old rules in my opinion. Or can the "supervision and mentorship of another Quality Agent" be someone from my current Direct Rating provider and my current QA Provider (both the same company)?
Comment #2Amendment: Proposed MINHERS Addendum 29Page Number: B 1Paragraph / Figure / Table / Note: 103.1Comment Intent: ObjectionComment Type: GeneralComment: It seems that these changes will consolidate 'power' to the larger providers (many of them who just happen to sit on the board) and also add substantially to a rater's cost...so much so, I think it may put low volume raters out of business as I assume costs for QA work will go up with this.
It seems that these changes will consolidate 'power' to the larger providers (many of them who just happen to sit on the board) and also add substantially to a rater's cost...so much so, I think it may put low volume raters out of business as I assume costs for QA work will go up with this.
Comment #3Amendment: Proposed MINHERS Addendum 29Page Number: 1Comment Intent: Not an ObjectionComment Type: GeneralComment: I should start this by saying it might not be an outright objection to the proposed changed, but a large concern. I agree that QA is incredibally important and that the current process has flaws. However, even though we are in a fairly large city (350,000 in the city limits), we find that there are very few (currently 1) option that we have for QA without flying someone in. I would like the new policy to take advantage of current technology (Facetime, Skype, GoPros, go to meeting, etc), so that to fufill QA requirements. It is really expensive, as well as inefficicent (time wise, jet fuel, using disposables while traveling, etc) to fly a qualified individual to the city that you are working in to do QA. In the area of the country we are in, there just isn't a lot of stress on or job opportunities for those in the green building and energy efficiency fields. I do not think that compnaies should have to take on such as large extra cost (given that the per rating fee just had such a large increase), just because they're working in an area with less people in the same field. It seems like disincentivizing people to be the one rater (or one of the few) in an area where there are very few HERS ratings would, have a greater negative effect, as compared to the affect on those who operate in areas where the HERS is much more saturated into the market. In short, I would like to see RESNET embrace technology, to make it easier to get better QA, and given the differences across states, cities and counties, make it possible to get quality, consist QA remotely. Thank you!
I should start this by saying it might not be an outright objection to the proposed changed, but a large concern.
I agree that QA is incredibally important and that the current process has flaws. However, even though we are in a fairly large city (350,000 in the city limits), we find that there are very few (currently 1) option that we have for QA without flying someone in.
I would like the new policy to take advantage of current technology (Facetime, Skype, GoPros, go to meeting, etc), so that to fufill QA requirements. It is really expensive, as well as inefficicent (time wise, jet fuel, using disposables while traveling, etc) to fly a qualified individual to the city that you are working in to do QA. In the area of the country we are in, there just isn't a lot of stress on or job opportunities for those in the green building and energy efficiency fields. I do not think that compnaies should have to take on such as large extra cost (given that the per rating fee just had such a large increase), just because they're working in an area with less people in the same field.
It seems like disincentivizing people to be the one rater (or one of the few) in an area where there are very few HERS ratings would, have a greater negative effect, as compared to the affect on those who operate in areas where the HERS is much more saturated into the market.
In short, I would like to see RESNET embrace technology, to make it easier to get better QA, and given the differences across states, cities and counties, make it possible to get quality, consist QA remotely.
Thank you!
Comment #4Amendment: Proposed MINHERS Addendum 29Page Number: 2Paragraph / Figure / Table / Note: 103.1.2.1.1.3Comment Intent: Not an ObjectionComment Type: EditorialComment: I am concerned that as this is written it could limit employment opportunities for a Rater working under a Direct Provider to become a Quality Agent. This could especially be true in the transition period. I agree that it needs to be known and identified, but not seen as an immediate disqualification so I suggest adding wording for clarity to the extent of, "The existance of such work history will not constitue an immediate conflict of interest but might lead to a higher level of scrutiny by the QA Manager." Having a statement similar to the one propsed above will help manage expectations and avoid misinterpretations by all parties.
I am concerned that as this is written it could limit employment opportunities for a Rater working under a Direct Provider to become a Quality Agent. This could especially be true in the transition period.
I agree that it needs to be known and identified, but not seen as an immediate disqualification so I suggest adding wording for clarity to the extent of, "The existance of such work history will not constitue an immediate conflict of interest but might lead to a higher level of scrutiny by the QA Manager."
Having a statement similar to the one propsed above will help manage expectations and avoid misinterpretations by all parties.
Comment #5Amendment: Proposed MINHERS Addendum 29Page Number: B1Paragraph / Figure / Table / Note: 905.2.1Comment Intent: ObjectionComment Type: GeneralComment: I have concerns regarding the number of ratings (ratings & QA rated) required for the new QA Agent designation. It is not reasonable to think that someone that has done 25 ratings has the in-depth knowledge required to provide accurate, sensible QA services. And requiring that only 5 of those 25 do not have any significant QA issues?! That does not really seem to make sense. We ran into this a few years ago. We hired a QA person that really had no clue about what actually happens in the field. It's one thing to read a book, study, take a test and say you are an expert. It's quite another to truly understand. Anyone that has actually worked in the field will tell you that there are just so many variables in this industry that you can't possibly possess a good working knowledge with so few ratings. Incidentally, this guy did not even know how to use some of the equipment, either. And it was simply from lack of field experience. I believe that a qualified QA Agent must have completed at least 100 ratings to illustrate a true working knowledge of HERS/ES Maybe 50/50?) certification and have the opportunity to encounter a multitude of scenarios in the field. Thanks for the consideration. Proposed Change: 905.2.2.1.2 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes one hundred (100) five (5) one hundred (100) 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 ten (10) homes and QA File reviews on a minimum of twenty (20) homes as either a Quality Assurance Designee or delegate (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
I have concerns regarding the number of ratings (ratings & QA rated) required for the new QA Agent designation. It is not reasonable to think that someone that has done 25 ratings has the in-depth knowledge required to provide accurate, sensible QA services.
And requiring that only 5 of those 25 do not have any significant QA issues?! That does not really seem to make sense.
We ran into this a few years ago. We hired a QA person that really had no clue about what actually happens in the field. It's one thing to read a book, study, take a test and say you are an expert. It's quite another to truly understand. Anyone that has actually worked in the field will tell you that there are just so many variables in this industry that you can't possibly possess a good working knowledge with so few ratings.
Incidentally, this guy did not even know how to use some of the equipment, either. And it was simply from lack of field experience.
I believe that a qualified QA Agent must have completed at least 100 ratings to illustrate a true working knowledge of HERS/ES Maybe 50/50?) certification and have the opportunity to encounter a multitude of scenarios in the field.
Thanks for the consideration.
905.2.2.1.2 As a certified HERS Rater, complete confirmed ratings on a minimum of twenty-five (25) homes one hundred (100) five (5) one hundred (100) 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 ten (10) homes and QA File reviews on a minimum of twenty (20) homes as either a Quality Assurance Designee or delegate (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
Comment #6Amendment: Proposed MINHERS Addendum 29Page Number: B1Paragraph / Figure / Table / Note: 905.2.2.1.3Comment Intent: Not an ObjectionComment Type: EditorialComment: I believe the language under this one section actually has two separate intentions. The first is to complete a minimum of 10 Field QAs and 20 file QAs as a previously certified QAD. The second is to be mentored by a Quality Agent/QAD on 10 Field QAs and 20 file QAs. As such, I propose to break this language out into a third line so we can have clarity in the language. Proposed Change: 905.2.2.1.3 Complete QA Field reviews on a minimum of ten (10) homes and QA File reviews on a minimum of twenty (20) homes as either a Quality Assurance Designee or delegate (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent or 905.2.2.1.4 Complete QA Field reviews on a minimum of ten (10) homes and QA File reviews on a minimum of twenty (20) homes under the supervision and mentorship of a Quality Assurance Designee or delegate (as previously allowed by RESNET) or Quality Agent.
I believe the language under this one section actually has two separate intentions. The first is to complete a minimum of 10 Field QAs and 20 file QAs as a previously certified QAD. The second is to be mentored by a Quality Agent/QAD on 10 Field QAs and 20 file QAs. As such, I propose to break this language out into a third line so we can have clarity in the language.
905.2.2.1.3 Complete QA Field reviews on a minimum of ten (10) homes and QA File reviews on a minimum of twenty (20) homes as either a Quality Assurance Designee or delegate (as previously allowed by RESNET) or under the supervision and mentorship of another Quality Agent or
905.2.2.1.4 Complete QA Field reviews on a minimum of ten (10) homes and QA File reviews on a minimum of twenty (20) homes under the supervision and mentorship of a Quality Assurance Designee or delegate (as previously allowed by RESNET) or Quality Agent.
Comment #7Amendment: Proposed MINHERS Addendum 29Page Number: B1Paragraph / Figure / Table / Note: 905.2.2.1.2Comment Intent: Not an ObjectionComment Type: GeneralComment: In regards to this section, I think this is a reasonable "experience" option for a previously certified HERS Rater. In reality, to meet with this one experience option you'd have to do 499 HERS Ratings to get 5 field QAs (1% * 499= 4.9= 5 field QAs). Otherwise, you'd be getting field QA'd at a higher percentage (5 / 25 = 20%) and risking a higher number of mistakes to be seen by an independent QAD or Quality Agent. That's a significant number of ratings. I think it's entirely unreasonable to require 100 Confirmed Ratings and 100 Field QA reviews to get the Quality Agent certification. This drastically favors the Vertically Integrated Rating Providers, the companies that are doing their own quality assurance. You could literally have a QAD say they were on site for a hundred HERS Ratings, get them all uploaded, and badabing, it's all good. I think requiring an extremely high number would actually push people to break the rules as QADs/Quality Agents age out of their positions. Now, I will say in the same breath that I believe the job of a HERS Rater and the job of a Quality Agent/QAD are two different things. In that regards, I applaud the language in section 905.2.2.1.3 that gives an experience path for someone to be mentored by a previously certified QAD/Quality Agent. If you can't distinguish between these two jobs, we can't make sure we have properly trained people to do them. Proposed Change: No Change
In regards to this section, I think this is a reasonable "experience" option for a previously certified HERS Rater.
In reality, to meet with this one experience option you'd have to do 499 HERS Ratings to get 5 field QAs (1% * 499= 4.9= 5 field QAs). Otherwise, you'd be getting field QA'd at a higher percentage (5 / 25 = 20%) and risking a higher number of mistakes to be seen by an independent QAD or Quality Agent. That's a significant number of ratings.
I think it's entirely unreasonable to require 100 Confirmed Ratings and 100 Field QA reviews to get the Quality Agent certification. This drastically favors the Vertically Integrated Rating Providers, the companies that are doing their own quality assurance. You could literally have a QAD say they were on site for a hundred HERS Ratings, get them all uploaded, and badabing, it's all good. I think requiring an extremely high number would actually push people to break the rules as QADs/Quality Agents age out of their positions.
Now, I will say in the same breath that I believe the job of a HERS Rater and the job of a Quality Agent/QAD are two different things. In that regards, I applaud the language in section 905.2.2.1.3 that gives an experience path for someone to be mentored by a previously certified QAD/Quality Agent. If you can't distinguish between these two jobs, we can't make sure we have properly trained people to do them.
No Change
Comment #8Amendment: Proposed MINHERS Addendum 29Page Number: 1Comment Intent: ObjectionComment Type: GeneralComment: Section 103.1 - Object - strike all. The proposed new catagories of Quality Assurance Contractors and Quality Agents are fundamentally no different than the existing Third-party provider roles. The pilot effort attenpted by RESNET failed to come to fruition due to projected costs and logistical impossibilities. It also showed the inability of a single QA QAC to practically provide these services over miltiple markets, and the use of multiple QAC's over miltiple markets would only result in greater variences in the consistancy of the QA provided. The existing structure of RESNET QA as well as QAD's should come under greater direct control of supervision of RESNET. This can be accomplished by some of the following efforts: *Enhanced QAD training requirepments to be developed and implemented by RESNET QA staff. *Additional RESNET Field Staff to conduct greater random inspections of both plan review and field activities. *full implementation of QA Genie to improve QA oversight. In summary, the current QA imrpovements currently underway with RESNET should be allowed to be fully implemented to determing their effectiveness vs. changes that have shown not to be financially and administratively viable at this time.
Section 103.1 - Object - strike all. The proposed new catagories of Quality Assurance Contractors and Quality Agents are fundamentally no different than the existing Third-party provider roles. The pilot effort attenpted by RESNET failed to come to fruition due to projected costs and logistical impossibilities. It also showed the inability of a single QA QAC to practically provide these services over miltiple markets, and the use of multiple QAC's over miltiple markets would only result in greater variences in the consistancy of the QA provided.
The existing structure of RESNET QA as well as QAD's should come under greater direct control of supervision of RESNET. This can be accomplished by some of the following efforts:
*Enhanced QAD training requirepments to be developed and implemented by RESNET QA staff.
*Additional RESNET Field Staff to conduct greater random inspections of both plan review and field activities.
*full implementation of QA Genie to improve QA oversight.
In summary, the current QA imrpovements currently underway with RESNET should be allowed to be fully implemented to determing their effectiveness vs. changes that have shown not to be financially and administratively viable at this time.
Comment #9Amendment: Proposed MINHERS Addendum 29Page Number: 1Comment Intent: ObjectionComment Type: GeneralComment: Section 103 Comments: This is too complicated and not clearly explained. There is a simpler way to go about this. The primary objectives (which we agree with) of this addendum to Section 103 appears to be to reduce conflict of interest & increase transparency among Providers. If that’s it, why do two separate provider types need to be created to achieve this? This is an overly complicated strategy, adding more proper nouns & definitions to an already complicated standard. Keep it simple. It also sounds like a strategy to justify increased fees for providers who operate under both of the proposed two distinct provider types. This would then lead to an increase in cost of HERS Ratings. A simple solution would be to require that current Rating Providers and QA Agents (former QAD(D)s) who perform ratings must register with and meet QA requirements through another Rating Provider. In addition, those Rating Providers cannot exchange services, and the financial conflict of interest still applies, etc… Section 905 (Quality Agents) Comments: These qualification requirements make sense, with the exception of 905.2.2.3: What is the intent of this on-site training event? Why require an on-site training when video-conferencing & telepresence is so prevalent and cheap? Our concern is that this is unnecessary to ensure consistent training for QA Agents, which will increase the cost of entry to the industry. We understand the importance of training QA Agents, however, this is an unnecessary requirement. A simpler, more accessible training could be held online, or a training curriculum could be developed and distributed to RESNET Training Providers, minimizing travel. Lastly, a remote QA option is long overdue and should be considered & implemented. Appendix I in the LEED for Homes QA Manual 2017 Edition is in place and outlines this language. Remote QA is a significant cost savings measure for HERS Raters operating in rural areas.
Section 103 Comments:
This is too complicated and not clearly explained. There is a simpler way to go about this. The primary objectives (which we agree with) of this addendum to Section 103 appears to be to reduce conflict of interest & increase transparency among Providers.
If that’s it, why do two separate provider types need to be created to achieve this? This is an overly complicated strategy, adding more proper nouns & definitions to an already complicated standard. Keep it simple. It also sounds like a strategy to justify increased fees for providers who operate under both of the proposed two distinct provider types. This would then lead to an increase in cost of HERS Ratings.
A simple solution would be to require that current Rating Providers and QA Agents (former QAD(D)s) who perform ratings must register with and meet QA requirements through another Rating Provider. In addition, those Rating Providers cannot exchange services, and the financial conflict of interest still applies, etc…
Section 905 (Quality Agents) Comments:
These qualification requirements make sense, with the exception of 905.2.2.3: What is the intent of this on-site training event? Why require an on-site training when video-conferencing & telepresence is so prevalent and cheap? Our concern is that this is unnecessary to ensure consistent training for QA Agents, which will increase the cost of entry to the industry. We understand the importance of training QA Agents, however, this is an unnecessary requirement. A simpler, more accessible training could be held online, or a training curriculum could be developed and distributed to RESNET Training Providers, minimizing travel.
Lastly, a remote QA option is long overdue and should be considered & implemented. Appendix I in the LEED for Homes QA Manual 2017 Edition is in place and outlines this language. Remote QA is a significant cost savings measure for HERS Raters operating in rural areas.
Comment #10Amendment: Proposed MINHERS Addendum 29Page Number: 3Paragraph / Figure / Table / Note: 103.2.5Comment Intent: ObjectionComment Type: GeneralComment: Stronger oversight of the QA process by RESNET is a long time coming and will do more to help ensure the consistency and quality of HERS Ratings than financial separation. It is the true key to keeping Quality Agents acting in an ethical manner, if they are ones who wish to cheat. Those who were already behaving ethically will not be affected...except within their business models. It is my belief that this section be removed in whole as it adds little of value that is not already being handled through the new oversight process. All it does is convolute the process and potentially add a great deal of additional expense to ratings which could make the Rater client decline to pursue ratings and hinder the market transformation organizations like EPA, USGBC, and Home Innovation Research Labs strive for. How this negatively impacts the process is twofold: 1) It sets a precedent for RESNET to stipulate business models, which is contrary to prior stated viewpoints. The rest of this process has worked to redefine, clarify, and restructure the Quality Assurance process and people involved. The idea behind 103.2.5 is already fully handled with 103.2.2 (Financial Separation) and 103.1.2.1.1 (vetting by QA Manager) and so this is unneeded. 2) It removes flexibility to find a business partner that makes sense. Take as an example a lighter market (such as Wyoming, Montana, North Dakota, etc.) as opposed to denser markets (Chicago, New York, Dallas). In these areas, you might have organizations who have become Raters and Providers to manage costs as the nearest organization, who also chose to be a Rater and Provider for the same reason, is half a day's drive away. Under the new financial separation, they would like to choose to work together as they are the nearest options, but 103.2.5 will force them to have to use someone even farther away which will lead to higher costs. These two organizations would still be subjected to the same increased levels of oversight by RESNET so there is no reason they should not be allowed to work together just because someone is concerned about price fixing, which is the only argument that remains. It is not RESNET's place to be involved in pricing, again per their own stated viewpoints. Since Quality Agents will be Agents of RESNET, held to a higher level of oversight, and relationships vetted by RESNET (as stated in other locations) this section should be removed. Proposed Change: 103.2.5 Two organizations that are both a Third-Party Provider and Direct Rating Provider shall not exchange quality assurance services specified in these Standards.
Stronger oversight of the QA process by RESNET is a long time coming and will do more to help ensure the consistency and quality of HERS Ratings than financial separation. It is the true key to keeping Quality Agents acting in an ethical manner, if they are ones who wish to cheat. Those who were already behaving ethically will not be affected...except within their business models.
It is my belief that this section be removed in whole as it adds little of value that is not already being handled through the new oversight process. All it does is convolute the process and potentially add a great deal of additional expense to ratings which could make the Rater client decline to pursue ratings and hinder the market transformation organizations like EPA, USGBC, and Home Innovation Research Labs strive for.
How this negatively impacts the process is twofold: 1) It sets a precedent for RESNET to stipulate business models, which is contrary to prior stated viewpoints. The rest of this process has worked to redefine, clarify, and restructure the Quality Assurance process and people involved. The idea behind 103.2.5 is already fully handled with 103.2.2 (Financial Separation) and 103.1.2.1.1 (vetting by QA Manager) and so this is unneeded.
2) It removes flexibility to find a business partner that makes sense. Take as an example a lighter market (such as Wyoming, Montana, North Dakota, etc.) as opposed to denser markets (Chicago, New York, Dallas). In these areas, you might have organizations who have become Raters and Providers to manage costs as the nearest organization, who also chose to be a Rater and Provider for the same reason, is half a day's drive away. Under the new financial separation, they would like to choose to work together as they are the nearest options, but 103.2.5 will force them to have to use someone even farther away which will lead to higher costs. These two organizations would still be subjected to the same increased levels of oversight by RESNET so there is no reason they should not be allowed to work together just because someone is concerned about price fixing, which is the only argument that remains. It is not RESNET's place to be involved in pricing, again per their own stated viewpoints.
Since Quality Agents will be Agents of RESNET, held to a higher level of oversight, and relationships vetted by RESNET (as stated in other locations) this section should be removed.
103.2.5 Two organizations that are both a Third-Party Provider and Direct Rating Provider shall not exchange quality assurance services specified in these Standards.
Comment #11Amendment: Proposed MINHERS Addendum 29Page Number: B1 (4th page)Paragraph / Figure / Table / Note: 905.2.2.4Comment Intent: ObjectionComment Type: TechnicalComment: 905.2.2.34 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 EnergyLogic team reads this section to mean that if a QA Agent performs a rating that they will need to send their ratings to a separate Direct Provider from the Provider they did the rating under. Given all the other parameters being proposed, this seems overkill as there would be no conflict or overlap of the workflow between a person’s QA Agent work and their rating work. The standard makes it very clear in multiple sections that a QA agent may not have financial interest with the Direct Rating Provider. Having a QA Agent performing ratings for a Direct Provider of which they are not able to QA (no conflict), and who is being QA’ed by another QA agent deemed to have no conflict with that rating business, is all that would be required to make sure there is no conflict in that QA Agent’s rating work. In other words the QA Agent is taking off their QA Agent hat and performing a rating under the same rules as other Raters with no overlap of conflict in their rating or QA work. Let’s look at an example and because most things are easier understand with a diagram we have created a workflow diagram as a visual aid the example below The diagram is linked here for easy access and also attached with submittal: https://drive.google.com/open?id=1gGAptC68VIrmG1CZSQj7ie5y-hTNi76x Let’s pose a scenario to shed more light on the topic. Let’s say EnergyLogic is a Direct Provider, 3rd Party Provider, and QA Contractor. We employ a QA Agent named Ben, who does QA for the 3rd Party Provider and QA Contractor business areas, but isn’t allowed by RESNET to do any QA for EnergyLogic’s Direct Provider. Let’s say EnergyLogic has chosen AAA QA Contracting as their QA Contractor for their Direct Provider work. AAA QA Contracting and all of its QA Agents have been vetted to have no conflict of interest, per this addendum. Let’s say EnergyLogic and Ben find a need for him to step in and perform ratings during a big crunch with Direct Providing Rating work. This would make sense as it would help EnergyLogic in the short term with a temporary spike in field work. Per proposed 905.2.2.4, those ratings that Ben does must be certified (QA’ed) by a “separate” Provider. However, AAA QA Contracting oversees all of EnergyLogic’s Direct Provider Ratings and has no conflict with Ben’s work as a rater or a QA Agent. So if there is no potential or “perceived conflict”, why should we require Ben to submit his ratings under a separate Third Party Provider? In this scenario, having one company processing ratings through two different processes/providers is overkill with no additional level of independent QA and could actually lead to more inconsistency and inefficiency with Ben’s rating work being under a separate provider from all the rest of EnergyLogic’s rating work. Proposed Change: 905.2.2.4 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.per 103.1.3 and 103.2.3, Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
905.2.2.34 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 EnergyLogic team reads this section to mean that if a QA Agent performs a rating that they will need to send their ratings to a separate Direct Provider from the Provider they did the rating under. Given all the other parameters being proposed, this seems overkill as there would be no conflict or overlap of the workflow between a person’s QA Agent work and their rating work. The standard makes it very clear in multiple sections that a QA agent may not have financial interest with the Direct Rating Provider. Having a QA Agent performing ratings for a Direct Provider of which they are not able to QA (no conflict), and who is being QA’ed by another QA agent deemed to have no conflict with that rating business, is all that would be required to make sure there is no conflict in that QA Agent’s rating work. In other words the QA Agent is taking off their QA Agent hat and performing a rating under the same rules as other Raters with no overlap of conflict in their rating or QA work.
Let’s look at an example and because most things are easier understand with a diagram we have created a workflow diagram as a visual aid the example below
The diagram is linked here for easy access and also attached with submittal: https://drive.google.com/open?id=1gGAptC68VIrmG1CZSQj7ie5y-hTNi76x
Let’s pose a scenario to shed more light on the topic. Let’s say EnergyLogic is a Direct Provider, 3rd Party Provider, and QA Contractor. We employ a QA Agent named Ben, who does QA for the 3rd Party Provider and QA Contractor business areas, but isn’t allowed by RESNET to do any QA for EnergyLogic’s Direct Provider.
Let’s say EnergyLogic has chosen AAA QA Contracting as their QA Contractor for their Direct Provider work. AAA QA Contracting and all of its QA Agents have been vetted to have no conflict of interest, per this addendum.
Let’s say EnergyLogic and Ben find a need for him to step in and perform ratings during a big crunch with Direct Providing Rating work. This would make sense as it would help EnergyLogic in the short term with a temporary spike in field work.
Per proposed 905.2.2.4, those ratings that Ben does must be certified (QA’ed) by a “separate” Provider. However, AAA QA Contracting oversees all of EnergyLogic’s Direct Provider Ratings and has no conflict with Ben’s work as a rater or a QA Agent. So if there is no potential or “perceived conflict”, why should we require Ben to submit his ratings under a separate Third Party Provider? In this scenario, having one company processing ratings through two different processes/providers is overkill with no additional level of independent QA and could actually lead to more inconsistency and inefficiency with Ben’s rating work being under a separate provider from all the rest of EnergyLogic’s rating work.
905.2.2.4 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.per 103.1.3 and 103.2.3, Quality Assurance of that rating shall be conducted by a Quality Agent without financial interest with the Quality Agent conducting the rating.
Comment #12Amendment: Proposed MINHERS Addendum 29Page Number: B1Paragraph / Figure / Table / Note: 103.1Comment Intent: ObjectionComment Type: GeneralComment: • 103.1 Direct Rating Provider (Direct Provider)– Object – Strike All o As the RESNET Board has already acknowledged their acceptance and support for there being two primary Rating Provider types of organization (Direct and Third-Party), there is no need to further clarify in this proposed Addendum; a definition of what constitutes a Direct Rating Provider. o The remaining proposed changes/modifications to subsections of 103.1 are all pertinent to the creation of new categories of quality assurance companies and individuals which are neither necessary nor do they provide any enhanced benefit to the existing structure of QADs/QADDs under either the acknowledged Direct Provider and Third-Party Provider models. ? The proposed new categories of Quality Assurance Contractors and Quality Agents are fundamentally no different than the existing Third-Party Provider but without the other Provider roles and responsibilities. • The pilot effort attempted by RESNET failed to come to fruition due to projected costs and logistical impossibilities. o Initial cost estimates placed the per-rating cost to conduct partially independent QA in the $20-$50 range and implementation was estimated to reduce staffing and administrative costs to Providers at less than a 40% rate. This net-effective cost burden of $50-$90 per-rating would have to be passed to builders and would be catastrophic to our industry without accomplishing any clear-cut goals for enhanced consistency and transparency of how QA is performed and managed. ? The existing structure of RESNET Quality Assurance practices as well as QADs and QADDs can and should come under greater direct control and supervision by RESNET. This can be accomplished through continuous improvement efforts such as: • Annual QAD/QADD training requirements to be developed and implemented by the newly enhanced RESNET QA staff. • Additional RESNET Field Staff to conduct routine random auditing of field and file QA as overseen by accredited QADs and QADDs. • Development of enhanced minimum RESNET Standards for how QA is conducted and reported. • Increased RESNET interaction and Data sharing with State and Utility Implementation Contractors who currently conduct independent QA on tens of thousands of Ratings every year. • Monitor and revise as deemed advisable how QA Genie is utilized. ? Concurrent efforts to continue to improve software alignment and minimum building-attribute data entry standards will minimize the output-creep that concerns builders, code officials, utility companies and state commissions. ? Continued effort to develop and fine-tune virtual and other electronic means and methods for consistent oversight and more cost effective Quality Assurance by both Direct and Third-Party providers so that these tools can be utilized effectively and consistently in all markets regardless of RESNET HERS penetration. ? A review and revision to minimum HERS Rater and Field Rater training. More direct RESNET involvement in how training is conducted will enable greater consistency in the practical application of HERS Ratings in the field and in the use of accredited software. Proposed Change: 103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for the rating work completed by third-party Rating Companies and/or whose staff conducts all or aany 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 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. 103.1.2.1 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, or contract with, willshall have no financial interest in the Direct Provider’s company, the Direct Provider’s employed including their Raters and Rating Company clients as well as, or any ratings completed by HERS Raters working with their Direct Provider clients. Quality Assurance Contractors and their Quality Agents may receive compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, and other non-HERS rating related services. 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. 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. 103.1.2.1.1 The 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. Appendix B B 1 103.1.2.1.1.2 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 mayshall not perform quality assurance of the Direct Provider’s work. 103.1.3.1 An organization who is a Direct Rating Provider providing Third-Party Rating Quality Assurance services for a Rating company or another Direct Rating 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 Direct Rating Provider (Direct Provider)– Object – Strike All o As the RESNET Board has already acknowledged their acceptance and support for there being two primary Rating Provider types of organization (Direct and Third-Party), there is no need to further clarify in this proposed Addendum; a definition of what constitutes a Direct Rating Provider. o The remaining proposed changes/modifications to subsections of 103.1 are all pertinent to the creation of new categories of quality assurance companies and individuals which are neither necessary nor do they provide any enhanced benefit to the existing structure of QADs/QADDs under either the acknowledged Direct Provider and Third-Party Provider models. ? The proposed new categories of Quality Assurance Contractors and Quality Agents are fundamentally no different than the existing Third-Party Provider but without the other Provider roles and responsibilities. • The pilot effort attempted by RESNET failed to come to fruition due to projected costs and logistical impossibilities. o Initial cost estimates placed the per-rating cost to conduct partially independent QA in the $20-$50 range and implementation was estimated to reduce staffing and administrative costs to Providers at less than a 40% rate. This net-effective cost burden of $50-$90 per-rating would have to be passed to builders and would be catastrophic to our industry without accomplishing any clear-cut goals for enhanced consistency and transparency of how QA is performed and managed. ? The existing structure of RESNET Quality Assurance practices as well as QADs and QADDs can and should come under greater direct control and supervision by RESNET. This can be accomplished through continuous improvement efforts such as: • Annual QAD/QADD training requirements to be developed and implemented by the newly enhanced RESNET QA staff. • Additional RESNET Field Staff to conduct routine random auditing of field and file QA as overseen by accredited QADs and QADDs. • Development of enhanced minimum RESNET Standards for how QA is conducted and reported. • Increased RESNET interaction and Data sharing with State and Utility Implementation Contractors who currently conduct independent QA on tens of thousands of Ratings every year. • Monitor and revise as deemed advisable how QA Genie is utilized. ? Concurrent efforts to continue to improve software alignment and minimum building-attribute data entry standards will minimize the output-creep that concerns builders, code officials, utility companies and state commissions. ? Continued effort to develop and fine-tune virtual and other electronic means and methods for consistent oversight and more cost effective Quality Assurance by both Direct and Third-Party providers so that these tools can be utilized effectively and consistently in all markets regardless of RESNET HERS penetration. ? A review and revision to minimum HERS Rater and Field Rater training. More direct RESNET involvement in how training is conducted will enable greater consistency in the practical application of HERS Ratings in the field and in the use of accredited software.
103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for the rating work completed by third-party Rating Companies and/or whose staff conducts all or aany 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 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. 103.1.2.1 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, or contract with, willshall have no financial interest in the Direct Provider’s company, the Direct Provider’s employed including their Raters and Rating Company clients as well as, or any ratings completed by HERS Raters working with their Direct Provider clients. Quality Assurance Contractors and their Quality Agents may receive compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, and other non-HERS rating related services. 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. 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. 103.1.2.1.1 The 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. Appendix B B 1 103.1.2.1.1.2 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 mayshall not perform quality assurance of the Direct Provider’s work. 103.1.3.1 An organization who is a Direct Rating Provider providing Third-Party Rating Quality Assurance services for a Rating company or another Direct Rating 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.
Comment #13Amendment: Proposed MINHERS Addendum 29Page Number: B1Paragraph / Figure / Table / Note: 103.2Comment Intent: ObjectionComment Type: GeneralComment: • 103.1 Direct Rating Provider (Direct Provider)– Object – Strike All o As the RESNET Board has already acknowledged their acceptance and support for there being two primary Rating Provider types of organization (Direct and Third-Party), there is no need to further clarify in this proposed Addendum; a definition of what constitutes a Direct Rating Provider. o The remaining proposed changes/modifications to subsections of 103.1 are all pertinent to the creation of new categories of quality assurance companies and individuals which are neither necessary nor do they provide any enhanced benefit to the existing structure of QADs/QADDs under either the acknowledged Direct Provider and Third-Party Provider models. ? The proposed new categories of Quality Assurance Contractors and Quality Agents are fundamentally no different than the existing Third-Party Provider but without the other Provider roles and responsibilities. • The pilot effort attempted by RESNET failed to come to fruition due to projected costs and logistical impossibilities. o Initial cost estimates placed the per-rating cost to conduct partially independent QA in the $20-$50 range and implementation was estimated to reduce staffing and administrative costs to Providers at less than a 40% rate. This net-effective cost burden of $50-$90 per-rating would have to be passed to builders and would be catastrophic to our industry without accomplishing any clear-cut goals for enhanced consistency and transparency of how QA is performed and managed. ? The existing structure of RESNET Quality Assurance practices as well as QADs and QADDs can and should come under greater direct control and supervision by RESNET. This can be accomplished through continuous improvement efforts such as: • Annual QAD/QADD training requirements to be developed and implemented by the newly enhanced RESNET QA staff. • Additional RESNET Field Staff to conduct routine random auditing of field and file QA as overseen by accredited QADs and QADDs. • Development of enhanced minimum RESNET Standards for how QA is conducted and reported. • Increased RESNET interaction and Data sharing with State and Utility Implementation Contractors who currently conduct independent QA on tens of thousands of Ratings every year. • Monitor and revise as deemed advisable how QA Genie is utilized. ? Concurrent efforts to continue to improve software alignment and minimum building-attribute data entry standards will minimize the output-creep that concerns builders, code officials, utility companies and state commissions. ? Continued effort to develop and fine-tune virtual and other electronic means and methods for consistent oversight and more cost effective Quality Assurance by both Direct and Third-Party providers so that these tools can be utilized effectively and consistently in all markets regardless of RESNET HERS penetration. ? A review and revision to minimum HERS Rater and Field Rater training. More direct RESNET involvement in how training is conducted will enable greater consistency in the practical application of HERS Ratings in the field and in the use of accredited software. Proposed Change: 103.2 Third-party Rating Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider who does not receive fees for the rating and whose staff does not conduct any portion of the rating. 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. 103.2.1 Third-party 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 Providers and the Quality Agents they employ, or contract with, willshall have no financial interest in their HERS Rating Company clients, or any ratings completed by HERS Raters working with their HERS Rating Company clients. Quality Assurance Contractors and their Quality Agents may receive compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, and other non-HERS rating related services. Financial interest is defined in Appendix Appendix B B 1 B. Contractual relationship includes providing design or subcontractor services to a project, whether or not a signed contract exists. 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. 103.2.4 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.
103.2 Third-party Rating Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider who does not receive fees for the rating and whose staff does not conduct any portion of the rating. 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. 103.2.1 Third-party 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 Providers and the Quality Agents they employ, or contract with, willshall have no financial interest in their HERS Rating Company clients, or any ratings completed by HERS Raters working with their HERS Rating Company clients. Quality Assurance Contractors and their Quality Agents may receive compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, and other non-HERS rating related services. Financial interest is defined in Appendix Appendix B B 1 B. Contractual relationship includes providing design or subcontractor services to a project, whether or not a signed contract exists. 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. 103.2.4 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.
Comment #14Amendment: Proposed MINHERS Addendum 29Page Number: B1Paragraph / Figure / Table / Note: 905.2Comment Intent: ObjectionComment Type: GeneralComment: • 103.1 Direct Rating Provider (Direct Provider)– Object – Strike All o As the RESNET Board has already acknowledged their acceptance and support for there being two primary Rating Provider types of organization (Direct and Third-Party), there is no need to further clarify in this proposed Addendum; a definition of what constitutes a Direct Rating Provider. o The remaining proposed changes/modifications to subsections of 103.1 are all pertinent to the creation of new categories of quality assurance companies and individuals which are neither necessary nor do they provide any enhanced benefit to the existing structure of QADs/QADDs under either the acknowledged Direct Provider and Third-Party Provider models. ? The proposed new categories of Quality Assurance Contractors and Quality Agents are fundamentally no different than the existing Third-Party Provider but without the other Provider roles and responsibilities. • The pilot effort attempted by RESNET failed to come to fruition due to projected costs and logistical impossibilities. o Initial cost estimates placed the per-rating cost to conduct partially independent QA in the $20-$50 range and implementation was estimated to reduce staffing and administrative costs to Providers at less than a 40% rate. This net-effective cost burden of $50-$90 per-rating would have to be passed to builders and would be catastrophic to our industry without accomplishing any clear-cut goals for enhanced consistency and transparency of how QA is performed and managed. ? The existing structure of RESNET Quality Assurance practices as well as QADs and QADDs can and should come under greater direct control and supervision by RESNET. This can be accomplished through continuous improvement efforts such as: • Annual QAD/QADD training requirements to be developed and implemented by the newly enhanced RESNET QA staff. • Additional RESNET Field Staff to conduct routine random auditing of field and file QA as overseen by accredited QADs and QADDs. • Development of enhanced minimum RESNET Standards for how QA is conducted and reported. • Increased RESNET interaction and Data sharing with State and Utility Implementation Contractors who currently conduct independent QA on tens of thousands of Ratings every year. • Monitor and revise as deemed advisable how QA Genie is utilized. ? Concurrent efforts to continue to improve software alignment and minimum building-attribute data entry standards will minimize the output-creep that concerns builders, code officials, utility companies and state commissions. ? Continued effort to develop and fine-tune virtual and other electronic means and methods for consistent oversight and more cost effective Quality Assurance by both Direct and Third-Party providers so that these tools can be utilized effectively and consistently in all markets regardless of RESNET HERS penetration. ? A review and revision to minimum HERS Rater and Field Rater training. More direct RESNET involvement in how training is conducted will enable greater consistency in the practical application of HERS Ratings in the field and in the use of accredited software. Proposed Change: 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. 905.2.1 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 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 ten (10) homes and QA File reviews on a minimum of twenty (20) homes as either a Quality Assurance Designee or delegate (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 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. 905.2.1 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 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 ten (10) homes and QA File reviews on a minimum of twenty (20) homes as either a Quality Assurance Designee or delegate (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;
Comment #15Amendment: Proposed MINHERS Addendum 29Page Number: B1Paragraph / Figure / Table / Note: 103.1.2.1Comment Intent: ObjectionComment Type: GeneralComment: 103.1.2.1 states that: Quality Assurance Contractors for Direc Providers , and the Quality Agents that they employ, or contract with, shall have no financial interest in the Direct Provider's company.... I believe that we need to think about what consitutes a financial interset. Take a hypthetical situation: A direct rating provider company, which produces 5000 ratings per year, is negotiating with a Quality Assurance Contractor who is going to charge $10/rating for QA. This contract is worth $50,000. Does the Quality Assurance Contractor now have a financial interest that this Direct Rating Provider stay in business to renew that contract. What if they did 10,000 ratings per year - is that $100,000 contract a financial interest. I believe the answer is yes. We are kidding ourselves if we think that this is financial separation. Other problems with this model include logistics of coordinating field quality assurance. The availability of homes to be subject to QA will be difficult to coordinate. Houses are largely being built as sold – there are few field models anymore. Final testing is frequently being conducted very close to closing dates. Conditions inside field models can change (water leaks, option changes, vandalism, etc.) Work can be taking place inside the house (paint, options changes, etc.) It is difficult for even someone who is in close physical proximity and is intimately involved in the scheduling of testing to be able to do field QA. It will be next to impossible to do this from outside the organization and coming from out of town. This is evidenced by the failure of the pilot program to be able to conduct field QA. It will still be relatively easy for the raters and providers who want to “cheat the system” to do so, by making only certain houses available for field QA. With this much uncertainty, and the idea of up-ending the business model for Raters and Direct Rating Providers with uncertain benefits to consistency or quality assurance, there is concern for the potential for the change to be extremely detrimental to the industry. Proposed Change: Strike the entire section. The Board of Directors needs to reconsider how to define financial interest and how to separate quality oversight from it. I would suggest that the model that Laurel and Scott presented at the Board of Directors meeting, where RESNET employees and/or contractors conduct on-site quality assurance review of processes would be far more effective that the currently proposed model. Alternative model for enhanced quality assurance • Make all of the existing QAD’s go through the new training. • Make all of the existing QAD’s sign a “contract” acknowledging that they are agents of RESNET. • Require the use of RESNET developed procedures and forms for completing file QA and Field QA. • Issue picture ID’s for all Raters and RFI’s. • Develop a better process for Whistle Blowing – get the builders involved. • Let QA Genie and/or common schema analysis do its job. RESNET Employees/Contractors conduct field quality assurance process reviews
103.1.2.1 states that:
Quality Assurance Contractors for Direc Providers , and the Quality Agents that they employ, or contract with, shall have no financial interest in the Direct Provider's company....
I believe that we need to think about what consitutes a financial interset. Take a hypthetical situation: A direct rating provider company, which produces 5000 ratings per year, is negotiating with a Quality Assurance Contractor who is going to charge $10/rating for QA. This contract is worth $50,000. Does the Quality Assurance Contractor now have a financial interest that this Direct Rating Provider stay in business to renew that contract. What if they did 10,000 ratings per year - is that $100,000 contract a financial interest. I believe the answer is yes. We are kidding ourselves if we think that this is financial separation.
Other problems with this model include logistics of coordinating field quality assurance. The availability of homes to be subject to QA will be difficult to coordinate.
Houses are largely being built as sold – there are few field models anymore. Final testing is frequently being conducted very close to closing dates. Conditions inside field models can change (water leaks, option changes, vandalism, etc.) Work can be taking place inside the house (paint, options changes, etc.) It is difficult for even someone who is in close physical proximity and is intimately involved in the scheduling of testing to be able to do field QA. It will be next to impossible to do this from outside the organization and coming from out of town. This is evidenced by the failure of the pilot program to be able to conduct field QA.
It will still be relatively easy for the raters and providers who want to “cheat the system” to do so, by making only certain houses available for field QA. With this much uncertainty, and the idea of up-ending the business model for Raters and Direct Rating Providers with uncertain benefits to consistency or quality assurance, there is concern for the potential for the change to be extremely detrimental to the industry.
Strike the entire section. The Board of Directors needs to reconsider how to define financial interest and how to separate quality oversight from it.
I would suggest that the model that Laurel and Scott presented at the Board of Directors meeting, where RESNET employees and/or contractors conduct on-site quality assurance review of processes would be far more effective that the currently proposed model.
Alternative model for enhanced quality assurance • Make all of the existing QAD’s go through the new training. • Make all of the existing QAD’s sign a “contract” acknowledging that they are agents of RESNET. • Require the use of RESNET developed procedures and forms for completing file QA and Field QA. • Issue picture ID’s for all Raters and RFI’s. • Develop a better process for Whistle Blowing – get the builders involved. • Let QA Genie and/or common schema analysis do its job.
RESNET Employees/Contractors conduct field quality assurance process reviews
Comment #16Amendment: Proposed MINHERS Addendum 29Page Number: B1Paragraph / Figure / Table / Note: 103.2.2Comment Intent: ObjectionComment Type: GeneralComment: Please see my comment on 103.1.2.1 - which was for Direct Rating Providers and Quality Assurance Contractors. The same issue arises for Third party Providers having a financial interest in Raters who produce a volume of ratings. There will be the same issues with logistics and manipulation of houses available for QA. Proposed Change: Strike the section. Request that the Board of Directors reconsider the definition of financial interest and how to best provide the Quality Assurance that they are trying to achieve. Alternative model for enhanced quality assurance Altnerative QA process: • Make all of the existing QAD’s go through the new training. • Make all of the existing QAD’s sign a “contract” acknowledging that they are agents of RESNET. • Require the use of RESNET developed procedures and forms for completing file QA and Field QA. • Issue picture ID’s for all Raters and RFI’s. • Develop a better process for Whistle Blowing – get the builders involved. • Let QA Genie and/or common schema analysis do its job. - Have RESNET conduct field quality assurance process reviews,similar to what was described at the fall board meeting.
Please see my comment on 103.1.2.1 - which was for Direct Rating Providers and Quality Assurance Contractors. The same issue arises for Third party Providers having a financial interest in Raters who produce a volume of ratings. There will be the same issues with logistics and manipulation of houses available for QA.
Strike the section.
Request that the Board of Directors reconsider the definition of financial interest and how to best provide the Quality Assurance that they are trying to achieve. Alternative model for enhanced quality assurance
Altnerative QA process:
• Make all of the existing QAD’s go through the new training. • Make all of the existing QAD’s sign a “contract” acknowledging that they are agents of RESNET. • Require the use of RESNET developed procedures and forms for completing file QA and Field QA. • Issue picture ID’s for all Raters and RFI’s. • Develop a better process for Whistle Blowing – get the builders involved. • Let QA Genie and/or common schema analysis do its job.
- Have RESNET conduct field quality assurance process reviews,similar to what was described at the fall board meeting.
Comment #17Amendment: Proposed MINHERS Addendum 29Page Number: B1Paragraph / Figure / Table / Note: 103.1 & 103.2Comment Intent: ObjectionComment Type: TechnicalComment: The RESNET Board of Directors formed the HERS Index Score Consistency Task Force to address concerns of consistency of ratings. Their analysis found three broad areas of the inconsistency of rating scores and one was inconsistency of quality assurance oversight by Rating Providers. Based on findings from the Task Force, one of the policies adopted by the RESNET Board of Directors was to make Quality Assurance Designees financially independent from direct providership models. RESNET staff’s analysis concludes that the proposed change will have catastrophic economic and operational ramifications for Rating Providers who have evolved mature rating operations with integrated Quality Assurance. It has been RESNET Staff’s experience that the economic relationship between QADs and Providers has no correlation to degrading the quality and consistency of HERS Ratings. Thus, the proposed solution of financially separating QADs from Providers is mostly for optics. It doesn’t address the inconsistent QA processes, interpretations, and enforcement of standards that are the true root causes. It will only cause more problems than solutions. The Staff’s analysis is the result of a pilot project that was initiated with two Direct Rating Providers (one large national and one smaller accredited in two states). The pilot demonstrated that an independent QAD system was not economically and logistically viable. RESNET is increasing field Quality Assurance oversight by adding more field support starting in 2018 which will address the original issue that the RESNET Board of Directors wanted to correct. Half of all providers will have increased Quality Assurance oversight each year. Additionally, in 2018, all existing QADs will be trained by RESNET personnel. As we move to Quality Agents being trained, certified and held accountable to RESNET, Quality Assurance will become more consistent across the industry. This alternative would be a solution to the numerous concerns raised by large direct providers and again Staff believes this approach will resolve the original issue of inconsistent quality assurance oversight raised by the Task Force to the Board of Directors. We are requesting that the SDC 900 petition the RESNET Board of Directors to reconsider the policy of financial separation of QADs from Providers due to the increased in-field QA oversight by RESNET of providers and to the consistent training of QADs to be trained agents of RESNET. Proposed Change: Strike the direct and third-party sections completely: 103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for the rating work completed by third-party Rating Companies and/or whose staff conducts all or any 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 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. 103.1.2.1 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, or contract with, willshall have no financial interest in the Direct Provider’s company, the Direct Provider’s employed including their Raters and Rating Company clients as well as, or any ratings completed by HERS Raters working with their Direct Provider clients. Quality Assurance Contractors and their Quality Agents may receive compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, and other non-HERS rating related services. 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. 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. 103.1.2.1.1 The 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 mayshall not perform quality assurance of the Direct Provider’s work. 103.1.3.1 An organization who is a Direct Rating Provider providing Third-Party Rating Quality Assurance services for a Rating company or another Direct Rating 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. 103.2 Third-party Rating Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider who does not receive fees for the rating and whose staff does not conduct any portion of the rating. 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. 103.2.1 Third-party 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 Providers and the Quality Agents they employ, or contract with, willshall have no financial interest in their HERS Rating Company clients, or any ratings completed by HERS Raters working with their HERS Rating Company clients. Quality Assurance Contractors and their Quality Agents may receive compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, and other non-HERS rating related services. 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. 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. 103.2.4 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.
The RESNET Board of Directors formed the HERS Index Score Consistency Task Force to address concerns of consistency of ratings. Their analysis found three broad areas of the inconsistency of rating scores and one was inconsistency of quality assurance oversight by Rating Providers. Based on findings from the Task Force, one of the policies adopted by the RESNET Board of Directors was to make Quality Assurance Designees financially independent from direct providership models.
RESNET staff’s analysis concludes that the proposed change will have catastrophic economic and operational ramifications for Rating Providers who have evolved mature rating operations with integrated Quality Assurance.
It has been RESNET Staff’s experience that the economic relationship between QADs and Providers has no correlation to degrading the quality and consistency of HERS Ratings. Thus, the proposed solution of financially separating QADs from Providers is mostly for optics. It doesn’t address the inconsistent QA processes, interpretations, and enforcement of standards that are the true root causes. It will only cause more problems than solutions.
The Staff’s analysis is the result of a pilot project that was initiated with two Direct Rating Providers (one large national and one smaller accredited in two states). The pilot demonstrated that an independent QAD system was not economically and logistically viable.
RESNET is increasing field Quality Assurance oversight by adding more field support starting in 2018 which will address the original issue that the RESNET Board of Directors wanted to correct. Half of all providers will have increased Quality Assurance oversight each year.
Additionally, in 2018, all existing QADs will be trained by RESNET personnel. As we move to Quality Agents being trained, certified and held accountable to RESNET, Quality Assurance will become more consistent across the industry.
This alternative would be a solution to the numerous concerns raised by large direct providers and again Staff believes this approach will resolve the original issue of inconsistent quality assurance oversight raised by the Task Force to the Board of Directors.
We are requesting that the SDC 900 petition the RESNET Board of Directors to reconsider the policy of financial separation of QADs from Providers due to the increased in-field QA oversight by RESNET of providers and to the consistent training of QADs to be trained agents of RESNET.
Strike the direct and third-party sections completely:
103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for the rating work completed by third-party Rating Companies and/or whose staff conducts all or any 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 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.
103.1.2.1 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, or contract with, willshall have no financial interest in the Direct Provider’s company, the Direct Provider’s employed including their Raters and Rating Company clients as well as, or any ratings completed by HERS Raters working with their Direct Provider clients. Quality Assurance Contractors and their Quality Agents may receive compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, and other non-HERS rating related services. 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.
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.
103.1.2.1.1 The 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 mayshall not perform quality assurance of the Direct Provider’s work.
103.1.3.1 An organization who is a Direct Rating Provider providing Third-Party Rating Quality Assurance services for a Rating company or another Direct Rating 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.
103.2 Third-party Rating Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider who does not receive fees for the rating and whose staff does not conduct any portion of the rating. 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.
103.2.1 Third-party 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 Providers and the Quality Agents they employ, or contract with, willshall have no financial interest in their HERS Rating Company clients, or any ratings completed by HERS Raters working with their HERS Rating Company clients. Quality Assurance Contractors and their Quality Agents may receive compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, and other non-HERS rating related services. 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.
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.
103.2.4 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.
Comment #18Amendment: Proposed MINHERS Addendum 29Page Number: 1, 2Paragraph / Figure / Table / Note: 103.1, 103.2Comment Intent: Not an ObjectionComment Type: EditorialComment: This comment is actually a question and applies to both sections. Section 103.1 on Direct Rating Provider and Section 103.2 on Third-party Provider both consist of a definition. Does the definition belong within the text of the standard or does it belong in the glossary in Appendix B or both?
This comment is actually a question and applies to both sections. Section 103.1 on Direct Rating Provider and Section 103.2 on Third-party Provider both consist of a definition. Does the definition belong within the text of the standard or does it belong in the glossary in Appendix B or both?
Comment #19Amendment: Proposed MINHERS Addendum 29Page Number: througoutComment Intent: Not an ObjectionComment Type: EditorialComment: It is our understanding that defined terms are capitalized by convention within the standard. There are multiple instances where this standard has not been followed for the following terms: Rating, Rating Company. These errors require correction. It is evident that the services of a technical or standards writer, prior to the comment process, would be helpful to this process. Document editing by committee, as well intentioned as it can be, is often insufficient.
It is our understanding that defined terms are capitalized by convention within the standard. There are multiple instances where this standard has not been followed for the following terms: Rating, Rating Company. These errors require correction.
It is evident that the services of a technical or standards writer, prior to the comment process, would be helpful to this process. Document editing by committee, as well intentioned as it can be, is often insufficient.
Comment #20Amendment: Proposed MINHERS Addendum 29Page Number: 1, 2Paragraph / Figure / Table / Note: 103.1.1, 103.1.2.1, 103.2.1Comment Intent: Not an ObjectionComment Type: EditorialComment: Use of the word "oversee" to describe the work provided by Quality Assurance Contractors and Quality Agents doesn't adequately describe the scope of work required to provide this service. 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 verify and document 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. 103.1.2.1 Quality Assurance Contractors must employ one or more Quality Agents certified by RESNET. The Quality Agent will oversee verify and document 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. 103.2.1 Third-party Providers must employ one or more Quality Agents certified by RESNET. The Quality Agent will oversee verify and document 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.
Use of the word "oversee" to describe the work provided by Quality Assurance Contractors and Quality Agents doesn't adequately describe the scope of work required to provide this service.
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 verify and document 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.
103.1.2.1 Quality Assurance Contractors must employ one or more Quality Agents certified by RESNET. The Quality Agent will oversee verify and document 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.
103.2.1 Third-party Providers must employ one or more Quality Agents certified by RESNET. The Quality Agent will oversee verify and document 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 #21Amendment: Proposed MINHERS Addendum 29Page Number: 2Paragraph / Figure / Table / Note: 103.1.2.1.1.2Comment Intent: ObjectionComment Type: EditorialComment: The requirement of full disclosure of any existing or prior business relationships between contracted entities is overly broad, and places an undue burden on Direct Providers, QA Contractors and the RESNET QA manager. Proposed Change: 103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity that is related to the Direct Provider's compliance with Chapter 9 of these Standards.
The requirement of full disclosure of any existing or prior business relationships between contracted entities is overly broad, and places an undue burden on Direct Providers, QA Contractors and the RESNET QA manager.
103.1.2.1.1.2 Require a full disclosure of any existing or prior business relationships with any potential contracted entity that is related to the Direct Provider's compliance with Chapter 9 of these Standards.
Comment #22Amendment: Proposed MINHERS Addendum 29Page Number: 2Paragraph / Figure / Table / Note: 103.1.3.1.1Comment Intent: Not an ObjectionComment Type: EditorialComment: It is our opinion that the term "solicit" used in this section has multiple definitions in a legal context. Our suggested expanded language below comes from a brief internet search. Our comment includes a question. Does RESNET seek legal review of their standards during the development and comment periods? Proposed Change: 103.1.3.1.1 Shall not solicit or otherwise attempt to establish any business relationship with any the clients of the company on which Quality Assurance is being performed.
It is our opinion that the term "solicit" used in this section has multiple definitions in a legal context. Our suggested expanded language below comes from a brief internet search.
Our comment includes a question. Does RESNET seek legal review of their standards during the development and comment periods?
103.1.3.1.1 Shall not solicit or otherwise attempt to establish any business relationship with any the clients of the company on which Quality Assurance is being performed.
Comment #23Amendment: Proposed MINHERS Addendum 29Page Number: Page 1-2Paragraph / Figure / Table / Note: 103.1 -103.25Comment Intent: ObjectionComment Type: GeneralComment: Financially independent Quality Assurance has been the “approach” driven by RESNET for the past four years in its efforts to resolve the many issues of Quality Assurance. While it was not a brilliant idea to begin with, at least Financially Independent QA had some hope of delivering improved QA to the Industry. Apparently, during that four year period, RESNET was not able to conceive of how to implement this QA Effort and the YEARS of effort and the YEARS of wait will continue as the Pilot Project for delivery of independent QA lacks financial viability (i.e.adds huge costs) without delivering any documentable improvement in Quality or Consistency. This is a disappointment. As RESNET proposes no changes in the potential path for independent QA, that idea must go by the wayside. Strike all the language. At present, RESNET plans modest improvements in its current efforts. The suggestions are underwhelming. QA Providers (soon to be “rebranded as Agents”) collect insufficient field evidence to evaluate QA Provider performance and absolutely insufficient evidence to fully evaluate field performance of Rating Companies and Raters and RFI’s. “Agents”, QA Genie and greater frequency of inspections on Rating Companies, Raters and RFI’s will also deliver almost no improvement in actual field performance. The variance of ratings (inconsistencies) come at the Field Level and are not addressed at the Provider Level. None of these elements shed light on the questions of: • Did a Qualified Person deliver the work at the home? • Did the person doing the work go into the home or just “drive by”? • Was the inspection and test delivered in an appropriate length of time? (I.e. Was the actual field inspector at the home for a long enough period to actually deliver the required inspections and testing?) • Can we document that the required minimum rated features were actually provided at the home? (I.e. Are the test gauges photographed with a date and time stamp and, if possible, GPS?) EPA’s RaterPro app is available (for FREE) come February and should be the industry “minimum standard” data collection tool beginning Q2 or Q3 2018. To do any less is missing the boat on easily available data that will provide vastly more insight into how ratings vary. Using the EPA tool as a minimum requirement and capturing field data as it is created (by the QA Provider and by RESNET) will be an inexpensive method to vastly improving the ability to deliver QA. This should be added to the RESNET QA minimum requirements as we delete the requirements for financially independent QA. Adding this information to the Rating File can add a vastly more complete view of each Rating, all Ratings in aggregate and give much better insight to the QA Providers and RESNET QA oversight in how ratings are performed and where the problems are. Proposed Change: all field inspections and performance tests must be recorded by digital/electronic means eg tablet / phone, Rater Pro or equivalent that clearly document - time the Rater/RFI arrived to start the inspection - time the Rater/RFI completed the inspection - all Failed and Passing performance test results are documented with date, time stamp photos - all onsite MRF are documented at least once with date, time stamp photos - all failed MRF are documented with date, time stamp photos Records shall be kept for min 5 years
Financially independent Quality Assurance has been the “approach” driven by RESNET for the past four years in its efforts to resolve the many issues of Quality Assurance. While it was not a brilliant idea to begin with, at least Financially Independent QA had some hope of delivering improved QA to the Industry. Apparently, during that four year period, RESNET was not able to conceive of how to implement this QA Effort and the YEARS of effort and the YEARS of wait will continue as the Pilot Project for delivery of independent QA lacks financial viability (i.e.adds huge costs) without delivering any documentable improvement in Quality or Consistency. This is a disappointment.
As RESNET proposes no changes in the potential path for independent QA, that idea must go by the wayside. Strike all the language.
At present, RESNET plans modest improvements in its current efforts. The suggestions are underwhelming. QA Providers (soon to be “rebranded as Agents”) collect insufficient field evidence to evaluate QA Provider performance and absolutely insufficient evidence to fully evaluate field performance of Rating Companies and Raters and RFI’s.
“Agents”, QA Genie and greater frequency of inspections on Rating Companies, Raters and RFI’s will also deliver almost no improvement in actual field performance. The variance of ratings (inconsistencies) come at the Field Level and are not addressed at the Provider Level. None of these elements shed light on the questions of:
• Did a Qualified Person deliver the work at the home? • Did the person doing the work go into the home or just “drive by”? • Was the inspection and test delivered in an appropriate length of time? (I.e. Was the actual field inspector at the home for a long enough period to actually deliver the required inspections and testing?) • Can we document that the required minimum rated features were actually provided at the home? (I.e. Are the test gauges photographed with a date and time stamp and, if possible, GPS?)
EPA’s RaterPro app is available (for FREE) come February and should be the industry “minimum standard” data collection tool beginning Q2 or Q3 2018. To do any less is missing the boat on easily available data that will provide vastly more insight into how ratings vary. Using the EPA tool as a minimum requirement and capturing field data as it is created (by the QA Provider and by RESNET) will be an inexpensive method to vastly improving the ability to deliver QA.
This should be added to the RESNET QA minimum requirements as we delete the requirements for financially independent QA.
Adding this information to the Rating File can add a vastly more complete view of each Rating, all Ratings in aggregate and give much better insight to the QA Providers and RESNET QA oversight in how ratings are performed and where the problems are.
all field inspections and performance tests must be recorded by digital/electronic means eg tablet / phone, Rater Pro or equivalent that clearly document - time the Rater/RFI arrived to start the inspection - time the Rater/RFI completed the inspection - all Failed and Passing performance test results are documented with date, time stamp photos - all onsite MRF are documented at least once with date, time stamp photos - all failed MRF are documented with date, time stamp photos
Records shall be kept for min 5 years
Comment #24Amendment: Proposed MINHERS Addendum 29Page Number: B1Comment Intent: ObjectionComment Type: TechnicalComment: As a provider who has contracted out 3rd party QA as well as had an internal QAD, we have a unique perspective on this proposed amendment. Our experience is that 3rd party QA did not increase the quality of our work over that of our in-house QA. In reality, having an in-house QAD allowed us to improve our quality and consistency as that team member was able to quickly address issues from a managerial standpoint, vs 3rd party QA, where our results were primarily used for RESNET compliance, and it’s benefit to our team’s overall quality was limited. In addition, the financial impact, the logistical challenges, and burden of changing our organization structure for this amendment, without proof of effectiveness, are significant enough for us to be highly concerned by this proposed amendment. Our recommendation is to increase RESNETs ability to QA actual homes in the field and increased oversight of file QA and all QADs. We encourage the board to refine the current QA process, focusing in on systemic issues and how those can be captured by RESNET, vs hoping a 3rd Party QAD will do that on their behalf. • 103.1 Direct Rating Provider (Direct Provider)– Object – Strike All o As the RESNET Board has already acknowledged their acceptance and support for there being two primary Rating Provider types of organization (Direct and Third-Party), there is no need to further clarify in this proposed Addendum; a definition of what constitutes a Direct Rating Provider. o The remaining proposed changes/modifications to subsections of 103.1 are all pertinent to the creation of new categories of quality assurance companies and individuals which are neither necessary nor do they provide any enhanced benefit to the existing structure of QADs/QADDs under either the acknowledged Direct Provider and Third-Party Provider models. ? The proposed new categories of Quality Assurance Contractors and Quality Agents are fundamentally no different than the existing Third-Party Provider but without the other Provider roles and responsibilities. • The pilot effort attempted by RESNET failed to come to fruition due to projected costs and logistical impossibilities. o Initial cost estimates placed the per-rating cost to conduct partially independent QA in the $20-$50 range and implementation was estimated to reduce staffing and administrative costs to Providers at less than a 40% rate. This net-effective cost burden of $50-$90 per-rating would have to be passed to builders and would be catastrophic to our industry without accomplishing any clear-cut goals for enhanced consistency and transparency of how QA is performed and managed. ? The existing structure of RESNET Quality Assurance practices as well as QADs and QADDs can and should come under greater direct control and supervision by RESNET. This can be accomplished through continuous improvement efforts such as: • Annual QAD/QADD training requirements to be developed and implemented by the newly enhanced RESNET QA staff. • Additional RESNET Field Staff to conduct routine random auditing of field and file QA as overseen by accredited QADs and QADDs. • Development of enhanced minimum RESNET Standards for how QA is conducted and reported. • Increased RESNET interaction and Data sharing with State and Utility Implementation Contractors who currently conduct independent QA on tens of thousands of Ratings every year. • Monitor and revise as deemed advisable how QA Genie is utilized. ? Concurrent efforts to continue to improve software alignment and minimum building-attribute data entry standards will minimize the output-creep that concerns builders, code officials, utility companies and state commissions. ? Continued effort to develop and fine-tune virtual and other electronic means and methods for consistent oversight and more cost effective Quality Assurance by both Direct and Third-Party providers so that these tools can be utilized effectively and consistently in all markets regardless of RESNET HERS penetration. ? A review and revision to minimum HERS Rater and Field Rater training. More direct RESNET involvement in how training is conducted will enable greater consistency in the practical application of HERS Ratings in the field and in the use of accredited software. Proposed Change: 103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for the rating work completed by third-party Rating Companies and/or whose staff conducts all or aany 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 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. 103.1.2.1 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, or contract with, willshall have no financial interest in the Direct Provider’s company, the Direct Provider’s employed including their Raters and Rating Company clients as well as, or any ratings completed by HERS Raters working with their Direct Provider clients. Quality Assurance Contractors and their Quality Agents may receive compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, and other non-HERS rating related services. 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. 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. 103.1.2.1.1 The 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. Appendix B B 1 103.1.2.1.1.2 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 mayshall not perform quality assurance of the Direct Provider’s work. 103.1.3.1 An organization who is a Direct Rating Provider providing Third-Party Rating Quality Assurance services for a Rating company or another Direct Rating 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.
As a provider who has contracted out 3rd party QA as well as had an internal QAD, we have a unique perspective on this proposed amendment. Our experience is that 3rd party QA did not increase the quality of our work over that of our in-house QA. In reality, having an in-house QAD allowed us to improve our quality and consistency as that team member was able to quickly address issues from a managerial standpoint, vs 3rd party QA, where our results were primarily used for RESNET compliance, and it’s benefit to our team’s overall quality was limited. In addition, the financial impact, the logistical challenges, and burden of changing our organization structure for this amendment, without proof of effectiveness, are significant enough for us to be highly concerned by this proposed amendment. Our recommendation is to increase RESNETs ability to QA actual homes in the field and increased oversight of file QA and all QADs. We encourage the board to refine the current QA process, focusing in on systemic issues and how those can be captured by RESNET, vs hoping a 3rd Party QAD will do that on their behalf.
Comment #25Amendment: Proposed MINHERS Addendum 29Page Number: B 1Comment Intent: ObjectionComment Type: GeneralComment: RESNET Quality Assurance of field inspections needs to be strengthened. Creating financial independence in itself does not accomplish this. Creating Quality Agents that work for Providers does not accemplish this either. Unfortunately, the Amendment as proposed which is a revision to current RESNET Standards but a revision to a not yet adopted revision of the RESNET Standard (WD-02 from what I can tell) does not even include the breadth of information to act as a vehicle to accomplish what is needed. Coordinated amendments through ANSI/RESNET 301 and Chap 9 and Appendix A of the MINHERS Standard are needed to introduce meaningful field QA changes. RESNET has dragged its feet on introducing any real changes to QA for so long now that anything we do here won't have any impact on ERI or IECC compliance until the 2021 Code Cycle based on how the ICC Codes reference Standards. By then, who knows what the field will look like.
RESNET Quality Assurance of field inspections needs to be strengthened. Creating financial independence in itself does not accomplish this. Creating Quality Agents that work for Providers does not accemplish this either.
Unfortunately, the Amendment as proposed which is a revision to current RESNET Standards but a revision to a not yet adopted revision of the RESNET Standard (WD-02 from what I can tell) does not even include the breadth of information to act as a vehicle to accomplish what is needed. Coordinated amendments through ANSI/RESNET 301 and Chap 9 and Appendix A of the MINHERS Standard are needed to introduce meaningful field QA changes.
RESNET has dragged its feet on introducing any real changes to QA for so long now that anything we do here won't have any impact on ERI or IECC compliance until the 2021 Code Cycle based on how the ICC Codes reference Standards. By then, who knows what the field will look like.
Comment #26Amendment: Proposed MINHERS Addendum 29Page Number: 103.1.1 +Comment Intent: ObjectionComment Type: GeneralComment: Given the scope and complexity of the operations of high volume rating companies and providerships, implementation of financially independent third party QA is costly and difficult to carry out. Currently RESNET complaints regarding QA is a tiny fraction of a percent, which means that significant problems with the QA process do not exist. As is currently done by professional orgainizations including Doctors, Lawyers and Engineers among others, additional training and instruction of QA agents by RESNET would be a vast increase over the lack of training or consistency that exists in this space. Additionally more predictable software results across software used in modeling, would place all companies on the same page when reviewing inspection programs based upon software results. Qualified QA agents should be allowed to work wherever they may be contracted. RESNET should have greater involvement in the qualification of QA agents.
Given the scope and complexity of the operations of high volume rating companies and providerships, implementation of financially independent third party QA is costly and difficult to carry out.
Currently RESNET complaints regarding QA is a tiny fraction of a percent, which means that significant problems with the QA process do not exist.
As is currently done by professional orgainizations including Doctors, Lawyers and Engineers among others, additional training and instruction of QA agents by RESNET would be a vast increase over the lack of training or consistency that exists in this space. Additionally more predictable software results across software used in modeling, would place all companies on the same page when reviewing inspection programs based upon software results.
Qualified QA agents should be allowed to work wherever they may be contracted. RESNET should have greater involvement in the qualification of QA agents.
Comment #27Amendment: Proposed MINHERS Addendum 29Page Number: entire documentParagraph / Figure / Table / Note: allComment Intent: ObjectionComment Type: EditorialComment: It would be disastrous for RESNET to proceed with the changes proposed in this WD-01 Amendment given that the Pilot was unable to be successfully implemented, even in a scaled back and limited way. Without a proper trial of the ideas presented in this amendment, and an opportunity to make adjustments where they would be required, thrusting the proposed QA model on the entire Rating Industry would cause far more harm than any possible good. In light of the failure to demonstrate a viable way to implement “financial separation” and true third-party QA, the RESNET Board of Directors must reconsider the original policy that launched RESNET on this current path. I agree with another commenter’s proposal that mandating greater electronic collection of data, like will soon be possible for free for every Rater with EPA’s RaterPro (or equivalent), would create a database from which much better QA oversight can be done on ratings. Coupled with QA Genie’s automated review of ratings submitted to the RESNET Registry and the additional staff that RESNET is now authorized to hire, a strong step forward is being made to strengthen RESNET quality assurance oversight. Proposed Change: Strike all changes and go back to the drawing board. 103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for the rating work completed by third-party Rating Companies and/or whose staff conducts all or aany 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 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. 103.1.2.1 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, or contract with, willshall have no financial interest in the Direct Provider’s company, the Direct Provider’s employed including their Raters and Rating Company clients as well as, or any ratings completed by HERS Raters working with their Direct Provider clients. Quality Assurance Contractors and their Quality Agents may receive compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, and other non-HERS rating related services. 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. 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. 103.1.2.1.1 The 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 mayshall not perform quality assurance of the Direct Provider’s work. 103.1.3.1 An organization who is a Direct Rating Provider providing Third-Party Rating Quality Assurance services for a Rating company or another Direct Rating 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. 103.2 Third-party Rating Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider who does not receive fees for the rating and whose staff does not conduct any portion of the rating. 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. 103.2.1 Third-party 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 Providers and the Quality Agents they employ, or contract with, willshall have no financial interest in their HERS Rating Company clients, or any ratings completed by HERS Raters working with their HERS Rating Company clients. Quality Assurance Contractors and their Quality Agents may receive compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, and other non-HERS rating related services. 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. 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. 103.2.4 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. 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. 905.2.1 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 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 ten (10) homes and QA File reviews on a minimum of twenty (20) homes as either a Quality Assurance Designee or delegate (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; 905.2.2.13 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; 905.2.2.34 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 be active certified HERS Raters or RFI’s or perform any work on ratings;
It would be disastrous for RESNET to proceed with the changes proposed in this WD-01 Amendment given that the Pilot was unable to be successfully implemented, even in a scaled back and limited way. Without a proper trial of the ideas presented in this amendment, and an opportunity to make adjustments where they would be required, thrusting the proposed QA model on the entire Rating Industry would cause far more harm than any possible good.
In light of the failure to demonstrate a viable way to implement “financial separation” and true third-party QA, the RESNET Board of Directors must reconsider the original policy that launched RESNET on this current path.
I agree with another commenter’s proposal that mandating greater electronic collection of data, like will soon be possible for free for every Rater with EPA’s RaterPro (or equivalent), would create a database from which much better QA oversight can be done on ratings. Coupled with QA Genie’s automated review of ratings submitted to the RESNET Registry and the additional staff that RESNET is now authorized to hire, a strong step forward is being made to strengthen RESNET quality assurance oversight.
Strike all changes and go back to the drawing board.
103.1 Direct Rating Quality Assurance Provider (Direct Provider). A Rating Quality Assurance Provider who receives fees for the rating work completed by third-party Rating Companies and/or whose staff conducts all or aany 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 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. 103.1.2.1 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, or contract with, willshall have no financial interest in the Direct Provider’s company, the Direct Provider’s employed including their Raters and Rating Company clients as well as, or any ratings completed by HERS Raters working with their Direct Provider clients. Quality Assurance Contractors and their Quality Agents may receive compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, and other non-HERS rating related services. 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. 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. 103.1.2.1.1 The 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 mayshall not perform quality assurance of the Direct Provider’s work. 103.1.3.1 An organization who is a Direct Rating Provider providing Third-Party Rating Quality Assurance services for a Rating company or another Direct Rating 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. 103.2 Third-party Rating Quality Assurance Provider (Third-party Provider). A Rating Quality Assurance Provider who does not receive fees for the rating and whose staff does not conduct any portion of the rating. 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. 103.2.1 Third-party 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 Providers and the Quality Agents they employ, or contract with, willshall have no financial interest in their HERS Rating Company clients, or any ratings completed by HERS Raters working with their HERS Rating Company clients. Quality Assurance Contractors and their Quality Agents may receive compensation for services necessary for the fulfillment of the quality assurance requirements specified in these Standards, and other non-HERS rating related services. 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. 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. 103.2.4 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. 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. 905.2.1 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 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 ten (10) homes and QA File reviews on a minimum of twenty (20) homes as either a Quality Assurance Designee or delegate (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; 905.2.2.13 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; 905.2.2.34 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 be active certified HERS Raters or RFI’s or perform any work on ratings;
Return to Proposed MINHERS Addendum 29, Changes to Requirements for QA Agent Training and Financial Separation