Comment #1Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 1-3Paragraph / Figure / Table / Note: 1.2.4.4Comment Intent: ObjectionComment Type: EditorialComment: The use of the term "employ" could be interpreted that the QAD must be an employee of the provider Proposed Change: 102.4.4 Employ Utilize a Quality Assurance Designee to 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 a particular organization.
The use of the term "employ" could be interpreted that the QAD must be an employee of the provider
102.4.4 Employ Utilize a Quality Assurance Designee to 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 a particular organization.
Comment #2Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-3Paragraph / Figure / Table / Note: 904.3.2.2 and 904.3.2.5.2.1Comment Intent: ObjectionComment Type: GeneralComment: There are two sections that address QA File Review of sampled ratings which seem to be contradictory and may need clarification. The latter section 904.3.2.5.2.1 addresses QA of sample sets, but wouldn’t the 10% review of sampled ratings address this already? Saying that 1% of sample sets need QA seems redundant. I think a stronger statement for RESNET (that wouldn’t increase the file review load much) is to just say that 100% of sample sets require file QA. This means that 14% of sampled ratings get file QA (sample sets of 7 with the 1 tested unit always getting QA equates to 14%). The way this currently reads with 1% QA of sample sets, one could “QA” a non tested file in their 10% review and not have to really QA anything but the worst case file. This would set the industry back in a time we should be more stringent on QA of sampled ratings, particularly with increased Multifamily work. Proposed Change: 904.3.2.2 For each HERS Rater, the Provider’s Quality Assurance Designee shall be responsible for an annual QA File review of the greater of one (1) rating or ten percent (10%) of the HERS Rater's annual total of Confirmed or Sampled Ratings. When determining the number of ratings to review for a HERS Rater, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 ratings x 10% = 10.1 means that 11 ratings shall be reviewed. 904.3.2.5.2.1 QA File review of the sampling process shall be completed on the greater of one (1) sample set or one hundred percent (100%) of the HERS Rater's annual total of sample sets. When determining the number of sample sets to review for a HERS Rater, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 sample sets x 10% = 1.0.1 means that 2 11 sample sets shall be reviewed.
There are two sections that address QA File Review of sampled ratings which seem to be contradictory and may need clarification. The latter section 904.3.2.5.2.1 addresses QA of sample sets, but wouldn’t the 10% review of sampled ratings address this already? Saying that 1% of sample sets need QA seems redundant. I think a stronger statement for RESNET (that wouldn’t increase the file review load much) is to just say that 100% of sample sets require file QA. This means that 14% of sampled ratings get file QA (sample sets of 7 with the 1 tested unit always getting QA equates to 14%). The way this currently reads with 1% QA of sample sets, one could “QA” a non tested file in their 10% review and not have to really QA anything but the worst case file. This would set the industry back in a time we should be more stringent on QA of sampled ratings, particularly with increased Multifamily work.
904.3.2.2 For each HERS Rater, the Provider’s Quality Assurance Designee shall be responsible for an annual QA File review of the greater of one (1) rating or ten percent (10%) of the HERS Rater's annual total of Confirmed or Sampled Ratings. When determining the number of ratings to review for a HERS Rater, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 ratings x 10% = 10.1 means that 11 ratings shall be reviewed.
904.3.2.5.2.1 QA File review of the sampling process shall be completed on the greater of one (1) sample set or one hundred percent (100%) of the HERS Rater's annual total of sample sets. When determining the number of sample sets to review for a HERS Rater, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 sample sets x 10% = 1.0.1 means that 2 11 sample sets shall be reviewed.
Comment #3Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-4Paragraph / Figure / Table / Note: 904.3.3.1.2Comment Intent: Not an ObjectionComment Type: GeneralComment: When raters who do inspections and also utilize RFI’s, it is important that the rater also receives feedback on their field work. The way this section is worded in saying, “The RFI QA Field reviews may fulfill all or a portion of the HERS Rater’s annual QA Field review requirement.” could create a gap where a Rater doing field inspections would not be required to receive feedback on their field work if their RFI’s field QA covers their requirement. I believe an added statement to this section to cover raters who utilize RFI’s and also do field work, must receive QA on 1% of the ratings they did field work on would strengthen this section. Proposed Change: 904.3.3.1.2 Rating Field Inspectors. For HERS Raters utilizing RFI’s, the Quality Assurance Designee Agent shall ensure that a QA Field review is completed on the greater of one (1) rating on a completed home or one percent (1%) of each RFI’s annual total of confirmed or sampled ratings the RFI assisted with. If an RFI conducts a test or an inspection of any minimum rated feature on a rated home, that home is counted in the “annual total” of ratings used for the 1% calculation for that RFI. When determining the number of QA Field reviews to complete for an RFI, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 ratings x 1% = 1.01 means that 2 QA Field reviews shall be completed. The RFI QA Field reviews may fulfill all or a portion of the HERS Rater’s annual QA Field review requirement, but only if the HERS Rater does not do field inspections on completed homes. When a HERS Rater also does field inspections on completed homes, they must have field QA at the same calculated rate of 1% using the above methodologies.
When raters who do inspections and also utilize RFI’s, it is important that the rater also receives feedback on their field work. The way this section is worded in saying, “The RFI QA Field reviews may fulfill all or a portion of the HERS Rater’s annual QA Field review requirement.” could create a gap where a Rater doing field inspections would not be required to receive feedback on their field work if their RFI’s field QA covers their requirement. I believe an added statement to this section to cover raters who utilize RFI’s and also do field work, must receive QA on 1% of the ratings they did field work on would strengthen this section.
904.3.3.1.2 Rating Field Inspectors. For HERS Raters utilizing RFI’s, the Quality Assurance Designee Agent shall ensure that a QA Field review is completed on the greater of one (1) rating on a completed home or one percent (1%) of each RFI’s annual total of confirmed or sampled ratings the RFI assisted with. If an RFI conducts a test or an inspection of any minimum rated feature on a rated home, that home is counted in the “annual total” of ratings used for the 1% calculation for that RFI. When determining the number of QA Field reviews to complete for an RFI, round up to the next whole number when the percentage calculation yields a decimal point, e.g. 101 ratings x 1% = 1.01 means that 2 QA Field reviews shall be completed. The RFI QA Field reviews may fulfill all or a portion of the HERS Rater’s annual QA Field review requirement, but only if the HERS Rater does not do field inspections on completed homes. When a HERS Rater also does field inspections on completed homes, they must have field QA at the same calculated rate of 1% using the above methodologies.
Comment #4Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-9Paragraph / Figure / Table / Note: 904.3.5.5.1; 904.3.5.5.1.3Comment Intent: Not an ObjectionComment Type: EditorialComment: I find this section confusing with lots of room for interpretation. In some areas I feel like the references are confusing and in other areas need clarification on what is expected. This section could be interpreted in the strictest manner that the QAD has to determine 5% compliance on the total number of ratings for that rater. This is not feasible without requiring review of all ratings impacted by QA findings, which in turn could be interpreted that the QAD must dig through all of the rater’s files to find the total impact of the findings before they can determine the 5% threshold. This effort would be leading QAD’s down a rabbit hole of digging through potentially hundreds of files and would not be a very effective use of time in the effort of coaching raters. Assuming that the 5% non-compliance rate to trigger a “coaching plan” is really intended to mean that “5% of the reviews for a rater” I am proposing clarifications that more clearly spell this out. This would be more reasonable to expect and would direct the efforts of the QAD towards focusing on coaching the raters. Additionally the references to 904.4.5.5.2 and .3 are confusing to me and don’t provide any context for what “threshold” means. I will be commenting on this in another proposal, but in the meantime, I feel like those references do not add value to my understanding of this section and only add to my confusion. Therefore I’m proposing that those references be removed. Proposed Change: 904.3.5.5.1 When in the course of quality assurance review, as ratings outlined in 904.3.5.5.2 and 904.3.5.5.3, If in a twelve (12) month period from January 1st through December 31st, more than 5% of the results of a Rater’s total number of file and field QA reviews are found to be out of compliance by more than 5%, or the Quality Assurance Designee determines that field work (e.g. testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur: 904.3.5.5.1.3 When appropriate (e.g. the HERS Rater/RFI previously struggled with field compliance, a piece of equipment is used in the rating that is not commonly found in the market or used by a builder, field test results are out of typical range for the market, etc.), a an additional QA Field review shall be completed by the Quality Assurance Designee Agent to confirm that issues were addressed from the findings on the ratings reviews that were out of compliance by more than 5%;
I find this section confusing with lots of room for interpretation. In some areas I feel like the references are confusing and in other areas need clarification on what is expected.
This section could be interpreted in the strictest manner that the QAD has to determine 5% compliance on the total number of ratings for that rater. This is not feasible without requiring review of all ratings impacted by QA findings, which in turn could be interpreted that the QAD must dig through all of the rater’s files to find the total impact of the findings before they can determine the 5% threshold. This effort would be leading QAD’s down a rabbit hole of digging through potentially hundreds of files and would not be a very effective use of time in the effort of coaching raters. Assuming that the 5% non-compliance rate to trigger a “coaching plan” is really intended to mean that “5% of the reviews for a rater” I am proposing clarifications that more clearly spell this out. This would be more reasonable to expect and would direct the efforts of the QAD towards focusing on coaching the raters.
Additionally the references to 904.4.5.5.2 and .3 are confusing to me and don’t provide any context for what “threshold” means. I will be commenting on this in another proposal, but in the meantime, I feel like those references do not add value to my understanding of this section and only add to my confusion. Therefore I’m proposing that those references be removed.
904.3.5.5.1 When in the course of quality assurance review, as ratings outlined in 904.3.5.5.2 and 904.3.5.5.3, If in a twelve (12) month period from January 1st through December 31st, more than 5% of the results of a Rater’s total number of file and field QA reviews are found to be out of compliance by more than 5%, or the Quality Assurance Designee determines that field work (e.g. testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following, at a minimum, shall occur:
904.3.5.5.1.3 When appropriate (e.g. the HERS Rater/RFI previously struggled with field compliance, a piece of equipment is used in the rating that is not commonly found in the market or used by a builder, field test results are out of typical range for the market, etc.), a an additional QA Field review shall be completed by the Quality Assurance Designee Agent to confirm that issues were addressed from the findings on the ratings reviews that were out of compliance by more than 5%;
Comment #5Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-10Paragraph / Figure / Table / Note: 904.3.5.5.1; 904.3.5.5.2 and 904.3.5.5.3Comment Intent: Not an ObjectionComment Type: EditorialComment: The sections below have no context for what “threshold” means. I commented earlier on the 5% non compliance rate seeking clarification on whether the intent was to look at a non-compliance rate of more than 5% of “rating reviews” to trigger a coaching plan/probation. Assuming the intent truly is to look at how many reviews were non-compliant to determine the need for probation, I am proposing the changes below. I also feel like these two sections could be combined with 904.3.5.5.1 for better flow and comprehension of the full picture. I’m proposing that 904.3.5.5.1 provide these separate sections as “exceptions” to 904.3.5.5.1. I have also included my previous proposal for 904.3.5.5.1 Proposed Change: 904.3.5.5.1 When in the course of quality assurance review, as ratings outlined in 904.3.5.5.2 and 904.3.5.5.3, If in a twelve (12) month period from January 1st through December 31st, more than 5% of the results of a Rater’s total number of file and field QA reviews are found to be out of compliance by more than 5%, or the Quality Assurance Designee determines that field work (e.g. testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following a coaching plan per 904.3.5.5.1.1 to 904.3.5.5.1.4, at a minimum, shall occur. Exceptions >>>>Move section 904.3.5.5.2 up in standard to be below section 904.3.5.5.1 for better flow in reading of the standard 904.3.5.5.2 Raters and RFI’s who performed work on fewer than 100 homes per year in the prior or current twelve (12) month period from January 1st through December 31st the threshold for determining the need for probation with a coaching plan per section 904.4.5.5.1 to 904.3.5.5.1.4 shall be “two (2) or more ratings non-compliant reviews”; 904.3.5.5.3 Raters and RFI’s who performed work on 100 homes or greater per year in the prior or current twelve (12) month period from January 1st through December 31st, the threshold for determining the need for probation with a coaching plan per section 904.4.5.5.1 shall be “three (3) or more non-compliant ratings reviews or 15% of ratings reviews, whichever is greater”; In case it helps to clarify the intended plain english reading I've patsed my proposed language here: 904.3.5.5.1 If in a twelve (12) month period from January 1st through December 31st, more than 5% of the results of a Rater’s total number of file and field QA reviews are found to be out of compliance, or the Quality Assurance Designee determines that field work (e.g. testing or inspections of minimum rated features) is being completed inaccurately or incompletely, a coaching plan per 904.3.5.5.1.1 to 904.3.5.5.1.4, at a minimum, shall occur. Exceptions Raters and RFI’s who performed work on fewer than 100 homes per year, the threshold for determining the need for probation with a coaching plan per section 904.4.5.5.1 to 904.3.5.5.1.4, shall be “two (2) or more non-compliant reviews”; Raters and RFI’s who performed work on 100 homes or greater, the threshold for determining the need for probation with a coaching plan per section 904.4.5.5.1 shall be “three (3) or more non-compliant reviews or 5% of reviews, whichever is greater”;
The sections below have no context for what “threshold” means. I commented earlier on the 5% non compliance rate seeking clarification on whether the intent was to look at a non-compliance rate of more than 5% of “rating reviews” to trigger a coaching plan/probation. Assuming the intent truly is to look at how many reviews were non-compliant to determine the need for probation, I am proposing the changes below.
I also feel like these two sections could be combined with 904.3.5.5.1 for better flow and comprehension of the full picture. I’m proposing that 904.3.5.5.1 provide these separate sections as “exceptions” to 904.3.5.5.1. I have also included my previous proposal for 904.3.5.5.1
904.3.5.5.1 When in the course of quality assurance review, as ratings outlined in 904.3.5.5.2 and 904.3.5.5.3, If in a twelve (12) month period from January 1st through December 31st, more than 5% of the results of a Rater’s total number of file and field QA reviews are found to be out of compliance by more than 5%, or the Quality Assurance Designee determines that field work (e.g. testing or inspections of minimum rated features) is being completed inaccurately or incompletely, the following a coaching plan per 904.3.5.5.1.1 to 904.3.5.5.1.4, at a minimum, shall occur.
Exceptions
>>>>Move section 904.3.5.5.2 up in standard to be below section 904.3.5.5.1 for better flow in reading of the standard
904.3.5.5.2 Raters and RFI’s who performed work on fewer than 100 homes per year in the prior or current twelve (12) month period from January 1st through December 31st the threshold for determining the need for probation with a coaching plan per section 904.4.5.5.1 to 904.3.5.5.1.4 shall be “two (2) or more ratings non-compliant reviews”; 904.3.5.5.3 Raters and RFI’s who performed work on 100 homes or greater per year in the prior or current twelve (12) month period from January 1st through December 31st, the threshold for determining the need for probation with a coaching plan per section 904.4.5.5.1 shall be “three (3) or more non-compliant ratings reviews or 15% of ratings reviews, whichever is greater”;
In case it helps to clarify the intended plain english reading I've patsed my proposed language here:
904.3.5.5.1 If in a twelve (12) month period from January 1st through December 31st, more than 5% of the results of a Rater’s total number of file and field QA reviews are found to be out of compliance, or the Quality Assurance Designee determines that field work (e.g. testing or inspections of minimum rated features) is being completed inaccurately or incompletely, a coaching plan per 904.3.5.5.1.1 to 904.3.5.5.1.4, at a minimum, shall occur.
Exceptions Raters and RFI’s who performed work on fewer than 100 homes per year, the threshold for determining the need for probation with a coaching plan per section 904.4.5.5.1 to 904.3.5.5.1.4, shall be “two (2) or more non-compliant reviews”;
Raters and RFI’s who performed work on 100 homes or greater, the threshold for determining the need for probation with a coaching plan per section 904.4.5.5.1 shall be “three (3) or more non-compliant reviews or 5% of reviews, whichever is greater”;
Comment #6Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-11Paragraph / Figure / Table / Note: 904.4.2.8 of original draftComment Intent: ObjectionComment Type: TechnicalComment: EnergyLogic commented in the last round of public comments to not take QA Events out of the QA Standard. Since we didn't get a sufficient response, I wanted to propose this in the latest round, hoping that in the years since the last round of public comment that the new committee might agree with our logic. The QA Event has been used by EnergyLogic not out of necessity, but out of the value it provides to our raters in determining areas of inconsistency. A distinction should be made here. We are not proposing this QA event strictly to save time and money. In fact it takes almost as much time to do a QA Event, when you consider all the logistics it takes to line up a house to be available all day, that meets the criteria for a good QA house, and then coordinating dates with attendees to be there. All this added time is traded off with a reduced travel burdens on the QAD but this does not reduce cost to raters who have to line up travels. The real value is in having a group of raters perform a rating on the same home and comparing those results to see how they differ. Given the light that has been shed on inconsistencies amongst raters in these types of events, we believe RESNET should support future efforts along these lines and allow these events to count towards annual QA requirements. This event has a clarifying effect on how inconsistent raters can be, and sheds light for areas of improvement in a rating company. Just like QA of pre-drywall inspections has been a best practice, but not performed unless it was convenient, the QA Event could suffer the same fate if it were to not be counted as field QA in the standard. Ultimately more frequent use of this event could help the industry achieve greater consistency. By recognizing this event RESNET could help shine a brighter light on those areas of inconsistency between raters. Leaving this event intact in the standard (for those who qualify) would ultimately help maintain the credible and informative process of finding inconsistencies. Last but not least, taking a more scientific approach using the scientific method, the QA Event is more like a scientific research project. By having a group of raters (the independent variables) all do a rating on the same house, we take away all the many variable in different homes and have a constant (control) in our comparison of rater’s results. Achieving greater consistency is the goal here and there is no better way to evaluate this than using a more scientific approach to QA such as a QA Event. Proposed Change: Please do not strike 904.4.2.8. Pasted as drafted in it's current form 904.4.2.8 If a QA Designee is required to complete an onsite QA inspection on at least two (2) homes for a given Rater, the QA Designee may use one centralized – proctored rating QA event, and only one, for review of the Rater in lieu of an independent confirmation of the rating for the home as required for the balance of homes evaluated for the onsite inspection process. 904.4.2.8.1 A centralized proctored rating QA event is defined as a rating that occurs at a house assigned by the QA Designee at which the QA Designee, or their Delegate, must be onsite to ensure that the Rater being reviewed is working completely independently to gather all aspects of the minimum rated features of a home. The Rater being reviewed will not be allowed to communicate by any means with others while gathering information in the home or creating their rating software file and report. The review shall include, but is not limited to, the following: 1. Diagnostic equipment set-up and testing measurements 2. Insulation evaluation and R-value determination 3. Calculations of gross areas, volumes, and square footage of the home 4. Input and creation of the software rating file and reports 904.4.2.8.2 QA under this Section shall adhere to the same variance allowances provided for in Section 904.4.2.5.
EnergyLogic commented in the last round of public comments to not take QA Events out of the QA Standard. Since we didn't get a sufficient response, I wanted to propose this in the latest round, hoping that in the years since the last round of public comment that the new committee might agree with our logic.
The QA Event has been used by EnergyLogic not out of necessity, but out of the value it provides to our raters in determining areas of inconsistency. A distinction should be made here. We are not proposing this QA event strictly to save time and money. In fact it takes almost as much time to do a QA Event, when you consider all the logistics it takes to line up a house to be available all day, that meets the criteria for a good QA house, and then coordinating dates with attendees to be there. All this added time is traded off with a reduced travel burdens on the QAD but this does not reduce cost to raters who have to line up travels. The real value is in having a group of raters perform a rating on the same home and comparing those results to see how they differ. Given the light that has been shed on inconsistencies amongst raters in these types of events, we believe RESNET should support future efforts along these lines and allow these events to count towards annual QA requirements. This event has a clarifying effect on how inconsistent raters can be, and sheds light for areas of improvement in a rating company. Just like QA of pre-drywall inspections has been a best practice, but not performed unless it was convenient, the QA Event could suffer the same fate if it were to not be counted as field QA in the standard. Ultimately more frequent use of this event could help the industry achieve greater consistency. By recognizing this event RESNET could help shine a brighter light on those areas of inconsistency between raters. Leaving this event intact in the standard (for those who qualify) would ultimately help maintain the credible and informative process of finding inconsistencies. Last but not least, taking a more scientific approach using the scientific method, the QA Event is more like a scientific research project. By having a group of raters (the independent variables) all do a rating on the same house, we take away all the many variable in different homes and have a constant (control) in our comparison of rater’s results. Achieving greater consistency is the goal here and there is no better way to evaluate this than using a more scientific approach to QA such as a QA Event.
Please do not strike 904.4.2.8. Pasted as drafted in it's current form
904.4.2.8 If a QA Designee is required to complete an onsite QA inspection on at least two (2) homes for a given Rater, the QA Designee may use one centralized – proctored rating QA event, and only one, for review of the Rater in lieu of an independent confirmation of the rating for the home as required for the balance of homes evaluated for the onsite inspection process.
904.4.2.8.1 A centralized proctored rating QA event is defined as a rating that occurs at a house assigned by the QA Designee at which the QA Designee, or their Delegate, must be onsite to ensure that the Rater being reviewed is working completely independently to gather all aspects of the minimum rated features of a home. The Rater being reviewed will not be allowed to communicate by any means with others while gathering information in the home or creating their rating software file and report. The review shall include, but is not limited to, the following:
1. Diagnostic equipment set-up and testing measurements 2. Insulation evaluation and R-value determination 3. Calculations of gross areas, volumes, and square footage of the home 4. Input and creation of the software rating file and reports
904.4.2.8.2 QA under this Section shall adhere to the same variance allowances provided for in Section 904.4.2.5.
Comment #7Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 25Paragraph / Figure / Table / Note: 904.3.3.2.4Comment Intent: ObjectionComment Type: GeneralComment: This section reads: “904.3.3.2.4 Each rating selected for a QA Field review for each HERS Rater and RFI shall be randomly selected to ensure that a representative sample of all home types, locations and builders is achieved. “ Randomly selected ratings can be impossible in certain situations. Many raters in the industry are low volume and therefore have few options for Field QA reviews. Add to that the fact that many raters’ providers are out of town or out of state, so significant planning and communication is required to schedule access to the rated homes. I appreciate the sentiment and I do believe in the power of blind QA reviews (when possible) but I do not think it is appropriate to have language in the standard to require something that is not always achievable. Random selection where a rater does not know which homes will be selected for QA is an important aspect of the integrity of the QA process. If a rater knows which homes will be selected, then there is no checks and balances in their daily operations. It is easier to cut corners if a rater knows that they get to choose the QA house. Random remote QA and random file QA can solve this issue and provide for a stronger QA program for RESNET. I think the root issue is that low volume raters and high volume raters have drastically different business models and processes. You could argue two sides of this coin; a) that low volume raters have less experience and therefore need the QA more than high volume raters b) low volume raters have more time to spend on each rating so their work should be less rushed and of higher quality. Neither are true 100% of the time. If you want a low volume rater to get valuable blind QA, give them an alternative. File QA, on the other hand is very easy to do blindly regardless of where a rater’s provider is located. I suggest requiring raters with less than 100 ratings per calendar year to increase their File QA to 50% and require 2% remote QA to satisfy their yearly QA requirements. I believe that the resultant large increase in File QA would meet the intent and exceed the effectiveness of 1% Field QA reviews for raters with less than 100 ratings, by spreading out the feedback throughout the year and requiring more stringent rates of QA without overburdening QADs with logistics of travel. This is already a struggle for QAD's who use delegates and will be even more of a logistical nightmare without the availability of delegates in the new standard. The logistics of scheduling during a rater’s, builder’s, and QAD’s small windows of opportunity on a small set of homes can take a lot of time and effort from the rater and QAD. The focus then becomes, what house is easiest to get into, rather then random selection and providing valuable feedback along the way. The amendment changes that are coming to increase the consistency and better define the Quality Assurance Data File and allowences for remote QA, will drastically improve the effectiveness of File and field QA reviews. I fully believe that this low volume rater Field QA alternative path will enhance oversight and not weaken it, as it touches more ratings and creates a pathway for random selection. Proposed Change: 904.3.3.2.4 Each rating selected for a QA Field review for each HERS Rater and RFI shall be randomly selected to ensure that a representative sample of all home types, locations and builders is achieved. If a HERS Rater will perform less than 100 ratings in a calendar year, that rater’s QAD may complete additional random File QA reviews at a rate of 50% and random 2% remote QA to meet the intent of random selection. This alternative pathway may replace the on site QA requirements for raters who qualify, but may not be used in consecutive years for the same rater.
This section reads:
“904.3.3.2.4 Each rating selected for a QA Field review for each HERS Rater and RFI shall be randomly selected to ensure that a representative sample of all home types, locations and builders is achieved. “
Randomly selected ratings can be impossible in certain situations. Many raters in the industry are low volume and therefore have few options for Field QA reviews. Add to that the fact that many raters’ providers are out of town or out of state, so significant planning and communication is required to schedule access to the rated homes. I appreciate the sentiment and I do believe in the power of blind QA reviews (when possible) but I do not think it is appropriate to have language in the standard to require something that is not always achievable. Random selection where a rater does not know which homes will be selected for QA is an important aspect of the integrity of the QA process. If a rater knows which homes will be selected, then there is no checks and balances in their daily operations. It is easier to cut corners if a rater knows that they get to choose the QA house. Random remote QA and random file QA can solve this issue and provide for a stronger QA program for RESNET.
I think the root issue is that low volume raters and high volume raters have drastically different business models and processes. You could argue two sides of this coin; a) that low volume raters have less experience and therefore need the QA more than high volume raters b) low volume raters have more time to spend on each rating so their work should be less rushed and of higher quality. Neither are true 100% of the time. If you want a low volume rater to get valuable blind QA, give them an alternative. File QA, on the other hand is very easy to do blindly regardless of where a rater’s provider is located.
I suggest requiring raters with less than 100 ratings per calendar year to increase their File QA to 50% and require 2% remote QA to satisfy their yearly QA requirements. I believe that the resultant large increase in File QA would meet the intent and exceed the effectiveness of 1% Field QA reviews for raters with less than 100 ratings, by spreading out the feedback throughout the year and requiring more stringent rates of QA without overburdening QADs with logistics of travel. This is already a struggle for QAD's who use delegates and will be even more of a logistical nightmare without the availability of delegates in the new standard. The logistics of scheduling during a rater’s, builder’s, and QAD’s small windows of opportunity on a small set of homes can take a lot of time and effort from the rater and QAD. The focus then becomes, what house is easiest to get into, rather then random selection and providing valuable feedback along the way.
The amendment changes that are coming to increase the consistency and better define the Quality Assurance Data File and allowences for remote QA, will drastically improve the effectiveness of File and field QA reviews. I fully believe that this low volume rater Field QA alternative path will enhance oversight and not weaken it, as it touches more ratings and creates a pathway for random selection.
904.3.3.2.4 Each rating selected for a QA Field review for each HERS Rater and RFI shall be randomly selected to ensure that a representative sample of all home types, locations and builders is achieved. If a HERS Rater will perform less than 100 ratings in a calendar year, that rater’s QAD may complete additional random File QA reviews at a rate of 50% and random 2% remote QA to meet the intent of random selection. This alternative pathway may replace the on site QA requirements for raters who qualify, but may not be used in consecutive years for the same rater.
Comment #8Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-8Paragraph / Figure / Table / Note: 904.3.5.5.3Comment Intent: Not an ObjectionComment Type: GeneralComment: Will the existing language of item 904.3.5.5.3 be fully replaced w/ new red / underlined 904.3.5.5.3 language or just renumbered accordingly? It appears previous comments above have expressed a request for clarification or changes in PDS-01 language that is not up for discussion w/ Addendum 30 / PDS - 01,
Will the existing language of item 904.3.5.5.3 be fully replaced w/ new red / underlined 904.3.5.5.3 language or just renumbered accordingly?
It appears previous comments above have expressed a request for clarification or changes in PDS-01 language that is not up for discussion w/ Addendum 30 / PDS - 01,
Comment #9Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 1-9Paragraph / Figure / Table / Note: 103.2.3Comment Intent: ObjectionComment Type: EditorialComment: This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 350 Raters and 11 Providers from New Jersey to Maine. The meaning of "all governing documents" is unclear and language addressing the ability of a Provider to avoid disclosure of proprietary information has been removed. We would object to RESNET making public any proprietary information relating to internal policies, processes and procedures associated with a Providef's application. This information is often a result of a considerable investment on the behalf of an applicant. It would not be right for a competitor to have access to this information. Proposed Change: all governing documents shall be made public. Proprietary information relating to internal HERS Rating procedures, processes and policies will not be considered governing documents and will not be made public.
This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 350 Raters and 11 Providers from New Jersey to Maine.
The meaning of "all governing documents" is unclear and language addressing the ability of a Provider to avoid disclosure of proprietary information has been removed. We would object to RESNET making public any proprietary information relating to internal policies, processes and procedures associated with a Providef's application. This information is often a result of a considerable investment on the behalf of an applicant. It would not be right for a competitor to have access to this information.
all governing documents shall be made public. Proprietary information relating to internal HERS Rating procedures, processes and policies will not be considered governing documents and will not be made public.
Comment #10Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-5Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: EditorialComment: In 904.3.3.1.3 Pre-drywall QA Field reviews, the example no longer aligns with the section language that states that pre-drywall QA is optional and can be counted for up to 25% of requried QA Field reviews. Propsoed revision below tries to reaalign the example as to avoid confusion. Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Assurance Designee may perform a pre-drywall QA Field review on each HERS Rater or RFI. Pre-drywall QA Field reviews can be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and can replace 10%, but no more than 25%, of the total number of QA Field reviews (rounded up). For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review can be on a completed home and one (1) additional QA Field review can be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field reviews may be performed and can count towards one, but no more than onethree, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviews may be performed and they can count towards two, but no more than two, of the QA Field reviews.
In 904.3.3.1.3 Pre-drywall QA Field reviews, the example no longer aligns with the section language that states that pre-drywall QA is optional and can be counted for up to 25% of requried QA Field reviews. Propsoed revision below tries to reaalign the example as to avoid confusion.
904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Assurance Designee may perform a pre-drywall QA Field review on each HERS Rater or RFI. Pre-drywall QA Field reviews can be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and can replace 10%, but no more than 25%, of the total number of QA Field reviews (rounded up).
For example, if a HERS Rater or RFI is required to have one (1) QA Field review, one (1) review can be on a completed home and one (1) additional QA Field review can be on the same or a different home before drywall is installed. If a HERS Rater or RFI is required to have two (2) to ten (10) QA Field reviews, one (1) pre-drywall QA Field reviews may be performed and can count towards one, but no more than onethree, of the QA Field reviews. If a HERS Rater or RFI is required to have eleven (11) or more QA Field reviews, two (2) pre-drywall QA Field reviews may be performed and they can count towards two, but no more than two, of the QA Field reviews.
Comment #11Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-6Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: Not an ObjectionComment Type: EditorialComment: This comment is being issued on behalf of the Standards Committee of the North East Home Energy Rating Alliance, which represents more than 350 Raters and 11 Providers from New Jersey to Maine. The ability to conduct QA Field Reviews using remote” QA Field review methodology appears to be a reversal of the current requirement that the "QA Designee shall ensure that the minimum rated features of a rating are independently confirmed". Although we do not object to this change in focus of QA, we want to clarify that this is an intentional rather than unintentional result of this change.
The ability to conduct QA Field Reviews using remote” QA Field review methodology appears to be a reversal of the current requirement that the "QA Designee shall ensure that the minimum rated features of a rating are independently confirmed". Although we do not object to this change in focus of QA, we want to clarify that this is an intentional rather than unintentional result of this change.
Comment #12Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-5Paragraph / Figure / Table / Note: 904.3.3.1.3Comment Intent: ObjectionComment Type: TechnicalComment: For new construction homes and apartments, which represent the majority of dwellings Rated using the HERS Index, the many minimum rated features can only be verified and thus QA'ed at predrywall. The items such as the envelope that can only be verified and QA'ed at predrywall also have some of hte greatest impact on the Rating produced. As such, minimum QA on Raters and RFIs should at a minimum include some level of QA oversight for predrywall inspections. Making predrywall QA optional ensures that HERS Index will have virtually the same amount of variablilty that exists today. Not addressing the volutility in the HERS Index dooms it to irrelivance in the CODE world as forces are already mustering to remove ERI from the IECC on the 2021 Code cycle solely in response to the question of consistent, reproducable Ratings and the variability that currently exiss. Proposed Change: 904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Assurance Designee Agent may shall perform shall ensure that a pre-drywall QA Field review is completedon a minimum of one (1) home foreach HERS Rater or RFI. Pre-drywall QA Field reviews shallcan be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shallcan replace 10%, but no more than 1025%, of the total number of QA Field reviews (rounded up).
For new construction homes and apartments, which represent the majority of dwellings Rated using the HERS Index, the many minimum rated features can only be verified and thus QA'ed at predrywall. The items such as the envelope that can only be verified and QA'ed at predrywall also have some of hte greatest impact on the Rating produced. As such, minimum QA on Raters and RFIs should at a minimum include some level of QA oversight for predrywall inspections. Making predrywall QA optional ensures that HERS Index will have virtually the same amount of variablilty that exists today. Not addressing the volutility in the HERS Index dooms it to irrelivance in the CODE world as forces are already mustering to remove ERI from the IECC on the 2021 Code cycle solely in response to the question of consistent, reproducable Ratings and the variability that currently exiss.
904.3.3.1.3 Pre-drywall QA Field reviews. In addition to QA Field reviews on completed homes, for ratings on new homes, the Quality Assurance Designee Agent may shall perform shall ensure that a pre-drywall QA Field review is completedon a minimum of one (1) home foreach HERS Rater or RFI. Pre-drywall QA Field reviews shallcan be used to meet the 1% QA Field review requirement for a HERS Rater or RFI in addition to the QA Field reviews on completed homes, and shallcan replace 10%, but no more than 1025%, of the total number of QA Field reviews (rounded up).
Comment #13Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-6Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: EditorialComment: The inclusion of remote QA Field Reviews is a really good and important addition to the RESNET Standards. Cuddos to whomever thought of this. The language in this section needs to be improved though after the proposed edits in order to be less confusing. As written it requires a QA for every rater and RFI, even those who have not actually conducted a Rating. The change below strives to address this and align it with earler section of the Standard. Proposed Change: 904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings they assisted with.. All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET.
The inclusion of remote QA Field Reviews is a really good and important addition to the RESNET Standards. Cuddos to whomever thought of this. The language in this section needs to be improved though after the proposed edits in order to be less confusing. As written it requires a QA for every rater and RFI, even those who have not actually conducted a Rating. The change below strives to address this and align it with earler section of the Standard.
904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings they assisted with.. All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET.
Comment #14Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-6Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: EditorialComment: The inclusion of remote QA Field Reviews is a really good and important addition to the RESNET Standards. Cuddos to whomever thought of this. The language in this section needs to be improved though after the proposed edits in order to be less confusing. As written it requires a QA for every rater and RFI, even those who have not actually conducted a Rating. The change below strives to address this and align it with earler section of the Standard. Proposed Change: 904.3.3.1.5 “Remote” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) QA Field reviews on one percent (1%) of the annual total of confirmed or sampled ratings they assisted with.. All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “remote” QA Field review methodology specified by RESNET.
Comment #15Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 1-2Paragraph / Figure / Table / Note: 102.3.3Comment Intent: ObjectionComment Type: EditorialComment: This statement is not in aligment with previous settled Board policy on transitioning rating software versions. Are you really intending on changing this again? If not, i recommend you keep what's aleady there. Proposed Change: 102.3.3 Ensure HERS Raters under their providership use the latest version of RESNET accredited software tools to produce ratings and provide notification within 30 days of any software changes. 102.3.3 Rating Software Changes When RESNET Accredited Software programs release a new version users of RESNET Accredited Software, shall be required to transition to the new version based on the following schedule: 103.3.3.1 Confirmed or Sampled Ratings on homes with a building permit date that is on or after the 6 month anniversary of the release of the software must utilize the newly released software. 103.3.3.2 Homes with a building permit date before the 6 month anniversary of the release of the software shall be allowed to complete a Confirmed or Sampled Rating based on the previous version of the software that was utilized for the Projected Rating. 103.3.3.3 The RESNET Board of Directors may stipulate a timeframe other than the 6 month anniversary of the building permit date.
This statement is not in aligment with previous settled Board policy on transitioning rating software versions. Are you really intending on changing this again? If not, i recommend you keep what's aleady there.
102.3.3 Ensure HERS Raters under their providership use the latest version of RESNET accredited software tools to produce ratings and provide notification within 30 days of any software changes.
102.3.3 Rating Software Changes
When RESNET Accredited Software programs release a new version users of RESNET Accredited Software, shall be required to transition to the new version based on the following schedule:
103.3.3.1 Confirmed or Sampled Ratings on homes with a building permit date that is on or after the 6 month anniversary of the release of the software must utilize the newly released software.
103.3.3.2 Homes with a building permit date before the 6 month anniversary of the release of the software shall be allowed to complete a Confirmed or Sampled Rating based on the previous version of the software that was utilized for the Projected Rating.
103.3.3.3 The RESNET Board of Directors may stipulate a timeframe other than the 6 month anniversary of the building permit date.
Comment #16Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 1-2Paragraph / Figure / Table / Note: 102.3.5Comment Intent: ObjectionComment Type: GeneralComment: This is a software report issue, not a QA Provider issue. To me this just gums up the document with unnecessary language. Delete. Proposed Change: 102.3.5 Require that Rated Home Registration ID’s provided by the National RESNET Registry are prominently displayed on all Rating Certifications.
This is a software report issue, not a QA Provider issue. To me this just gums up the document with unnecessary language. Delete.
102.3.5 Require that Rated Home Registration ID’s provided by the National RESNET Registry are prominently displayed on all Rating Certifications.
Comment #17Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 1-1Paragraph / Figure / Table / Note: 102.3Comment Intent: ObjectionComment Type: GeneralComment: Seems unnecesssary to say "direct" and "third party" providers here given that there are no rules in this standard that differentiate the roles and scopes of the two types of Providers, meaning the rules apear to be the same. II'm not even sure it is still necessary to define TP vs Direct provider in the standard becauseJthere is no clear distintction in their role and scope per tihs standard. Proposed Change: 102.3 Rating Quality Assurance Provider Responsibilities. All accredited Direct and Third-Party Home Energy Rating Quality Assurance Providers shall have the following minimum responsibilities:
Seems unnecesssary to say "direct" and "third party" providers here given that there are no rules in this standard that differentiate the roles and scopes of the two types of Providers, meaning the rules apear to be the same. II'm not even sure it is still necessary to define TP vs Direct provider in the standard becauseJthere is no clear distintction in their role and scope per tihs standard.
102.3 Rating Quality Assurance Provider Responsibilities. All accredited Direct and Third-Party Home Energy Rating Quality Assurance Providers shall have the following minimum responsibilities:
Comment #18Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 1-1Paragraph / Figure / Table / Note: 102.3.1Comment Intent: ObjectionComment Type: GeneralComment: This is confusing... why are you saying that Providers are performing QA from this section of the standard in addition to Chapter 9, when this section does not have any specific provisions for QA Delete of make more clear what you're asking people to do. Keeping records and invesigating complaints is not performing QA. Proposed Change: 102.3.1 Perform sufficient quality assurance oversight of HERS Raters and Rating Field Inspectors (RFI’s) to ensure compliance with these Standards and the minimum quality assurance requirements outlined in Chapter 9. This oversight is in addition to the oversight performed by RESNET and quality assurance performed by Quality Assurance Designees of RESNET defined in Chapter 9 of these Standards.
This is confusing... why are you saying that Providers are performing QA from this section of the standard in addition to Chapter 9, when this section does not have any specific provisions for QA Delete of make more clear what you're asking people to do. Keeping records and invesigating complaints is not performing QA.
102.3.1 Perform sufficient quality assurance oversight of HERS Raters and Rating Field Inspectors (RFI’s) to ensure compliance with these Standards and the minimum quality assurance requirements outlined in Chapter 9. This oversight is in addition to the oversight performed by RESNET and quality assurance performed by Quality Assurance Designees of RESNET defined in Chapter 9 of these Standards.
Comment #19Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 1-2Paragraph / Figure / Table / Note: 102.3.6Comment Intent: ObjectionComment Type: GeneralComment: What if a Provider cannot "resolve" a compliant, becuase the rater fails to follow through? Needs better language Proposed Change: 102.3.6 Investigate and attempt to resolve formal complaints issued to the Provider regarding any affiliated HERS Rater or Rating Field Inspector who works compliance complaints.
What if a Provider cannot "resolve" a compliant, becuase the rater fails to follow through? Needs better language
102.3.6 Investigate and attempt to resolve formal complaints issued to the Provider regarding any affiliated HERS Rater or Rating Field Inspector who works compliance complaints.
Comment #20Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 1-3Paragraph / Figure / Table / Note: 102.4.2Comment Intent: ObjectionComment Type: EditorialComment: This is bad grammar. Please edit as follows Proposed Change: 102.4.2 To apply for accreditation as a RESNET Rating Quality Assurance Provider, applicants must complete an accreditation application developed by RESNET and which includes a certificate of completion from the RESNET training for new Providers referenced in 103.4.1.
This is bad grammar. Please edit as follows
102.4.2 To apply for accreditation as a RESNET Rating Quality Assurance Provider, applicants must complete an accreditation application developed by RESNET and which includes a certificate of completion from the RESNET training for new Providers referenced in 103.4.1.
Comment #21Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 1-3Paragraph / Figure / Table / Note: 102.4.4Comment Intent: ObjectionComment Type: GeneralComment: What "other Provider categories" are you referring to? Sampling? I don't see any other types of providers in this standard other than just QA Providers.If you're not intentionally trying to keep it open for future different types of Providers that could be invented, I'd keep this specific Proposed Change: 102.4.4 Employ a Quality Assurance Designee to oversee the Provider’s compliance with Chapter 9 of these Standards and those associated with RESNET Sampling, where the QA Provider is also a RESNET Sampling Provider. any specific Quality Assurance requirements for other Provider categories that may apply to a particular organization.
What "other Provider categories" are you referring to? Sampling? I don't see any other types of providers in this standard other than just QA Providers.If you're not intentionally trying to keep it open for future different types of Providers that could be invented, I'd keep this specific
102.4.4 Employ a Quality Assurance Designee to oversee the Provider’s compliance with Chapter 9 of these Standards and those associated with RESNET Sampling, where the QA Provider is also a RESNET Sampling Provider. any specific Quality Assurance requirements for other Provider categories that may apply to a particular organization.
Comment #22Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 1-5Paragraph / Figure / Table / Note: 102.4.9.3.1.2Comment Intent: ObjectionComment Type: GeneralComment: Being put on Probation for having lapsed eequipment calibration is too stringent. Allow the Provider to use Administrative Suspension as an alernative. Proposed Change: 1032.4.9.3.1.2 Noncompliance with equipment calibration requirements; Non-compliance with this item may also be recorded in the RESNET Natinoal Registry as "Suspension - Admin"
Being put on Probation for having lapsed eequipment calibration is too stringent. Allow the Provider to use Administrative Suspension as an alernative.
1032.4.9.3.1.2 Noncompliance with equipment calibration requirements; Non-compliance with this item may also be recorded in the RESNET Natinoal Registry as "Suspension - Admin"
Comment #23Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 1-5Paragraph / Figure / Table / Note: 102.4.9.3.1.3Comment Intent: ObjectionComment Type: GeneralComment: What is magic about "four ratings" being affected by any change? This seems like it could be broadly interpreted as a rater who makes a mistake that otherwise has little effect on the accuracy of the rating but techincally was not right... if such an issue occured on 4 ratings then they're busted. Whereas a rater can have flagrantly bad ratings on 3 homes and presumably they're not subject to Probation? This just comes off as a poorly thought out, made up number. Please either delete or make it more meaningful. Proposed Change: 102.4.9.3.1.3 Discovered violations of one or more provisions of the RESNET Standards that result in four or more non-compliant ratings submitted to the RESNET National Registry with significant deviations on the HERS Index (ie, >2 Index points), or which appear to intentionally misrepresent any minimum rated feature for the purpose of improving the rating outcome. for a calendar year, i.e. the twelve month period from January 1st through December 31st;
What is magic about "four ratings" being affected by any change? This seems like it could be broadly interpreted as a rater who makes a mistake that otherwise has little effect on the accuracy of the rating but techincally was not right... if such an issue occured on 4 ratings then they're busted. Whereas a rater can have flagrantly bad ratings on 3 homes and presumably they're not subject to Probation?
This just comes off as a poorly thought out, made up number. Please either delete or make it more meaningful.
102.4.9.3.1.3 Discovered violations of one or more provisions of the RESNET Standards that result in four or more non-compliant ratings submitted to the RESNET National Registry with significant deviations on the HERS Index (ie, >2 Index points), or which appear to intentionally misrepresent any minimum rated feature for the purpose of improving the rating outcome. for a calendar year, i.e. the twelve month period from January 1st through December 31st;
Comment #24Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 1-6Paragraph / Figure / Table / Note: 102.4.9.3.2.5Comment Intent: Not an ObjectionComment Type: EditorialComment: This is repeated from the same statement under Probation. How can the same issue be cause for both probation ans suspension? Delete Proposed Change: 102.4.9.3.2.5 Misrepresentation of a certification status in marketing materials, or services offered or actually provided, for which the HERS Rater does not possess the appropriate RESNET certification from the Provider.
This is repeated from the same statement under Probation. How can the same issue be cause for both probation ans suspension? Delete
102.4.9.3.2.5 Misrepresentation of a certification status in marketing materials, or services offered or actually provided, for which the HERS Rater does not possess the appropriate RESNET certification from the Provider.
Comment #25Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-1Paragraph / Figure / Table / Note: 903.3Comment Intent: ObjectionComment Type: GeneralComment: This is a misleaading statement. This evokes the same concern people had 5 years ago of RESNET trying to "take over" performing QA. Need to change the language to make more clear intent. Proposed Change: 903.3 Quality Assurance File Review Oversight of Rating and Quality Assurance Data Through use of the RESNET National Registry, RESNET will centrally administer oversight of ratings, quality assurance review reports, and other responsbilities of QA Providers reported to the RESNET Registry. of ratings using data in the National RESNET Registry.
This is a misleaading statement. This evokes the same concern people had 5 years ago of RESNET trying to "take over" performing QA. Need to change the language to make more clear intent.
903.3 Quality Assurance File Review Oversight of Rating and Quality Assurance Data Through use of the RESNET National Registry, RESNET will centrally administer oversight of ratings, quality assurance review reports, and other responsbilities of QA Providers reported to the RESNET Registry. of ratings using data in the National RESNET Registry.
Comment #26Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-2Paragraph / Figure / Table / Note: 904.3.2.1Comment Intent: Not an ObjectionComment Type: EditorialComment: Intent of this edit is to make consistent with previous proposed edit of definitoin of RESNET review of QA activity Proposed Change: 904.3.2.1 QA File review of RESNET Flagged Files. Quality Agents Assurance Designees shall review ratings with apparent errors flagged identified by the RESNET QA oversight process File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct theany errors. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater.
Intent of this edit is to make consistent with previous proposed edit of definitoin of RESNET review of QA activity
904.3.2.1 QA File review of RESNET Flagged Files. Quality Agents Assurance Designees shall review ratings with apparent errors flagged identified by the RESNET QA oversight process File review for further Quality Assurance review, investigating the specific issues of concern and working with the HERS Rater and Rating Quality Assurance Provider to correct theany errors. Significant errors impacting the rating may require increased QA File or QA Field reviews for the HERS Rater.
Comment #27Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-3Paragraph / Figure / Table / Note: 904.3.2.4.3Comment Intent: ObjectionComment Type: TechnicalComment: This is a shame that through this entire drawn out process of rewriting this standard, no more clear or substantive language was devleoped for what exactly a File QA is supposed to do. Proposed Change: 904.3.2.4.3 For of each Confirmed Rating, confirm that the values entered into the HERS Rating Software for all Minimum Rated Features are supported by actual on-site field-verified test data; and through using the RESNET QA Review Checklist to determine if the file QA review complies with the RESNET Standards or needs corrective action
This is a shame that through this entire drawn out process of rewriting this standard, no more clear or substantive language was devleoped for what exactly a File QA is supposed to do.
904.3.2.4.3 For of each Confirmed Rating, confirm that the values entered into the HERS Rating Software for all Minimum Rated Features are supported by actual on-site field-verified test data; and through using the RESNET QA Review Checklist to determine if the file QA review complies with the RESNET Standards or needs corrective action
Comment #28Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-6Paragraph / Figure / Table / Note: 904.3.3.1.5Comment Intent: ObjectionComment Type: GeneralComment: Allowing all other QAs other than the first one to be remote puts undue cost presusre of QA on low-volume raters.It seems to me that low-volume raters that demonstrate year-over-year consistency should be able to access the potential cost savsings of remote QA just like higher volume raters, but this standard does not allow for that. Furthermore, this standard - nor any other document - has clear provisoins for RESNET's remote QA policy. It is unreasonable to make such a significant change without clear policy in place . Lastly, the document does not speak to quality issues that might impact whether a provider can use Remote QA instead of in person QA. It would seem that raters who have demonstarted issues should receive more in person QA, but this standard does not make that recommendation. As such, this is jumping the gun to allow such a significant amount of remote QAs to be performed when the rules are not even clearly established and I move to strike it until RESNET can develop a clear policy on this so that this is a tool to incenvize better performing raters - regardless of volume - to achieve potential cost savings of remote QA Proposed Change: 904.3.3.1.5 “VirtualRemote” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtualremote” QA Field review methodology specified by RESNET.
Allowing all other QAs other than the first one to be remote puts undue cost presusre of QA on low-volume raters.It seems to me that low-volume raters that demonstrate year-over-year consistency should be able to access the potential cost savsings of remote QA just like higher volume raters, but this standard does not allow for that.
Furthermore, this standard - nor any other document - has clear provisoins for RESNET's remote QA policy. It is unreasonable to make such a significant change without clear policy in place .
Lastly, the document does not speak to quality issues that might impact whether a provider can use Remote QA instead of in person QA. It would seem that raters who have demonstarted issues should receive more in person QA, but this standard does not make that recommendation. As such, this is jumping the gun to allow such a significant amount of remote QAs to be performed when the rules are not even clearly established and
I move to strike it until RESNET can develop a clear policy on this so that this is a tool to incenvize better performing raters - regardless of volume - to achieve potential cost savings of remote QA
904.3.3.1.5 “VirtualRemote” QA Field reviews. All HERS Raters and RFI’s must annually receive a minimum of one (1) on-site, in-person QA Field review on a completed home and also one (1) on-site, in-person QA Field review on the same or a different home before drywall is installed. One of the two required QA Field reviews must be completed on-site and in-person, the other may be "virtual". All other QA Field reviews, for completed and pre-drywall homes, may be performed using a “virtualremote” QA Field review methodology specified by RESNET.
Comment #29Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-7Paragraph / Figure / Table / Note: 904.3.3.2.5Comment Intent: ObjectionComment Type: GeneralComment: For consistency with my prevoius comment on this standard amendment attempting to jump the gun on appropriate use of remote QA, delete this section. Proposed Change: 904.3.3.2.5 Remote QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Assurance Designee, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET.
For consistency with my prevoius comment on this standard amendment attempting to jump the gun on appropriate use of remote QA, delete this section.
904.3.3.2.5 Remote QA Field reviews. QA Field reviews not completed on-site, in-person by a Quality Assurance Designee, may be completed remotely using video technology and processes, protocols, and procedures approved by RESNET.
Comment #30Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-7Paragraph / Figure / Table / Note: 904.3.4 Quality Assurance for Multifamily ProjectsComment Intent: Not an ObjectionComment Type: EditorialComment: It seems like the numbering isincorrect. This section is relating to Field QA. As such it should be numbered differently Proposed Change: 904.3.43.3 Quality Assurance for Multifamily Projects
It seems like the numbering isincorrect. This section is relating to Field QA. As such it should be numbered differently
904.3.43.3 Quality Assurance for Multifamily Projects
Comment #31Amendment: Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01Page Number: 9-14Paragraph / Figure / Table / Note: 907 QUALITY ASSURANCE REQUIREMENTS FOR CONTRACTOR EDUCATION AND QUALIFICATION (CEQ) PROVIDERS, ENERGYSMART CONTRACTORS AND ENERGYSMART TEAMSComment Intent: Not an ObjectionComment Type: GeneralComment: Is RESNET ready to give up on this yet? Takes up so much room in the standardsfor something that is not nor has ever really been used. My reocmmendatoin would be to delete it and chapter 10 for now, and perhaps come back to it when there is a market-driven reason to revive it. Proposed Change: Delete 907 QUALITY ASSURANCE REQUIREMENTS FOR CONTRACTOR EDUCATION AND QUALIFICATION (CEQ) PROVIDERS, ENERGYSMART CONTRACTORS AND ENERGYSMART TEAMS and all other subsequent sections
Is RESNET ready to give up on this yet? Takes up so much room in the standardsfor something that is not nor has ever really been used. My reocmmendatoin would be to delete it and chapter 10 for now, and perhaps come back to it when there is a market-driven reason to revive it.
Delete
907 QUALITY ASSURANCE REQUIREMENTS FOR CONTRACTOR EDUCATION AND QUALIFICATION (CEQ) PROVIDERS, ENERGYSMART CONTRACTORS AND ENERGYSMART TEAMS
and all other subsequent sections
Return to Proposed MINHERS Addendum 30, Quality Assurance, Draft PDS-01