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RESNET Proposes HERS Rating Quality Assurance Oversight Standard Amendment to Enhance the National Consistency of HERS Index Scores

Feb 23, 2016

Across the nation the RESNET HERS Index Score is fast becoming a mainstream in the housing market. Homebuilders are having their homes energy rated and are marketing the HERS Index Score of their homes. Multiple Listing Services (MLS) are incorporating the HERS Index Scores in their listings and code jurisdictions are recognizing a HERS Index Score as a building energy code compliance option. With the increased visibility of the HERS Index Score, RESNET is obligated to ensure that HERS Index Scores are as consistent as possible.

This need has been made more important with the International Code Council adopting an Energy Rating Index option to the 2015 International Energy Conservation Code.

RESNET has embarked on a comprehensive effort to enhance the consistency of HERS Index Scores nationally.  This effort includes the upgrading of its quality assurance standards to align with the RESNET Board Policies on Enhancing Quality Assurance Oversight that were adopted November 3, 2014.  To view the RESNET Board policies go to RESNET Board Policies on Enhancing Quality Assurance Oversight

RESNET staff is proposing a set of amendments to its HERS rating quality assurance oversight standard. Major elements of the proposed changes are:

  • Because the RESNET Standards apply to all types of Providers and not just Rating Quality Assurance Providers, it is being proposed that the Standards be modified to be more generic where possible and more specific to each Provider category where necessary.
  • It is being proposed to move the Provider accreditation and renewal process from Chapter 9 to Chapter 1 to be properly grouped with the other accreditation and renewal requirements for Providers (Section 102).
  • For QA File and QA Field reviews, it is being proposed that the HERS Rater’s “annual total of ratings” be considered as all ratings entered into the National RESNET Registry (based on “date registered”) for a calendar year, i.e. the twelve month period from January 1st through December 31st (Section 904.3.1.1).
  • It is being proposed that Rating Quality Assurance Provider accreditation and accreditation renewal procedures will require participation in a special RESNET training (Section 102.3.3 and Section 103.4.1).
  • In accordance with the November 3, 2014, RESNET Board policy directive, two new Provider sub-categories are being proposed to be created under the Rating Quality Assurance Provider category, “Direct Rating Quality Assurance Providers” and “Third-party Rating Quality Assurance Providers.” The proposed modification will fully integrate these two new sub-categories and define how they are to work (Section 103).
  • A key element of RESNET Board policy directives on consistency and quality assurance improvements is “financial independence” in the quality assurance process. The definition of “financial interest” that is being proposed will mirror that used by the California Energy Commission, “An ownership interest, debt agreement, or employer/employee/contractor relationship. Financial interest does not include ownership of less than five percent of the outstanding equity securities of a publicly traded corporation.” (Appendix B, “Financial Interest”).
  • The proposed amendment makes provisions for organizations to act as both a Third-party Rating Quality Assurance Provider and separately as a Direct Rating Quality Assurance Provider (Paragraph 103.2.3). Additionally, per Paragraph 905.1.2, “Third-party Providers who meet the minimum requirements to be a Quality Assurance Contractor are being proposed to be recognized by RESNET as Quality Assurance Contractors.”

This approach is being presented because there are three “safety valves” that RESNET can use to prevent problems. First, the definition of financial interest is being proposed to be spelled out clearly and must be adhered to. Second, RESNET will have a very close relationship with all Third-Party Providers and their Quality Agents under the new Quality Assurance Program, providing for greater oversight and knowledge of what they are doing and how they are doing it. Third, RESNET can exercise the right to not approve a Direct Provider’s choice of Quality Assurance Contractor(s) if it is believed that there is a conflict of interest (Paragraphs 103.1.2.1.1 and 103.1.2.2).

  • Some sections of text are being proposed to be removed because they will be moved to another chapter in the Standards being handled by a separate amendment process (example, after 103.4.5, struck out Sections 102.1.2.2, 102.1.2.3, and 102.1.2.4).
  • Conflict of interest provisions are being proposed to be updated (Section 103.4.9.2). The Standards are proposed to explicitly prevent home builders from conducting ratings on their own homes. For multi-family projects and production home communities, the RESNET Standard Disclosure form is not required for each home or unit that receives a home energy rating, but instead is to be provided to the rating client prior to the start of construction. These and other changes have been incorporated into an update to the RESNET “Home Energy Rating Standard Disclosure” form. The revised form will be released for public comment after these amendments to the RESNET Standards have been finalized.
  • With the proposed addition of a requirement of due process for Raters (Paragraph 103.4.6) to appeal disciplinary action and as part of the Rater Agreement (Paragraph 103.4.7.3), the provision for RESNET review of “disputes between Providers and Raters regarding a Rater’s probation, suspension or revocation status” is no longer necessary (Paragraph 102.1.4.8). Raters will be able to file an appeal to their provider disciplinary actions taken against them.
  • New financial penalties are being proposed to be added to the Standards for Rating Software Providers that do not meet deadlines for required software change/updates (Paragraph 105.3), Rating Quality Assurance Providers placed on Disciplinary Compliance Probation (Paragraph 910.2.1.2.9), and Rating Quality Assurance Providers Suspended by RESNET who wish to be reinstated (Paragraph 910.3.5.3). This is being proposed to be an incentive to providers to meet deadlines and not be suspended.
  • It is being proposed to delete most of Chapter 5 because the process for amending the RESNET Standards is now spelled out in the RESNET Standards Development Policy and Procedures Manual for Non-ANSI-RESNET Standards.
  • Requirements for pre-drywall QA Field Reviews are being proposed as an addition. (Paragraph 904.3.3.1.3).
  • To make the quality assurance process more efficient, flexible and cost effective, it is being proposed to add provisions for “Virtual” QA Field reviews. (Paragraph 904.3.3.1.5)
  • It is being proposed that Home Energy Raters that conduct over 500 confirmed ratings in one year and do not have errors found for over a two (2) year period will have a reduction in the required quality assurance reviews. (Paragraphs 904.3.2.2.1 and 904.3.3.1.1.1)
  • Quality assurance for multifamily projects from the RESNET Guidelines for Multifamily Ratings is being proposed to be added (Section 904.3.4).
  • The allowance for one “centralized proctored rating QA events” in lieu of one QA Field review for Raters is being proposed to be removed (Section 904.4.2.8). This allowance will no longer be necessary with “Virtual” QA Field reviews.
  • The paragraph regarding allowable variances in HERS Index scores is being proposed to be moved from the QA Field review section to the section on “non-compliance of reviewed ratings” so that it applies to both File and Field QA reviews (Paragraph 904.3.5). Additionally, the percentage of variance allowed is being proposed to be increased from ±3% to ±5% and made a “cumulative” change rather than “net” change. Lastly, an example to illustrate the application of this concept is being proposed.
  • In accordance with the 2013 RESNET Board policy directive on increased consistency of ratings, which required “provisions through modification to the standard to add additional oversight of HERS Raters when errors are found in these reviews,” is being proposed to be added to the Standards (Section 904.3.5.5.1).
  • In accordance with the November 3, 2014 RESNET Board policy directive, it is being proposed to formally add Quality Assurance Contractors to the Standards (Section 905.1).
  • Certification, Professional Development, and Responsibilities for RESNET certified Quality Agents, which replace the Quality Assurance Designees, are being proposed to be added (Section 905.2).
  • Quality Assurance Designee Delegate is being proposed to be removed from the Standards (paragraph Section 905.7).
  • New definitions being proposed to be added to Appendix B.

The proposed amendment is posted at Proposed Amendment to the RESNET Quality Assurance Standard

Prior to going through the formal RESNET standard amendment public review and comment process, RESNET gave the HERS Industry a chance to review and vet the preliminary draft of the proposed standard. Over 160 comments were received. After receiving the industry’s input, staff reviewed and carefully considered each comment and made the necessary modifications.

The SDC 900 has voted to submit this proposed RESNET staff amendment to the RESNET standard amendment public review and comment process. Interested parties are encouraged to comment on the proposed amendment.

Comments will only be accepted on the proposed underlined and strike out propose amended language.

Public comments on the proposed amendment will be accepted until April 25, 2016.

To submit your comments click on RESNET Quality Assurance Amendment Comment Online Form

Comments are posted real time and you will be able to review comments that were submitted by clicking on Comments Submitted on Proposed RESNET Quality Assurance Amendment

Only comments made through the online system will be accepted.

After the comment period, the RESNET Standard Development Committee 900 will consider and document its consideration of each of the comments submitted and make appropriate changes. The revised proposed amendments will then be submitted to the RESNET Standards Management Board for adoption.