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After considerable discussion, heated debate, and many false starts, we have rewritten our Administrative Appeals (AA) Policy (effective February 1, 2024).
Projects that register for an Administrative Appeal before that date may use either the current policy or the new policy. Please be sure to note in the verification report which policy will be followed. Buildings registered after February 1, 2024 must follow the new policy. Buildings that the Verifier or Client realize an Administrative Appeal is required after February 1ST must also follow the new policy, even if the building was registered prior to February 1ST.
As a reminder, the Administrative Appeals policy was intended as a last resort for buildings that wanted to earn NGBS Green certification but missed all or part of the rough inspection. We expect that, whenever possible, buildings follow the typical verification process to earn NGBS Green certification.
Alternately, Clients and/or Verifiers may elect to use the full Appeal Process should they so choose.
We re-wrote the AA Policy for several reasons.
First, the old policy was vague and subject to various interpretations. Clients were "shopping" Verifiers to find one with the "best" interpretation of the policy. Moreover, the lack of clarity led staff to make project-specific applications of the policy which then creates inconsistencies in certification decisions. Certification policies should be clear, transparent, and provide for consistent outcomes.
Second, on application, even when the policy was followed carefully, NGBS Green reviewers too often did not have clear evidence of a building's conformance. NGBS Green certification credibility rests on our ability to render certification decisions with our full confidence.
This is why we sometimes pilot new processes, so that we can learn and improve before they become formal program policy.
The new policy aims to address the previous policy's flaws. It also expands and clarifies verification requirements to ensure Home Innovation has the necessary information to make accurate conformance decisions. Going forward, only Master Verifiers are allowed to submit and supervise projects seeking NGBS Green certification via the AA process. The verification report will be rejected if a Master Verifier is not noted as the Verifier of Record. The AA process is more complicated and requires significant Verifier discretion. Master Verifiers have demonstrated NGBS Green expertise through their years of service and successful verification submissions.
Last, along with the new AA Policy, we have initiated a "three strikes" rule in AXIS. With a goal to eliminate the possibility that some clients are using the Administrative Appeals process as a cheaper alternative verification process, AXIS will now flag clients that file for an Administrative Appeal. After registration of the third project for an Administrative Appeal, the Client will be notified that they are no longer able to use the AA process for any other project going forward. The third project will be able to use the AA process. We know the AXIS rule is working because it has already flagged a client trying to register a fourth project. No exceptions.
Generally Verifiers are asked not to share the VRG, in whole or in part, this is the exception. Please share the new AA Policy and the corresponding Mandatory Practices for Administration Appeals if you have current or prospective Clients interested in this topic.
Effective immediately, the Full Appeal fees have been raised to $750 per home and $1,500 per building. This was necessary to reflect how labor-intensive full appeals are for us and to ensure that the new AA process didn't inadvertently create an incentive for Verifiers to select the full appeal process over the AA workflow. While the AA process can be labor intensive for Verifiers, we like its consistency and thoroughness in how we deal with the issue of a missed rough inspection and how we document compliance. Because the full appeal process is intended to handle myriad project-specific situations, practice interpretations, and clarifications, it allows more flexibility. But at the same time, because each decision is made independently, it is also less likely to be consistent. Thus, whenever possible, our preference is that projects with missed rough inspections use the AA process.
As always, I welcome your feedback by email or phone (240.997.8027).
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