New disciplinary procedures and quality assurance standards imposed
Failing to catch energy assessments “strewn with ‘schoolboy errors’ and glaring omissions”; schemes allowing energy assessors to lodge reports even though membership had lapsed; and individuals granted accreditation despite being dismissed from rival bodies for “disciplinary reasons”.
These damning indictments against some of the (un-named) accreditation schemes are just some of the “growing number of allegations and reports of unacceptable practices and poor quality of EPCs” listed by the CLG in a surprise letter sent to all accreditation schemes on 22nd December 2009.
The catalogue of failings and shortcomings listed in the letter, leaked to this site yesterday, include:
- EPC assessments being carried out “on the cheap” without proper process, and people being given poor quality EPC reports that are strewn with “schoolboy errors” and glaring omissions;
- inadequate Quality Assurance procedures being applied, including failure to keep proper records, or to publish key documents about standards and procedures;
- schemes accrediting energy assessors without carrying out proper checks or after they have been dismissed by other schemes for disciplinary reasons;
- schemes accrediting energy assessors to carry out assessments that are not covered by the scope of the Scheme’s approval from the Secretary of State;
- schemes continuing to allow assessors to lodge EPCs/DECs/Air Conditioning reports even though their membership of the scheme has lapsed;
- failure to act on outcomes from Quality Assurance procedures, and inadequate enforcement of Codes of Conduct for assessors; and
- use of unauthorised software or unauthorised changes to software or reporting templates.
Invalid EPCs
Later (in the accompanying Annex D), it concedes what others have warned:
There have been known cases of EPCs being created (hard copies) that do not reside within the EPC Registers. There are some cases where this may be for valid reasons (e.g. the building transaction did not proceed following the production of the EPC), however, this may not explain all discrepancies.
CLG Disciplinary Procedures for Schemes
The letter also notifies, with immediate effect, new terms of approval to operate as an Accreditation Scheme which subject them to a three-tier disciplinary process should they fail to uphold strengthened quality control standards - the last of which being a Termination Notice.
Termination Notice
Depending on the severity of non-compliance, CLG may issue either an Initial Notice, or Final Notice. Although it won’t issue the final sanction, a Termination Notice, before a Final Notice is served, except “under exceptional conditions where compelling evidence comes to light during an Initial Notice of an instance such as fraud”, according to Annex A.
Accreditation schemes have the right to appeal at each step, and may continue to operate subject to any restrictions the CLG may impose.
Spot-checks
Schemes will, at “minimal advance notice”, be subject to spot-check audit visits, including mystery shopping exercises, the letter says, and “auditors will be under instruction to report as a matter of urgency any breaches of CLG’s standards and requirements by individual schemes.”
Whistle-blowers
Breaches may come to light through various sources, including scheme audits* and “other evidence available to CLG from whistle blowers, other schemes, end users, registry analysis, etc, which CLG judge is compelling.”
Any breaches will automatically be subject to disciplinary procedures.
* current scheme auditors are Aecom
Minimum requirements for Quality Assurance of Domestic Energy Assessors
The CLG also issued draft clarifications on the minimum requirements for the quality assurance of DEAs, which it intends to put into effect by 1st March 2010 after taking feedback from accreditation schemes.
Auditors have discovered “huge variations in the interpretation of CLG requirements and in the detail of implementation”, Annex C says, and “it is CLG’s view that these differences lead to major variations in quality outcomes, and hence need to be addressed.”
Inconsistencies
It also:
acknowledges that there are some inconsistencies in CLG documentation as to the accuracy levels which are required for energy assessors.
Annex C includes an extensive table (Table 1) of clarifications it expects accreditation schemes to follow and report on. The measures are too numerous to list here, but include:
Accuracy
- 95% of certificates should be within 5 SAP points of the “truth”. The “truth” will be assessed by the accreditation scheme QA team, must be evidence based, and use the software protocols provided by CLG.
- The error between the energy assessor and the QA assessor will be defined as the sum of the absolute errors associated with each data field of SAP (ie avoid the instance where self-cancelling errors lead to an acceptable SAP score).
- Schemes must, as a minimum, have internal procedures to: (a) moderate QA assessors; (b) verify the work of a QA assessor if there is a single assessor within a strand; (c) moderate between the work of schemes (see later); (d) manage an appeals mechanism for instances where there is a difference between the energy assessor and the QA team; (e) provide feedback to the assessor; and (f) provide aggregate data to CLG on a monthly basis using the proforma attached at Appendix A.
As a clue, perhaps, of past misdemeanours, it lists reasons for which schemes may attract an Initial or Final Notice against each of the listed clarifications. These include lateness to report, unclear QA procedures, a failure to “inform members of a change in software protocol from CLG,” and “systemic errors associated with poor procedures within Scheme”, amongst others.
Defective certificates
On defective certificates, it says:
Certificates are deemed to be defective and must be replaced when:
The sum of the absolute errors between the energy assessor’s and QA assessor’s SAP score is more than 5 SAP points as identified above.
If errors in the building’s description would result in a change in the recommendations made.
If the building’s description is sufficiently inaccurate such that it brings into question the accuracy of the rating by the seller.
Sampling
New minimum requirements on EPC sampling will be set in addition to the overall 2% desk based sampling of EPCs over a calendar membership year:
- Each energy assessor must have at least 1% (minimum one) of their certificates assessed annually through a desk based audit.
- Additional monitoring of energy assessors who have failed a QA check – with schemes having an escalation procedure (see later) which results in at least one additional QA check within no more than 30 days of the error being identified (or the next available certificate). An allowable alternative is to sample additional reports that the energy assessor has lodged at around the same time (within one month) as the date of the EPC which was checked.
- Other risk factors, such as excessive customer complaints or use of a help line in a way which implies a lack of competence, should trigger a higher sampling rate of 2% of an assessor’s lodgements.
- New members should be assessed within no more than the first 30 days of their membership (or first available certificate). Sampling rates of newly registered members should be at least 2% of lodged EPCs during the first six months of their membership.
DEA disciplinary procedures – escalation procedures
The CLG says it expects the minimum disciplinary requirements to “be developed over time” but reiterates the current “basic” regime:
- Temporary suspension of an energy assessor who does not provide sufficient details associated with an EPC to allow a scheme to undertake a QA assessment within no more than ten working days of the request being issued.
- If the energy assessor has a reasonable excuse as to why the data could not be provided then the energy assessor is given a warning and any future infringement associated with the non-provision of required information should normally lead to disciplinary procedures being implemented.
- Schemes will need to form a view as to whether a particular QA assessment failure is an oversight which is unlikely to be replicated, or something which is an indication that the energy assessor lacks the competence to undertake work. In both cases there is a need for additional QA checks, but the corrective actions required will need to reflect the circumstances.
- Failure of two consecutive QA checks will necessitate a 10% QA sampling rate unless the QA assessor can demonstrate that the two consecutive failures are minor in nature and likely to be corrected.
- Shortcomings in competence will be tackled initially by a series of appropriate measures including mandatory CPD and site based checks.
- Accreditation schemes need to have procedures where there are clear criteria where repeated QA failures which demonstrate a lack of competence and a failure of corrective actions should lead to the suspension of an energy assessor. The period between an energy assessor first failing an energy assessment and suspension should not normally be more than six months.
As above, accreditation schemes will attract warnings for failing to abide by these, and future requirements.
Other areas listed within Table 1 include: competence of QA assessors; QA checks by 3rd parties (accred schemes still allowed to outsource QA checks); and conflicts of interest (of the QA assessor).
Accreditation schemes have until 5pm on Thursday 30th April 2010 to submit their first set of reports to the CLG under the new quality reporting regime, which will cover the period 1st – 31st March.
The CLG will propose a requirement on schemes to participate in a forum to “identify and promote best practice, and suggest changes to the CLG DEA QA clarifications so as to meet CLG’s quality requirements.”
Other changes
EPCGen and ORGen software to verify Energy Assessor details
Annex D details changes to the way EPCGen and ORGen verifies energy assessor details when creating “un-watermarked” EPC and DEC certificates.
A new digital certificate will be introduced to allow EPCgen.net to connect to the Non Domestic Register to verify assessor details.
Energy Assessor Unique Identifier to identify suspended assessors
From 31st January 2010, birth dates will be used by Landmark to uniquely identify energy assessors which will help detect duplicate assessor records and flag-up assessors suspended by accreditation schemes.
Update: Accreditation schemes and industry react to new CLG rules
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