Focus on Appraisal Districts' Operations
Before the Legislature created CADs in 1981, thousands of individual taxing units appraised property and assessed taxes independently, resulting in wide disparities in values. As the state began to base more aid to school districts on property values, and property tax levies increased, centralized local appraisal became necessary to ensure equal taxpayer treatment.
The CAD system greatly improved equity in property taxation and school funding, although there are still wide differences in individual CAD practices. Each year, the Comptroller’s Property Tax Assistance Division (PTAD) surveys the state’s 253 CADs for information about their operations. The CADs provide these data for the prior tax year and project data on budgets and plans for the current tax year.
The differences in responses reported in the PTAD’s annual survey reflect the CADs’ diversity. While the range in survey results makes generalized observations difficult, they do demonstrate the complexity of the CADs’ daily operations, the massive job they perform each year and the benefit they provide to local taxing units.
This year, five CADs did not participate in the Comptroller survey – Knox, Nacogdoches, San Jacinto, San Patricio and Van Zandt CADs. PTAD used data from previous years’ surveys for these CADs to provide the most accurate statewide data possible.
The Comptroller provides CAD information to legislators, local taxing entities, taxpayers, news media, state agencies and the appraisal districts themselves. PTAD uses the information to prepare legislative fiscal estimates and as background for its appraisal standards reviews (ASRs). Appraisal districts use the information to compare their operations to those of other CADs.
The complete survey data are available on the Comptroller’s Web site at www.window.state.tx.us/taxinfo/proptax/ador0708/ (Excel, 278 KB). Following are highlights of the information contained in the surveys.
A board of directors selected by the taxing units within the CAD governs each appraisal district. The directors hire the chief appraiser; establish the CAD’s goals and policies; appoint appraisal review board (ARB) members; and approve agricultural advisory board members.
Property Tax Code Section 6.03 requires that if a taxing unit does not appoint the county tax assessor-collector to the CAD board, the county assessor-collector serves as a non-voting CAD director. If a county tax assessor-collector serves as the CAD’s chief appraiser, however, or if the county commissioners court contracts with another taxing unit to collect county taxes, the county tax assessor-collector is ineligible to serve on the CAD board.
Most board members are citizen appointees of the taxing units in the CAD, but 792, or about half of all directors, are taxing unit officials, including county tax assessor-collectors, school board members, county judges, county commissioners, city council members and other elected officials. They represent the interests of the respective taxing units that appoint and elect them. The number of taxing unit officials on CAD boards rose by 255 or 47.5 percent, from the total of 537 elected officials who served in 2006.
One hundred eighty-six CADs purchase liability insurance for errors and omissions by board members, while 62 do not purchase this insurance protection. Two hundred fifteen CADs reported that they retain legal counsel to advise the board on legal issues that may arise from CAD operations. Thirty-six CADs do not have legal counsel on retainer.
Appraisal Review Boards
Appraisal review boards are separate entities appointed by CAD directors to handle taxpayer protests and taxing unit challenges. In 2007, CADs appropriated $7.5 million for ARB operations, 82.9 percent more than 2006’s $4.1 million. The average annual CAD expenditures for ARB operations are $29,563.
Two hundred thirty-five CADs reimburse ARB members for time and travel expenses. One hundred seventy-nine CADs provide the ARB with liability insurance and 81 provide the ARB with legal counsel.
Thirteen CADs indicated they provide the ARB with full-time support staff totaling 26 employees. The 240 CADs that do not provide the ARB with a full-time staff assigned 537 CAD employees to assist the ARB during the protest period.
Thirty-one CADs provide in-house training to the ARB, while 218 do not. PTAD provides training to ARB members via seminars offered at multiple sites throughout the state. One hundred fifty-five CADs said that a PTAD-produced training video would be a good alternative to the onsite training seminars. Seventy CADs disagreed with this idea.
Agricultural Advisory Boards
Property Tax Code Section 6.12 requires the chief appraiser, with the advice and consent of the CAD’s board, to appoint three or more members to an agricultural advisory board. This board advises the chief appraiser on the appraisal and use of land designated for agricultural, open space or timberland appraisal.
One hundred ninety-three CADs have agricultural advisory boards with a total of 787 members. The average board had four members.
Local taxing units pay CAD expenses according to their share of the total property tax levy of all the taxing units in the CAD. Property Tax Code Section 6.06 permits taxing units served by a CAD to veto the CAD’s budget, but only two taxing units did so in 2007.
Final 2007 CAD operating expenses totaled $334.2 million, or an average of $19.61 per parcel. The average 2007 CAD operating budget exceeded $1.3 million, 7.1 percent more than in 2006. CADs approved budgets for 2008 totaling $349.9 million, an increase of 8.9 percent.
The top 10 CADs account for 46.7 percent or nearly half of all CAD budgets in the state (Exhibit 7).
|CAD||2008 Adopted Budget|
|Total Top 10 Budgets||$163,535,638|
|Total CAD Budgets Statewide||$349,886,749|
|Percent Top 10 Budget of Total Budgets||46.7%|
Source: Texas Comptroller of Public Accounts.
While the average statewide cost per account was $19.61 in 2007, grouping the CADs by account sizes shows the variance in costs per account, with three groups of appraisal districts exceeding the state average (Exhibit 8).
|Number of Accounts||Number of CADS||Average 2007 Expenses||Average Cost Per Account|
|5,000 to 9,999||26||$136,948||$17.18|
|10,000 to 14,999||30||$197,930||$16.20|
|15,000 to 19,999||24||$496,556||$27.81|
|20,000 to 24,999||17||$363,406||$16.07|
|25,000 to 34,999||30||$529,006||$17.15|
|35,000 to 49,999||41||$664,353||$15.76|
|50,000 to 74,999||31||$849,472||$14.05|
|75,000 to 149,999||26||$1,848,329||$17.63|
|150,000 to 300,000||14||$3,323,381||$16.60|
|More than 300,000||10||$14,227,227||$25.42|
Source: Texas Comptroller of Public Accounts.
Appraisal districts indicated they had accumulated $31.8 million in surplus funds. This represents 90.1 percent more than in 2006, or nearly double the surplus funds available in the previous year’s budgets. Almost 75 percent of this increase is attributable to Harris CAD, which amassed an additional $10.8 million surplus from 2006. Exhibit 9 lists the 10 CADs with the largest surpluses in 2007.
|CAD||2006 Surplus||2007 Surplus||Increase/
Source: Texas Comptroller of Public Accounts.
Most CADs enter into contracts with third-party vendors to provide appraisal services for complex properties such as mineral holdings and utilities. In 2007, these contracts cost CADs $15 million, or $64,731 per CAD.
Nearly all CADs (245) included a budget line item for staff training. Statewide training budgets totaled slightly less than $3 million, or an average of $11,761 per CAD.
Chief appraisers oversee CAD staff and operations. Employment arrangements within the CADs vary with CAD size and workload. The largest CADs commonly have as many as 200 staff members, while a small CAD may employ only part-time appraisers or contract for appraisal work.
Two hundred two chief appraisers perform appraisals; 46 do not. On average, chief appraisers earned $57,018 annually, ranging from a low of $6,600 in Hardeman CAD to a high of $161,684 in Harris CAD. Exhibit 10 lists the top 10 chief appraiser salaries.
|CAD||Chief Appraiser Salary|
Source: Texas Comptroller of Public Accounts.
Forty-four chief appraisers also received pay as tax assessor-collectors. Most CADs (201,) provide the chief appraiser both medical and retirement benefits. Four provide only medical insurance, while 21 offer their chief appraiser retirement benefits. One hundred ninety-seven CADs provide the chief appraiser with liability insurance coverage.
Full-time CAD employees numbered 4,457 in 2007, with 871 holding supervisory positions and another 317 involved in collection activities. The CADs employed 1,670 professional appraisers, representing 37.5 percent of all full-time CAD employees. Salaries for CAD appraisers in 2007 ranged from an average of $26,178 to $41,201. CADs employed 84 computer programmers, paying them average amounts ranging from $14,178 to $21,165.
Appraisers must be registered with the Board of Tax Professional Examiners (BTPE) and must either be a registered professional appraiser (RPA) or enroll in training to become one within five years of their employment as an appraiser. Texas CADs reported that 2,309 of their employees have certifications issued by BTPE. Statewide, 1,435 appraisers have obtained the RPA designation; 237 are registered Texas assessor-collectors; 112 are registered Texas tax collectors; and 93 individuals have all three designations.
Some 216 CADs provide staff with medical insurance and retirement benefits; while six provide only medical insurance; and 14 only provide retirement.
CAD Appraisal Work
In 2007, Texas CADs appraised more than 17 million pieces of property valued at more than $1.7 trillion. In 2006, appraised property totaled $1.6 trillion.
Exhibit 11 highlights the appraisal district workload for the 25-year period from 1983 through 2007.
|Year||Taxable Parcels||Appraisal Notices Sent||ARB Hearings Scheduled|
Source: Texas Comptroller of Public Accounts, Property Tax Assistance Division.
A parcel is any item of real property, regardless of size, that has a single owner or multiple owners in undivided ownership and for which there is a separate appraisal record.
State law requires CADs to reappraise property in their jurisdiction at least once every three years. Many reappraise property every year. For the 2007 tax year, CADs reappraised 72 percent of parcels not appraised by contractors. CADs reappraised 68 percent of such parcels in 2006 and plan to reappraise 82 percent in 2008. The CADs also plan to reappraise 98 percent of contracted parcels annually in 2006, 2007 and 2008.
Two hundred sixteen CADs conducted ratio studies in 2007, while 25 did not. Sixteen CADs did not provide information on this subject.
Property Tax Code Section 11.14 entitles a property owner to an exemption from taxation of tangible personal property that the owner does not use to produce income. Manufactured homes do not qualify for this exemption. A taxing unit may opt to tax property exempted by Section 11.14, however, and 358 Texas taxing units have chosen to do so. Seventy-two cities tax leased vehicles used primarily for personal purposes.
Property Tax Code Section 11.261 allows a county, city or junior college district to limit taxes (also called a tax ceiling) for homeowners who are either disabled or 65 or older or both. One hundred forty-seven such entities chose to allow this limitation, while 98 did not.
CADs generally are required to mail notices of appraised value to taxpayers by a certain time each year. If an owner’s property value is higher than in the previous year or higher than the owner’s rendered value, or if the property is new to the appraisal roll, the CAD must mail a notice reporting the proposed taxable value and estimated taxes. A shorter version with no estimated taxes is required if none of the above conditions apply, but the property has been reappraised in the preceding year or has changed ownership, or if the owner requests a notice.
In response to those notices, property owners filed 1.1 million written protests. Of these protesting taxpayers, 643,277 met with CAD staff in informal meetings to attempt to resolve the appraised value on their property. ARBs scheduled 649,483 formal protests. Nearly a third (33.1 percent) or 215,129 of the taxpayers were “no shows” for their scheduled hearing.
Of the more than 1 million protests initially filed with the CADs, 888,601 sought a property value reduction. Another 455,421 protested because they felt they had received an unequal appraisal.
Property owners who are unsatisfied with the outcome of their protest can file a lawsuit in district court; 7,798 chose to take this route in 2007. The appraised value of the property contested in district court was $126.8 billion.
Certifying the Appraisal Roll
After all protests are completed, the chief appraiser must certify the appraisal roll to the CAD’s member taxing entities so they can adopt budgets, set tax rates and prepare for the tax collection process. Property Tax Code Section 26.01 requires the chief appraiser to certify the appraisal roll by July 25. In 2007, 196 CADs met the statutory deadline, and 52 did not. Five did not respond to this survey question (Exhibit 12).
Assessing and Collecting
While all CADs appraise property, some have the additional duties of assessing or collecting property taxes. In 2007, 131 CADs calculated effective and rollback tax rates for 999 local taxing units; 71 published required notices of proposed tax increases by 430 taxing units; and 119 prepared and mailed tax bills for 864 taxing units.
One hundred seven CADs collect taxes on behalf of 938 taxing units. They budgeted $16.4 million for the function, or an average of $132,553 per CAD performing collections.
Facilities and Computers
Most CADs, 229, operate offices under an independent board and chief appraiser. Another 21 CADs make other arrangements, such as having the tax-assessor or other offices oversee CAD operations. Three CADs did not respond to this question on the survey.
CADs may own property for use as office space. In 2007, 155 CADs owned office space. Thirty-two CADs leased office space from a private concern; 41 leased from a taxing entity; and 22 enjoyed free use of office space. Three CADs did not respond to this question on the survey.
The number of CADs with a geographic information system (GIS) totaled 162. Reporting CADs entered 76 percent of their appraisal records in the GIS. Four CADs with a GIS had not yet entered appraisal records into the system. Eighty CADs reported that they did not have a GIS and 11 CADs did not answer this question on the survey.
PTAD used the Appraisal District Operations Survey to gather data for this report. PTAD also publishes other publications helpful to taxpayers, taxing entities and CADs. Some CADs also mailed the Comptroller’s office a copy of their 2007 appraisal budget, and some CADs that collect taxes provided copies of their 2007 collection budgets.
To obtain a copy of a CAD’s completed survey response, appraisal budget or collection budget, e-mail a request to email@example.com or call the PTAD’s technical assistance hotline at (800) 252-9121. In Austin, call (512) 305-9999.
In a separate survey, PTAD obtained information to update names and addresses of CAD directors, ARB members and chief appraisers. This information is contained in the 2008 Appraisal District Directory, available online at www.window.state.tx.us/taxinfo/proptax/apprdir08/.