Brown County Appraisal District
Appraisal Standards Review Follow-Up Report
The Honorable Michael Coppic, Board Chairman
Mr. Doran E. Lemke, Chief Appraiser
Brown County Appraisal District
403 Fisk Ave.
Brownwood, Texas 76801-2929
Dear Chairman Coppic and Chief Appraiser Lemke:
This letter constitutes the Comptroller’s follow-up report of the Appraisal Standards Review (ASR) of Brown County Appraisal District (Brown CAD) originally released in July 2006. We commend the cooperation of Brown CAD’s board, chief appraiser and staff in conducting this follow-up review.
CADs play an integral part in setting property values because they have the statutory responsibility for determining local property values, which in turn affect funding to public schools.
The ASR made 11 recommendations to help Brown CAD achieve accurate local value in the annual Property Value Study and improve operations. The Comptroller acknowledges the work Brown CAD has performed over the last year. The CAD has completed recommendations 2, 5, 6, 8 and 11. These completed recommendations have assisted the CAD in improving its staffing, management and appraisal practices.
We reviewed the implementation of the remaining recommendations and while work is in progress, Brown CAD has not fully implemented recommendations 1, 3, 4, 7, 9 and 10. Enclosed is more detail on what the CAD still needs to do.
The Comptroller’s office will continue to monitor district operations and require quarterly reports until the district has implemented all recommendations. Brown CAD must implement the recommendations within one year.
This letter is available on our Window on State Government Web site at www.window.state.tx.us/taxinfo/proptax/cadreports/asr/brown01/.
I hope this information is helpful. Please let us know if we can be of any further assistance.
cc: Superintendent and Board of Trustees, Bangs Independent School District; Brownwood Independent
School District; Blanket Independent School District; May Independent School District;
Zephyr Independent School District; Brookesmith Independent School District; and
Early Independent School District
Brown CAD Board of Directors
What Remains to Be Done
The Comptroller’s office will continue to monitor Brown CAD’s progress toward meeting the state’s legal requirements. The following outlines specific steps the CAD still needs to take.
Conduct long-term planning and establish a schedule for reviewing the long-term plan.
The chief appraiser stated that the CAD has obtained sample planning documents from Taylor CAD, which it plans to edit to fit the needs of Brown CAD. The CAD appointed two new members to the board in January 2007, and the chief appraiser feels it is better to wait until these members gain experience on the board before initiating long-term planning for the CAD. The chief appraiser expects to have the long-term planning completed by March 2008.
To complete this recommendation, the CAD should submit copies of the long-term strategic plan and board minutes showing the plan adoption to PTD by Mar. 31, 2008.
Either obligate existing surplus funds in the budget for specific purposes, or, at the end of the fiscal year, credit a proportionate share of the unspent funds to each taxing unit.
The chief appraiser stated that the CAD’s external auditor made no finding or recommendation in the Management Letter to follow Property Tax Code Section 6.06(j). Testing whether the CAD complies with the Property Tax Code may be beyond the scope of the independent auditor’s engagement agreement to perform a financial audit. Appraisal districts, as Texas governmental agencies, are required to comply with all applicable laws.
Property Tax Code Section 6.06(j) requires CADs to either obligate surplus funds or credit them back to the taxing entities. While the external auditor did not report the CAD’s failure to meet the requirements of the Property Tax Code, the Legislature, nonetheless, mandates that appraisal districts obligate funds or credit surpluses back to the taxing entities at the end of the fiscal year. The Texas Attorney General, moreover, has ruled that appraisal districts must comply with this requirement.
The chief appraiser stated that the CAD’s independent auditor is developing a policy on how to handle excess funds. The chief appraiser will present the proposed policy for the board’s consideration at its October 2007 meeting.
To comply with this statute, the CAD must forward a copy of the October 2007 board minutes reflecting the adoption of a policy for excess funds that satisfies the requirements of Property Tax Code Section 6.06(j). In the alternative, the CAD must provide written documentation from each taxing unit directing the CAD to retain and obligate its pro rata share of the annual budget surplus. Documentation of completion of one of the alternatives must be submitted to PTD by Dec. 31, 2007.
Make full use of competitive sealed bid and proposal laws to get best value from purchases, and seek a legal opinion concerning the requirements of Local Government Code Chapter 252.
The chief appraiser stated that the CAD is currently planning to begin drafting a policy for the bidding process by the end of 2007 for board approval by March 2008. The chief appraiser stated that no capital expenditures have been made since the ASR was conducted in 2005.
The CAD must submit copies of the board-approved policy to PTD by Mar. 31, 2008.
Revise the appraisal manuals to include IAAO standards for appraisal of real property and replace documents as needed to broaden the manual’s scope and improve the currency of data.
This recommendation is in progress. The chief appraiser stated he and the CAD staff have discussed it and have begun to address it by reviewing the IAAO Technical Standards. The chief appraiser plans to complete the revision of the appraisal manual by March 2008.
A copy of the revised manual must be furnished to PTD by Mar. 31, 2008.
Develop and incorporate into the personnel manual provisions for annual staff performance reviews to aid in measuring employee progress and effectiveness and to identify CAD and employee performance goals and objectives.
This recommendation remains in progress as the CAD has developed a performance evaluation form to be used to evaluate staff. The CAD intends to incorporate this form into the existing personnel manual and to evaluate all CAD staff by Mar. 31, 2008.
To comply with this recommendation, submit copies of the employee evaluations performed on CAD staff by Mar. 31, 2008.
Develop and implement a work force and succession planning process to meet short- and long-term staffing needs.
This recommendation is in progress. While the CAD has not prepared a documented plan, the board and chief appraiser discussed and attempted to address staffing needs during the budget planning process. As an outcome of their discussion, the CAD added a new position in the 2007 proposed budget.
Hiring a new employee is short-term human resources planning. For an appraisal district to develop and plan for the future, a longer-range view is needed.
To comply with this recommendation, the CAD must provide documented evidence of work force and succession planning processes to the Comptroller no later than Mar. 31, 2008.