Texas Tax Code §5.12 - Performance Audit of Appraisal District
(h) In addition to the performance audits required by Subsections (a), (b), and (c) and the review of appraisal standards required by Section 5.102, the comptroller may audit an appraisal district to analyze the effectiveness and efficiency of the policies, management, and operations of the appraisal district. The results of the audit shall be delivered in a report that details the comptroller's findings and recommendations for improvement to the appraisal district's chief appraiser and board of directors and the governing body of each taxing unit participating in the appraisal district. The comptroller may require reimbursement by the appraisal district for some or all of the costs of the audit, not to exceed the actual costs associated with conducting the audit.
Added by Acts 1987, 70th Leg., ch. 860, § 1, eff. Jan. 1, 1990. Amended by Acts 1989, 71st Leg., ch. 384, § 12, eff. Sept. 1, 1989; Acts 1991, 72nd Leg., ch. 843, § 10, eff. Sept. 1, 1991; Acts 2003, 78th Leg., ch. 1183, § 6, eff. June 20, 2003.
Property Value Study
This section presents an overview of the Property Value Study (PVS) and explains its procedures in detail.
The Texas Comptroller's office conducts the PVS annually to estimate the total taxable property value in each school district and to measure county appraisal district performance. It is a ratio study because it uses the appraisal roll values divided by market value. The appraisal roll value is the property value estimated by the local appraisal district. Market value, in simple terms, is the price for which a property would sell under normal conditions.
Primary Purpose of the PVS
The primary purpose of the PVS is to ensure that state funds for public schools are distributed equitably.
Texas funds public education through a combination of state and local funds. Local funding comes from local property taxes. The chief appraiser of each county appraisal district determines local property values, and school districts set tax rates that determine the amount of local tax revenue. State funding is based on the total taxable property value within each school district as determined by the PVS.
The commissioner of Education uses the PVS to ensure equitable distribution of educational funds, so that school districts have roughly the same number of dollars to spend per student, regardless of their wealth. School districts with less taxable property value per student receive more state dollars per pupil than districts with more value per student. The state's fair distribution of school funding depends largely on the Comptroller's taxable value findings.
School Funding Equity Example
A sole reliance on the values set by the 253 Texas appraisal districts could result in inequitable school funding in some school districts. For example, assume that two school districts, districts A and B, are identical in every respect except that the appraisal district does a better job of appraising property for school district B than that for school district A.
Appraisal districts are required to appraise most property at market value–in short, a property's fair selling price. If property values in school district A are at 75 percent of market value, while property values in school district B are at 100 percent of market value, school district A would appear to have less taxable property value per student than school district B. Accordingly, more state funding would flow to school district A, even though the two districts have the same number of students, the same taxable property value and are alike in every way.
Court Challenges/State Response
A series of court cases brought in the 1980s by poor school districts challenged the Texas funding system. One of the issues was that property values were not set at uniform percentages of market value in each school district, resulting in an unfair distribution of funds. As part of its response to these court challenges, the Legislature directed the Texas Comptroller's office to provide an independent estimate of taxable property value in each school district to ensure fair school funding.
The independent estimate is accomplished through the study by adjusting school district property values to market value. If the locally appraised value in a school district (local value) is within an acceptable range of the adjusted value (state value), the Comptroller's Property Tax Division (PTD) certifies the local value to the commissioner of Education. If the local value is outside the acceptable range, PTD certifies the state value, unless the school district is eligible for a grace period–a two-year period during which the local value is used even though it is invalid.
The state funds districts based on either the local value or the state value, depending on which was certified. The state values do not directly affect local property taxes, which are based on the local values provided by each appraisal district. If state value is used in the funding formula, however, it normally is higher than the local value and causes the school district to receive less money than expected. For this reason, school districts should monitor the efforts of their appraisal districts to maintain market values and should encourage them to perform accurate appraisals.
Chapters 41 and 42 of the Texas Education Code describe how the state uses the findings of the PVS in the school funding formula to determine state aid. For questions about state aid or the funding formula, contact the Texas Education Agency at (512) 463-9238.
The PVS is also intended to provide taxpayers, school districts, appraisal districts and the Legislature with measures of appraisal district performance and to provide accountability for appraisal districts that fail to meet certain performance standards. PTD staff achieves this by publishing measures of appraisal level and uniformity, conducting performance audits and appraisal standards reviews.
Appraisal Level and Uniformity
Texas Tax Code §5.10 requires the Comptroller to measure appraisal district performance annually and to publish the results. PTD measures the level and uniformity of property tax appraisals in each appraisal district using data collected in the annual school district study. The level of appraisal shows whether the district has appraised typical properties at 100 percent of the legally required level–normally, the market value. The uniformity of appraisal indicates how much the percentage of market value varies from property to property.
The school district study required by Texas Government Code §403.302 and the appraisal district study required by Texas Property Tax Code §5.10 are jointly referred to as the Comptroller's Property Value Study.
Appraisal Standards Reviews
In addition to the performance audits, Texas Property Tax Code §5.102 requires the Comptroller to perform an appraisal standards review of the appraisal district(s) serving a school district that receives a grace period. This review produces a report with recommendations for improving their appraisal procedures so that future PVS reports will validate their property values. The affected school districts will receive a copy of the Comptroller's findings so that they can work directly with their appraisal district(s) to remedy any problems.
The school district, through its appraisal district, can prevent any adverse funding consequences by achieving valid values in the year after the two-year grace period. It also can meet an important requirement for re-establishing eligibility for a future grace period by achieving valid values for two years in a row.
If the appraisal district fails to take remedial action within a year of the report's issuance, the Comptroller is required to notify the judge of each district court in the county. The district judge, in turn, then must appoint a five-member board of conservators to take control of the appraisal district. The board of conservators supervises the appraisal district until the PVS finds all its component school districts' values are valid.
Other Legal Requirements
Texas Government Code §403.302 requires the Texas Comptroller to conduct the taxable value portion of the property value study.
Taxable value is the estimated property wealth of each school district. By law, it equals the market value of all property in a district, minus certain exemptions and deductions. The Comptroller's estimated taxable value reflects deductions for state-mandated homestead, disabled veterans' exemptions and value limitations. Deductions also are made for reinvestment zones, freeport exemptions, productivity appraisal of qualified agricultural lands, and school tax ceiling for homeowners over age 65 or disabled and other state-mandated exemptions.
In estimating school district taxable values, the Government Code requires the Comptroller to:
- use generally accepted sampling, valuation and statistical techniques;
- ensure that different levels of appraisal on sold and unsold property do not adversely affect the accuracy of the study; and
- test the validity of taxable values and presume that appraisal roll values are correct when values are valid.
Margin of Error
The Comptroller tests the validity of the taxable values assigned to each category of property by the appraisal district as required by the Government Code by constructing a statistical margin of error around the Comptroller's estimate of value for selected property categories in each school district. The state presumes values are valid when they are within the error margin.
Local Value More Than Market Value
Even though a school district's local value is invalid, the law requires the Comptroller to certify the local value if it is more than the state value. This requirement prevents a school district from receiving extra state funding based on a lower state value while receiving local funds from taxes on property appraised above market value.
The Government Code also requires the Comptroller to use the local appraisal roll values to estimate the total taxable value in an eligible school district for up to two years even when the local appraisal roll values are invalid. A school district is eligible for this grace period if it meets three conditions:
- its values are invalid in the most recent property value study;
- its values were valid in the two studies preceding the most recent study; and
- its local value is above 90 percent of the lower threshold of the margin of error.
The PVS is an annual project performed by PTD staff with the assistance of appraisal districts and taxpayers. It begins in February each year and concludes in July of the following year. A new study begins while the previous year's study is being modified by protests, so there is considerable overlap between the two.
Under the Government Code, the agency must certify the preliminary findings of taxable value for each district before February 1 of the year following the year under study. The agency delivers the findings to school and appraisal districts and certifies them to the commissioner of Education. Districts that wish to protest preliminary value findings must do so within 40 days after the date of preliminary certification.
The Comptroller publishes the results of the appraisal district study simultaneously with the school district study and distributes copies to all appraisal districts and members of the Legislature. Although the Property Tax Code does not give appraisal districts the right to protest study findings, the Comptroller allows appeals of level and uniformity measures in an effort to enhance fairness and accuracy.
After PVS protests are complete, the Comptroller certifies final values to the commissioner of education on or about July 1. The commissioner of Education uses the final values to adjust school district funding the following September.
The Government Code and Property Tax Code require the Comptroller to develop ratios and value estimates for property categories and to combine information on the various property categories into overall estimates.
The property categories generally used are:
A. real property: single-family, residential;
B. real property: multifamily, residential;
C. real property: vacant lots and tracts;
D/E. real property: acreage at market value, and farm and ranch improvements;
D1. real property: acreage at productivity value;
F1. real property: commercial;
G. real property: oil, gas and other minerals;
J. real and tangible personal property: utilities; and
L1. personal property: commercial.
Discretionary Review Protocol
Determine County Appraisal District's Compliance with Appraisal Standards and State Laws
Governance and Management
The quality of the property tax system depends on the county appraisal district's (CAD's) board of directors. Individuals serving on the board of directors bring to the board knowledge, judgment and expertise in establishing policies and procedures for the district's organization and operation.
Copy of Comptroller's Property Value Study (PVS) findings for each district in the CAD
- Results of Comptroller's Board of Directors Survey
- Copy of strategic planning documents prepared over the last five years
- Copies of the board-approved budget for prior three years, the notices of public hearing posted to adopt the budget, and the budget calendar showing hearing dates, resolutions from the taxing units approving the budget (statute; IAAO)
- Copies of collection budgets, if the district collects for any taxing units
- Copies of two most recent financial audits and related documents (statute)
- Copies of board minutes for the prior three years
- List of current board members, who they represent, and date board members began serving on the board (statute)
- Copies of board of directors policies (statute)
- A list of all chief or interim chief appraisers employed by the district over the last 10 years and the reason for their leaving, such as retirement, termination or resignation
- Copies of chief appraiser's resume (or some document showing all current certifications), job description, expectations and formal annual evaluation document for last three years, as applicable
- Names of law firms, copies of contracts and budgets for external and internal legal services, as applicable
- The dollar amount actually expended for legal services (broken down by CAD and ARB costs) in the last three years, shown by retainer and hourly billings by the lawyer
People to Interview
Budget or Finance manager
Financial auditor, as necessary
Activities to be Performed
- After carefully analyzing the Property Value Study (PVS) findings for all school districts in the appraisal district, reading the Comptroller's summary assessment of those findings and interviewing the chief appraiser and selected board members, prepare a list of the possible causes identified by the district for the invalid finding in one or more school districts within this appraisal district. For each cause identified, whether the cause is internal to the district or based on some external factor, show what actions the district has taken or are planning to take to remedy the situation.
- Develop an exhibit with the names of board directors, the governmental entity each member represents and the date each member started serving on the board. Identify whether any board members are elected officials.
- Prepare and index of all key board policies, noting any outdated or legislatively required but missing policies. Discuss efforts used to ensure compliance; note any deviations from state law, regulations or rules; and make recommendations for improvement.
- Chart the budget preparation and strategic planning processes for the district and determine how planning and budgeting are linked to ensure that sufficient resources are available to achieve district goals and that available resources are being used wisely. (IAAO Chapter 2)
- Prepare a table showing the budget for the last three years, and examine the district's budget documents for compliance with Texas Tax Code requirements as set forth in Section 6.06; and where deviations are noted, discuss the deviations and suggest possible remedies.
- Prepare a table comparing the budget and actual expenditures for the last three years, showing the percentage change from prior years for each category of the budget and showing the budget-to-actual expenditure deviations. Note areas of significant changes in the budget and in the budget-to-actual numbers, up or down. Through interviews, determine the reason for those changes and how strategic planning may have been used to determine critical needs in the budget. (IAAO Chapter 2).
- Examine the most recent district financial audits and determine how the district has addressed the findings in the management letter or any noted material weaknesses. If material weaknesses or findings are identified, note how the district has rectified the problems or make specific recommendations for immediate remediation.
- Prepare a list of all chief or interim chief appraisers employed by the district over the last 10 years, showing the reasons for any turnover such as retirement, resignation, termination and the like. Examine the chief appraiser's resume (certifications), job description, expectations and evaluations for the last three years. Through interviews, determine the method used to communicate expectations and progress toward meeting those expectations. Discuss in detail the extent to which performance goals are measurable, the subjectivity or objectivity of the evaluation process, and the methods used to monitor and communicate progress annually and throughout the year.
- Prepare a list of law firms showing whether a written contract is in place, the key terms and conditions of each contract, and total budget to total actual expenditures for legal services for the last three years. Through interviews, determine how the district defends values and legal issues and how it offers legal advice.
Generally Accepted Appraisal Practices
Three general appraisal methods or approaches–cost, income and market–must be considered in determining market value. The chief appraiser must use the method most appropriate to a particular property. These three approaches are outlined below.
Additional information about the approaches to determining or appraising value may be found in appraisal textbooks. Appraisers usually determine the value of producing mineral deposits–such as oil, gas and coal–and the value of many utility and commercial properties by using the income approach to value. Most appraisal districts contract with consultants to appraise mineral and utility properties. The chief appraiser can provide information concerning the method used to appraise mineral and utility properties.
When using the cost method of appraisal, the appraiser should:
- use cost data obtained from generally accepted sources;
- adjust appropriately for physical, functional or economic obsolescence;
- provide to the public, upon request and for a reasonable charge, cost data developed and used by the chief appraiser on properties within a property category;
- state clearly the reason for any variation between generally accepted cost data and locally produced cost data, if the data vary by more than 10 percent; and
- provide to a property owner, on request, all applicable market data demonstrating the difference between the replacement cost and the depreciated value of an improvement.
When using the income method of appraisal, the appraiser should:
- analyze comparable rental data available to the chief appraiser or the potential earnings capacity of the property, or both, to estimate the gross income potential of the property;
- analyze comparable operating expense data available to the chief appraiser to estimate the operating expenses of the property;
- analyze comparable data available to the chief appraiser to estimate rates of capitalization or rates of discount; and
- base projections of future rent or income potential and expenses on reasonably clear and appropriate evidence.
When using the market data comparison method, the appraiser should use comparable sales data and adjust the comparable sales data to the subject property.
The Tax Code also requires appraisers to use special methods for land qualifying for agricultural or timber appraisal. (Tax Code, Chapter 23, subchapters C, D, E and H)
Access to maps or geographic information system documentation
- Map and list of all market areas identified by the appraisal district
- Copy of the district re-appraisal plan used last year and the one for this year (statute)
- Policies and procedures documenting the district's appraisal techniques (IAAO)
- Copies of all appraisal district manuals for each relevant category of property (IAAO; statute)
- Documentation on the agricultural use appraisal system and procedures for granting and verifying qualified lands (IAAO; statute)
- Documentation on the timber appraisal system and procedures for granting and verifying qualified lands (IAAO; statute)
- Documentation on the personal property appraisal system and procedures for discovery and verification of personal property
- Copies of internal ratio studies for all categories of properties for the past three years (IAAO)
- Appraisal records (sample examined while on-site)
People to Interview
Chief appraiser and district staff
Activities to be Performed
- Obtain a copy of the reappraisal plan; make a list of the activities required by Section 25.18(b), Tax Code and to the right of each activity state whether it is provided for in the plan, and whether it is actually being performed. Pull appraisal cards, review procedures manuals and interview staff to confirm the activities.
- Compare the district's maps or geographic information system (GIS) to the International Association Assessing Officers' Standard on Digital Cadastral Maps and Parcel Identifiers and note compliance or deviation from the standard. Review and describe the district's appraisal software system and the district's mapping or GIS and describe how each operates. Determine when these systems were installed and/or upgraded; whether they are stand-alone or integrated with other systems; whether the departments are experiencing any major problems with the system; and if any are scheduled for replacement or upgrade in the near future. Detail whether or not the appraisal system and the mapping system/geographic information system are integrated, and if they are not integrated, detail how the system could be integrated.
- Make a list of all of the market areas identified by the appraisal district. Review the maps or GIS system in conjunction with the appraisal district's market areas and note whether market areas have been identified and whether they appear reasonable (rural appraisal districts may not need market areas, while more urban appraisal districts should have several).
- Interview staff members about their property discovery procedures and obtain copies of the district's discovery procedures. Prepare a list of all real property discovery methods such as building permits, physical inspections, telephone directories, sales tax records, etc. Determine whether the district is in compliance with Section 23.12 of the Tax Code as well as IAAO standards on personal property. Note any deviations from the standard and recommend additional procedures that should be in place.
- Prepare a list of all appraisal procedure manuals that the appraisal district provides to staff; state the date when each was revised next to each manual, as well as the usefulness and applicability of the manuals to the appraisal district's operations (adapted to fit the community needs, rather than being a purchased general appraisal guide); and note whether the manual complies with generally accepted appraisal standards such as the Uniform Standards of Professional Appraisal Procedures, the IAAO Standard on Mass Appraisal of Real Property and the IAAO text Property Appraisal and Assessment Administration. If not in compliance, state specifically how it is out of compliance. Also, list any additional manuals that should be provided by the district. Make recommendations for improvement where needed.
- Obtain a copy of internal ratio studies for the past three years. Make a chart showing property categories and show the result of each ratio study next to each property category for which sales exist. Review the internal ratio study results, procedures manuals and appraisal records, and interview staff to determine whether the district is reappraising according to a plan that prioritizes its reappraisal efforts based on the needs reflected in the internal ratio studies. Determine whether the market areas with the lowest appraisal level are being reappraised as soon as possible after a low ratio is shown in the ratio study, and whether all properties are being reappraised within the three-year period required by law. Compare the budget, reappraisal plan and internal ratio studies to determine whether ratio study results are used as significant tools in the budgeting and reappraisal processes. Prepare a timeline, including significant dates, in the ratio study and the budgeting and reappraisal processes. Based on your interviews, comparisons, timeline and other research, describe how these processes are linked and how priorities are set, and recommend further linkages or different priorities, if necessary.
- Interview staff members regarding their procedures for obtaining sales information, review their sales procedures manuals and inspect the appraisal district's sales files. List the methods used by the appraisal district to acquire sales (e.g. multiple listing services, sales questionnaires, agreements with local real estate appraisers, etc). List any methods that might be available to the appraisal district that are not being used. List sources of construction cost data and income data and list other sources not being used.
- Examine and prepare a flowchart of the district's sales screening procedures (procedures to confirm that a sale occurred, to verify the accuracy of sales prices, sales dates and other sales information, and to exclude non-market sales). Note any additional procedures that should be used.
- Examine and list the district's sales adjustment procedures (procedures to adjust sales prices for date of sale, financing, personal property and the like). Note any additional procedures that should be used.
- Describe the district's use of sales, cost and income data in the three approaches to value and write your recommendations for improvement, if any.
- List all property categories appraised by the district (including special appraisal categories) and list the appraisal method(s) used by the district next to each category. If other methods would be more appropriate, so indicate. Next to each category, list whether the district's methods follow the requirements of Chapter 23 of the Tax Code for property appraised at market value, and for qualified agricultural land or other special use property. If any of the district's appraisal methods deviate from the requirements of Chapter 23, describe the deviation.
Resources and Management
In organizing and administering a county appraisal district, the chief appraiser is responsible for hiring, firing and training personnel; for ensuring compliance with a wide range of legal requirements; and for maintaining policies and procedures for the effective operation of the appraisal district.
Conduct a comprehensive examination and evaluation of the district's staffing, personnel qualifications, and the system of positions, as well as assess the human resources in the district available to perform district functions in each county appraisal district reviewed.
- Copy of Comptroller's Exhibit 3
- Copy of operational and personnel policies and procedures (IAAO; statute)
- Copy of district organization chart (IAAO)
- A diagram of all CAD facilities and information pertaining to total square footage of the facilities, as well as the age and condition of each facility
- List of all appraisal district staff, job titles, salaries, length of service in the district and certifications held (IAAO)
- Copies of employee handbook and appraisal district personnel policies and procedures manual
- Copies of all conflict of interest statements signed by staff (Chapter 171, Local Government Code) (statute)
- Any other personnel files not confidential as a matter of law
- Copies of appraisal contracts or other contracts related to appraisal standards and compliance and all contracts relating to district operations and district information technology systems (IAAO)
People to Interview
Chief appraiser and district staff
Board members who express an interest in being interviewed
Activities to be Performed
- Prepare a list of the district's operational policies and procedures; note the last revision date, any missing or incomplete procedures, and missing procedures for day-to-day operations such as purchasing, bank reconciliations, payroll or the like; and discuss how the district ensures legal or regulatory compliance and a system of adequate internal control. Make recommendations for remediation, where applicable.
- Using the list prepared above, and a copy of the most recent organizational charts, interview supervisory staff and show what staff or contractors are responsible for fulfilling each of the operational functions, who serves as their backup for each function and the level of cross-training among staff that would ensure all operational functions can be carried out in the absence of key employees. Where staffing is inadequate, or where internal control weaknesses exist, make recommendations for improvement.
- Using information pertaining to the square footage and physical arrangement of the district office, show the square footage of office space allocated per full-time equivalent and discuss the adequacy of the facilities and any impediments to work or taxpayer access that result from the design or size of the facility.
- Develop an exhibit that lists staff names (names will be omitted in final report), positions (titles), certifications, length of service in the district and salary information. Indicate how each person's qualifications comply with appraisal standards and state laws. Note any areas of deviation from the law or guidelines, and recommend improvements. Compare the current staffing information to that reported to the Comptroller on the most recent Operations Report and discuss variances.
- Examine a copy of the employee handbook and other personnel-related policies, and prepare a list of the key topical areas covered. Specifically compare the district's policies on staff conflicts of interest to signed employee conflict statements, noting any identified weaknesses in the district's policies or improperly documented employee conflict statements.
- Prepare an organization chart showing both employee and contract positions, and to the extent possible, explain the reporting relationships between contractors and staff, and between supervisors and staff. Note areas in which the span of control is too great or too small, and where internal organizational weaknesses may impede the organization's efficiency. Make recommendations for improvement where needed.
- Examine the supervisor-to-staff ratios, the staff-to-parcel ratios and the appraiser to locally appraised parcel count in the district as compared to statewide averages and to peer districts, and note significant variances. Through interviews, determine the reason for variances and make recommendations accordingly.
- Examine all contracts entered into by the district for the last year to determine compliance with the Tax Code; Local Government Code Chapter 271, Subchapter C; and IAAO Chapter 2.10 provisions. Prepare a list of all contracts, the name of the contractor, the dollar amount of the contract, expiration date of the contract, the type of bid procurement process used to enter into the contract and the position name of the person in the district assigned to monitor contract compliance, pay invoices and act as liaison with the contractor. Where compliance deviations are noted, discuss the deviations and make recommendations to bring the district into compliance with state laws and regulations; review the district's contract monitoring and invoice payment procedures and review all contracts for IAAO compliance and contracting practices.
- Examine each employee's job descriptions, expectations and evaluations for the last three years and determine, through interviews, the method used to communicate expectations and progress toward meeting those expectations. Discuss, in detail, the extent to which performance goals are measurable, the subjectivity or objectivity of the evaluation process, and the methods used to monitor and communicate progress annually and throughout the year.
Information Processing and Data Collection
Computers have become a necessity for all appraisal districts. The use of computers allows the district to amass large amounts of data, perform complex tasks that otherwise would take hundreds of staff hours to perform manually, and more accurately analyze trend data to ensure accurate valuation of similar properties.
Technology infrastructure is the underlying system of cabling, phone lines, hubs, switches, routers and other devices that connect the various parts of an organization through a wide area network (WAN) and through a series of local area networks (LANs). Maintaining a strong infrastructure and integrating the various systems used by the district is critical to increased staff productivity, fewer costly data errors and better customer service to the users, community members and the taxing units dependent on the appraisal district for critical information.
Documentation for the district's information processing system, including contracts and specifications on the appraisal software system and the mapping/geographic information system (IAAO), and a list of all hardware and other software
- Documentation on the internal control mechanisms used to ensure uniformity and accuracy of appraisals (IAAO; statute)
- Copies of documentation or procedures for gathering, entering, verifying, confirming, and maintaining data electronically (IAAO)
- Copies of written procedures for the use of electronic data in the appraisal process (IAAO)
- Procedures and systemic capabilities and controls within the electronic data systems that ensure compliance with (statute; rule):
- uniform tax records system (Rule 9.3003)
- appraisal cards (Rule 9.3001)
- tax maps (Rule 9.3002)
- alphabetical index of property owners (Rule 9.3009)
- partial exemptions lists (Rule 9.310)
- absolute exemption lists (Rule 9.3011)
- special appraisal lists (Rule 9.3012)
- property identification system (Rule 9.3014)
- certification of appraisal roll (Rule 9.3059)
- Copy of the district's disaster recovery plan
- Copies of procedures on data security and integrity
People to Interview
Chief appraiser and District staff
Selected members of the board of directors
IT and Mapping staff
Activities to be Performed
- Compile a list of specialized appraisal software and major administrative programs being used by the district. Review and describe the district's appraisal software system and the district's mapping or geographic information systems and describe how each operates. Determine when these systems were installed and/or upgraded, whether they are standalone or integrated with other systems, whether the districts or departments are experiencing any major problems with the system and if any are scheduled for replacement or upgrade in the near future. Explain whether or not the appraisal system and the mapping system/geographic information system are integrated, and if they are not integrated, explain how the system could be integrated. Examine all documentation and output to determine whether the current information system adequately ensures compliance with applicable Comptroller rules.
- Examine the disaster recovery plan and any other documents that show how the district has prepared for the event of a disaster. List the major components of the plan and how the plan ensures business continuity following a disaster. In the absence of a formal plan, determine what elements of a plan are in place and what still remains to be done.
- Examine and diagram the internal control mechanisms, including data security and integrity, within the district's information management system(s) to determine whether sufficient controls exist to ensure uniformity and accuracy of appraisals and the protection of data from unauthorized access. Examine measures for uniformity, such as a ratio study, as outlined in the uniform Standards of Professional Appraisal Practice (USPAP), to determine if additional controls are needed. Where control weaknesses are noted, discuss and make recommendations for improvement.
- Examine and diagram the district's method of obtaining, entering and maintaining all data on the computer system(s) to determine if the methods used are in compliance with USPAP. Where system or procedural weaknesses are noted, discuss and make recommendations for improvement.
- Examine and describe the district's Web site. Compile a list of information the district provides on its Web site. If the district does not have a Web site, outline what the district needs to do to set up a Web site.
All appraisal districts in Texas are required by law to post various notices, send various reports to the taxing units and to the state, and comply with a host of laws, rules and regulations.
Appraisal districts have three primary functions: property discovery, property listing and property appraisal. Although much attention is placed on the appraisal process itself, the administrative functions of discovery and listing are equally important to accurate and timely appraisal.
Another important appraisal district responsibility is the administration of exemptions. An exemption is an exclusion of all or part of a property's value from taxation. Texas law grants a number of total and partial exemptions. Between January and May, the chief appraiser decides which taxpayers and which properties will receive exemptions.
The chief appraiser has legal responsibilities for preparing the appraisal roll within a statutory timeframe.
- Copies of all state mandated forms and applications currently used by the district for the last two years
- Documentation showing evidence of timely compliance with certification of tax rolls to each taxing unit in the district over the last three years
- Documentation showing compliance with the deadline for delivery of applications for special appraisal and exemptions requiring annual applications
- Documentation showing timely compliance with all state reporting requirements
- Access to a sample of appraisal records
- Procedures relating to renditions and access to a sample of submitted renditions
- Copy of policies and procedures for granting, verifying or denying exemptions
- Copy of the records retention policy filed with the State Library and Archives Commission
- Procedures for document storage, retention and destruction
- Copies of notification of annual application of exemptions/special appraisal for last two years
People to Interview
Chief appraiser and district staff
Designated records management officer
Taxing unit representatives, as appropriate
2.5.1 Activities to Perform
- Prepare a list of all state-mandated forms and applications, and after examining district forms and applications, note if all of the district's forms are in compliance with the Comptroller's rules found at 34 Texas Administrative Code (TAC) §§ 9.402, 9.415, 9.417 and 9.419. Where forms are found to be out of compliance, make recommendations for achieving full compliance.
- Examine a sample of the district's appraisal records and for each record examined, note if the records contain all of the information required to be certified to the Comptroller annually, as set forth in Comptroller's rule, 34 TAC §9.3059 and Texas Property Tax Code §26.01. Through interviews, determine how the records are maintained and when records were most recently updated.
- Examine district records management policies and procedures and prepare a side-by-side comparison of the requirements set out in the Texas Local Government Records Act (Title 6, Subtitle C, Local Government Code). Contact the State Library in Austin to determine whether all required paperwork has been filed with their offices. Interview the designated records management officer, and discuss the process used by the district to ensure compliance with state laws and policy. Where weaknesses are noted, make recommendations for improvement.
- Examine the district's documentation for evidence of compliance with certification of the appraisal roll to each taxing unit as required by law, and note the certification dates for each of the taxing units in each of the last three years. Through select interviews with taxing units, confirm that appraisal district records are accurate and complete. If certifications were not done in a timely manner or if evidence of timely certification is not available, determine the reason for the delay and determine what actions have been taken to ensure compliance in the future. Where applicable, make recommendations for improvements that will ensure full compliance.
- Examine the documentation proving notification of annual application of exemptions/special appraisal for the last two years, and in a formal paragraph, discuss whether this was done in full compliance with Sections 11.11-11.47 of the Tax Code. If deviations have occurred, prepare a discussion of the reasons for noncompliance and any steps taken to remedy the situation. Where appropriate, make recommendations for compliance.
- Examine policies and procedures relating to exemptions and a sample of properties with exemptions and the corresponding documentation. Prepare a write-up discussing the district's level of compliance with the Tax Code on granting, verifying and denying exemptions, and/or special appraisals, as shown in Sections 11.11-11.47 of the Tax Code. Where system or procedural weaknesses are noted, discuss and make recommendations for improvement.
Industry Appraisal Standards
Uniform Standard of Professional Appraisal Practice Standards are available from:
The Appraisal Foundation
1029 Vermont Avenue, NW, Suite 900
Washington, DC 20005-3517
and may be viewed on the Internet at:
The International Association of Assessing Officers Standards' Standards of Assessment Practice are available from:
International Association of Assessing Officers
130 East Randolph St., Suite 850
Chicago, IL, 60601
Web site: www.iaao.org.
Concho County Appraisal District Self-Evaluation Questionnaire
Texas Comptroller of Public Accounts
Property Tax Division
International Association of Assessing Officers
Self Evaluation Questionnaire
Concho Country Appraisal District
Chapter 1: Setting, Legal Framework, Value Standard and Assessment Cycle
- What does the assessment office do to keep current with legislative proposal, laws, and court decisions?
Concho CAD is a member of TAAD & TAAO. Monthly publications of the Appraiser, TAN, Statement & Window on Local Government are available to all. Several annotated copies of the current tax code and laws book are available at each employees desk and each employee also has access via the internet to the comptrollers web site. The office participates in seminars offered by the State and area associations. The CAD's law firm (Linebarger, ET AL) provides updates, and our software vendor, Pritchard and Abbott keeps current with legislative changes as well. The Chief Appraiser and all registered staff members attend classes and conferences.
- Does the law require general uniformity in property taxation?
Yes, Article VIII Section 1 of the Texas Constitution states, "Taxation shall be equal and uniform and tax should be in proportion to value. "The Peveto Bill sets up standards for valuation in taxation as represented in the Texas Property Tax Code. The base valuations are done by schedules to insure uniformity within Classes of improvements; however, through legislation and special interests, exemptions are granted and caps are applied giving preferential treatment to different property classes and individuals.
- What measures in the law support a current market value standard, and what matters undercut such a standard?
Section 23-01 of Texas Property Tax Code requires all property be appraised at market value other than exceptions set out in the code. Use of cost, market, and income approaches to value are validated by the code and support a market value standard. Requirement of ratio studies should be considered supportive. Remedies are allowed for appraisals in excess of market value so there are punitive measures if the market value standard is not used. Limits on increase of value, laws requiring a different standard of value, and no laws requiring disclosure of sales undercut a market value standard. Small districts having few or no sales restrict the ability to measure the market standard.
- Does the assessment district have the size, resources and fiscal capacity to perform the assessment function effectively and efficiently?
No, since the current CA took office we have had a couple employees not performing their duties adequately resulting in 25.10 notices being sent late in 2005 and even later in 2006 making certification late which lead to tax rates being set late. Therefore one employee chose early retirement and the other is no longer employed at the district. Because of time and budget constraints we have not been able to replace but one employee. She has only been with the district for 4 months. Currently we are physically understaffed and under skilled.
Chapter 2: Resources and Management
- Does the assessment office engage in formal planning?
Yes, the staff is constantly being made aware of areas that need attention. Taxpayers, realtors, septic system inspectors, ARB proceedings, sales, property listings and drive by are all sources of information for properties needing to be reviewed and/or additions to the appraisal roll. Formal planning for all departments is conducted at least twice per year for budget preparation. Please see the adopted appraisal plan submitted with this review.
- Has the assessment office prepared a formal estimate of resources it requires?
Yes, all resources are outlined in the annual budget.
- Is office space sufficient, and are other facilities adequate?
The office contains 2500 on the lower floor. The upstairs floor contains the same amount and is shared with the County and the Bank for storage.
- Are performance– or program-based budgeting methods used?
Yes, the budget is prepared with performance, collection and appraisal programs taken into consideration. Monthly reports are provided to the board of directors. Overages and underage are used to determine changes needed in the coming year. We also keep track of special needs, legislative changes such as binding arbitration more information on notices and statement print jobs, or when the appraisal district wishes to upgrade an existing department.
- Is the office's funding adequate?
Salaries are comparable with same size counties according to the comptroller's appraisal district operations report printed annually. The 2007 Appraisal and Collections budget was denied by a majority of the voting taxing entities due to the lateness of the certified values. We had to remove a proposed position in an already under staffed office.
- Does the staff have the right skills?
The Chief Appraiser is Registered Professional Appraiser and Registered Assessor-Collector. We have one clerk with three years experience and one bookkeeper with 25 years experience but has only been with the district for 4 months. She will be registered with BTPE and begin classes January 2007.
- Are salaries and benefits competitive?
Our salaries and benefits seem to be competitive but when you take into consideration someone moving to a city with less than 300 people and is anywhere from 15 to 45 miles from the surrounding cities it is very difficult to get qualified persons to move or even travel to our office for the salaries we are able to give.
- Is the assessment office well organized?
Yes, the organizational chart and job descriptions are attached.
- Is the staff well managed?
Yes, we have personnel policy that outlines the duties and responsibilities of the staff and steps of the chain of command.
- Are skills in procurement and contract management sufficient?
Procurement and contract management are done to the best of our ability. Detailed bids made specifically to detail our needs are carefully done. The Chief Appraiser and the Board of Directors, carefully comparing submissions with requests, review contracts and bids received. Services are sought in a timely manner to secure funding as required. Pre-qualifying vendors is scarcely necessary due to the limited number of vendors available in this small area and the limited number of vendors able to perform the specialized services required. The Chief Appraiser monitors the performance of all contracted firms.
- Is the staff quality-conscious?
Yes. The staff is recruited and trained to adhere to quality standards and is assisted by computer software, administrative edits, and valuation programs. Also, the staff realizes the importance of taxpayer opinions and feedback.
Chapter 3: Computerization
- Do you have at least one computer workstation (terminal or personal computer) for each appropriate staff member?
The office provides each and every employee a computer workstation with additional workstations available for counter help.
- Does the infrastructure provide for the following services? (See page 23 of the Assessment Guide for details)
- In addition to color printers at individual workstations, employees have access to three different network printers: One standard laser printer, one "high-speed" laser printer, and one Xerox color work station.
- Our CAMA server contains mirrored drives to protect from hard drive failure and has a monitored battery backup, which triggers a safe shutdown in the event of an extended power failure. Tape backups are conducted daily utilizing a tape rotation system. These tapes are then stored in a fireproof, concrete vault with one copy stored by the software vendor. Other systems (e.g., administrative, mapping) are conducted in the same manner.
- An office suite is available on every workstation, to include email, spreadsheet and database creation and work processing. Internet access is available on every workstation as well.
- Our CAMA software provides for extensive user rights management including, but not limited to, day and time of day restrictions, viewing of data and data entry restrictions.
- Our systems provides for rapid data entry and inquiry. All workstations and servers are near state of the art and our software is routinely updated. Outdated hardware is routinely updated or replaced. We will be getting updated workstations and server the third week of November 2006.
- All employees have "domain name" email to foster rapid and accurate communications and accurate communications.
- Is the system based on a database management system (DBMS)–preferably a relational DBMS–that provides integration possibilities with other applications not provided by the base system?
Our CAMA system is based on an industry-standard ODBC-compliant database which allows for integrations with other ODBC compliant systems.
- Does the assessment office maintain data security and integrity including an audit trail of changes in records that affect assessments?
Our computer system maintains a change log containing the identity of the person who made the change, date the change was made, and the nature of the change. It generates a report capable of telling when users were logged in, what was accessed and what changes were made. The system has a firewall to protect from outside influences.
- Does the computer system adequately address issues of security and privacy?
As discussed above, the system provides for extensive user rights administration to protect from internal unauthorized use. All workstations are password-protected. The CAMA system is also password-protected.
- Does the system provide query/reporting tools to allow advanced users to work independently of programming personnel in addressing needs that had not been anticipated at the time the system was first installed?
Our system supports an extensive industry standard query builder.
- Does the computer system support multiyear processing?
Yes, our system displays complete history back to 2001 and has the ability to supplement any year. We also have the ability to create future year layers for the storage of incoming information and the complete appraisal cycle.
- Does the office provide public web access to information and services?
Not at this time we are looking into it and have incorporated funds into the 2007 budget.
- Does the system provide geographic information services (GIS) capabilities?
Our system integrates GIS into the CAMA making it possible for appraisers to more easily locate properties and to do geographic searches. The system also generates maps from custom queries based on user-defined parameters. To accomplish this, our system incorporates data from our Bentley Redline GIS-based geographic information system.
- Does the system provide advanced workflow processing and management?
A practically unlimited number of reports and tools are available on our software to aid in workflow and management. Some of those reports are change log reports, next inspection reports, owner transfer reports, ag reports, exemption reports, etc.
- Does the system offer the ability to manage document images or photo imagery?
The system allows users to download images from a camera or scan images directly into the system and attach that image to a specific account, or to link to an image, which already exists.
Chapter 4: Mapping
- Does the assessment office maintain a complete set of cadastral maps showing the size, shape, and location of each parcel in the jurisdiction?
Concho CAD is in the second year of a four to six year computerized mapping project to establish a uniform set of maps. The district maintains a hard-copy non-computerized mapping system, which is currently being converted to a computerized system.
- Are maps maintained using professionally accepted standards for size, scale, payout, lines, symbols and the like?
Maps are generated on an as needed basis to whatever size, scale, etc., the user desires. The office has the capability to generate or have generated maps and to symbolize those maps at any scale a user may desire. The underlying data is maintained to industry and professional standards.
- Are parcel splits and combinations noted on maps within one month of a deed's recordation?
Every effort is made to update map data in an expedited manner. A CAD employee goes to the County Clerks office and makes copies of the recorded deeds. The information on the deed is transferred to a change form then the take-off forms are distributed to the appropriate person to make changes to the appraisal records and maps. We have been looking into using the laptop and scanner to make this process faster and more efficient but we have had difficulties in getting it approved with the County/District Clerk due to the use of County electricity.
- Are all parcels assigned a parcel identifier that uniquely identifies the parcel?
No, the only parcels that are assigned an identifier that uniquely identifies the parcel is properties in the lake subdivisions that were done 10-15 years ago. We have not had any new subdivisions and all other parcels were assigned numbers at random. This is a problem the current Chief Appraiser has been researching and currently budget restraints and manpower interfere with accomplishing the correction of this task.
After a review of the preliminary draft of the ASR, the chief appraiser added that "the district has hired an individual to redo the account numbering system to incorporate unique identifiers for each parcel. The system should be in place by end of 2007."
- Are geographic coordinates displayed on cadastral maps?
Yes. State plane coordinates are maintained in the computerized maps.
- Does the assessment office maintain map representations of spatial assessment areas and the valuation influences?
Not at this time our mapping system is not complete and we cannot fully utilize this function.
- Does the assessment office have computerized maps?
Yes. Some computerized maps are now available. We are currently running Bentley Redline software. We anticipate the completing the computerized mapping of the District within the next four years.
- Are the assessment office's maps and records part of a multipurpose GIS or LIS?
Yes. Concho CAD plans to integrate the completed computerized map product with the city, county and school entities in a cooperative effort to fill public and governmental information needs.
Chapter 5: Data Collection
- Do computer records contain information on current property use, highest and best (most probable) use, and indicators of legal uses, such as zoning?
Yes. Identifiers are in scheduling and coding type but with the absence of any zoning; economics dictate highest and best use.
- Does the assessment office maintain computerized data on land attributes important in the local market?
Yes, location, soil type, utility, transportation access, and water influence is noted in schedules and type coding.
- Does the assessment office physically inspect properties at least every four to six years?
Yes. Concho CAD's reappraisal plan establishes a 3-year reappraisal cycle; however market movements sometime necessitate a shorter term.
- Does your assessment office regularly obtain copies of building permits, occupancy permits, or both, and does it conduct physical inspections of affected properties?
We do not regularly obtain copies of building permits but we do get a copy of utility connections, changes and transfers.
- Does the assessment office maintain only data necessary in valuation or the support of values?
No, many items are kept that are essential to the valuation, and are required by law such as: past renditions, exemption applications, prior ARB determinations, and the computer has historical information on all parcels for changes made.
- Is the residential property record card well designed and supported by a data-coding manual and training program?
Yes, the residential appraisal card is maintained by two sources. One is a hard-copy record depicting the sketch of improvements and property history. The other is a record of the associated value information in a computer database.
- Does your office use a hand held computer for field data collection?
No. The CAD has a laptop purchased for this reason, however the prior appraisers elected to use the printed cards and make changes back at the office.
- Does the assessment office have a computerized edit program that includes both range and consistency checks?
Numerous checks and balances are available in our software, from making sure the legal acreage and the pricing acreage balance to checking for excessive values. We run those errors and edits monthly.
- Are data for commercial properties collected by experienced appraisers?
Yes. In addition, the appraisal district contracts with an outside firm of appraisal engineers for the collection of data and appraisal of industrial properties.
- Does the assessment office have a program of routinely collecting income data for apartment buildings, retail stores, office buildings, and other commonly leased or rented properties?
No. Concho County does not have any apartments, and very few retail stores.
Chapter 6: Land Evaluation
- Are land sales reviewed, confirmed, and maintained in a sales file?
Yes, our land sales are kept in the computer system. They are received and confirmed through multiple sources.
- Do you stratify land by zoning or use and by location?
Land is stratified by use and location. Other units of separation include lakefront, view, and highway or main thoroughfare frontage.
- Are land sales analyzed in terms of value per unit, and are the per unit values plotted on maps?
Land sales are analyzed in terms of value per unit but are not currently plotted on maps.
- In downtown and other high density commercial areas, are standard unit values assigned to each block face?
Concho County does not have any high-density areas. Our county is in a rural area where highway frontage is the determining factor in value and is priced as such
- Does the assessment office use market-derived tables to make size or depth adjustments?
Not at this time. We will be plotting market sales to adjust lots in town this coming appraisal year.
- Does the assessment office have a standard procedure for adjusting land values for shape or corner location, and are the adjustments based on market analysis?
- Are adjustments made for positive location (situs) factors, such as golf course frontage, other premium frontage, premium view, or negative situs factors, such as excess traffic, limited access, adverse topography?
Most of these adjustments are reflected in the land schedules themselves, both positive and negative.
- Does the assessment office use spreadsheets or statistical software to help develop land values?
- Does the assessment office use a geographic information system to assist in data quality control and fine-tuning valuation models?
Some, our GIS is not fully functional and complete at this time
- In built-up areas with few vacant land sales, does the assessment office use the abstraction, allocation, or land residual capitalization methods to derive standard unit values?
- Does the assessment office use the cost-of-development method in the appraisal of large tracts of land awaiting development?
We do not have any large tracts of land awaiting development but if we did any large tracts would continue to be used as agriculture. Pre-development market value would still be the same as surrounding tracts.
Chapter 7: Residential Property Valuation
- Does the assessment office place primary emphasis on the sales comparison approach in the appraisal of subdivision homes, condominiums, and town homes?
Yes. While mass appraisal techniques are employed, market approach is used on homogeneous properties.
- Are sales ratios analyzed by neighborhood, size, age, and other key features during the appraisal process?
Not as they should be.
After a review of the preliminary draft of the ASR, the chief appraiser added that "This has been corrected for the 2007 appraisal year with assistance from Lisco Appraisal Services."
- Are value estimates reviewed by appraisers and reconciled before generation of final values?
- Are comparable sales readily available and used for residential property valuation, analysis, and value support?
- Are statistical models technically sound and the coefficients reasonable?
- Are cost schedules checked against local buildings of known cost and adjusted as necessary?
The district subscribes to Marshall and Swift valuation service and utilizes it's cost schedules and that is compared with limited local new construction.
- Are cost schedules fully computerized?
- Are depreciation schedules based on sales analysis?
Depreciation schedules are basic age life models with effective age and outside influence adjustments made on individual properties.
Chapter 8: Commercial Property Valuation
- Does the assessment office employ the three approaches to value in appraising business properties?
Yes, when adequate data permits all available methods are employed.
- Has the assessment office defined separate market areas or neighborhoods for business properties?
Yes, business properties are located generally along the two major highways in the county.
- Does the assessment office make a comprehensive effort to collect local income and expense data?
Yes, every effort is attempted; however very little response is generated.
- Does the assessment office use commercial publications to help in the development of rental rates, vacancy ratios, expenses and expense ratios, and capitalization rates?
We do not have any large chain commercial properties and our properties are "Mom & Pop" operations that do not lend themselves to national publications.
- In the income approach, does the office maintain automated income data to analyze reported sales, revenue, and expense data to develop the following: typical market rents and other income, vacancy ratios, expense ratios, capitalization rates and/or gross rent multipliers?
After a review of the preliminary draft of the ASR, the chief appraiser added, "Not in house, but our outside appraisal firms have this information readily available."
- Are available sales used to: Help derive capitalization rates and income multipliers? Help calibrate depreciation schedules? Development benchmark per-unit values or build market models?
Insufficient sales are available to develop business property categories, but are used to check the tables and schedules for accuracy and make adjustments as necessary.
- In the cost approach, have base rates and cost factors been developed from local cost data or adjusted to the local market?
Yes, national tables are used and adjusted to the local area using sales analysis.
- Are observed physical condition, economic obsolescence, and functional obsolescence considered in estimating total depreciation?
Yes, physical condition is done at the time of inspection; functional and economic obsolescence are usually made aware at the time of informal and formal review processes.
- Are automated value estimates reviewed and reconciled by senior appraisers?
- Does your assessment office employ software tools in analyzing commercial properties?
Chapter 9: Sales Data, Ratio Studies, and Stratification
- Are real estate sales properly screened?
Yes. Sales are verified through comptrollers' letters, information gathered from buyers and sellers as well as deed records. The sales are screened by the Chief Appraiser and when not considered to be a market sale they are coded and the reason given and excluded from the ratio study.
- Does the assessment office's computer system maintain a "snapshot" of properties at time of sale?
- Are sales used in valuation analyses and ratio studies adjusted to the valuation date?
- Has the assessment office stratified residential properties by market area and sub-area (neighborhood)?
An infinite number of stratifications are possible but the standards such as: school, class, area and influence are most commonly used.
- Are ratio studies conducted in a timely manner?
The District is capable of conducting ratio studies at will. The ratio study is a primary component of the District's reappraisal plan.
- Does the assessment office use ratio studies in planning and determining reappraisal priorities?
Reappraisal priorities are established from these ratio studies.
- Does the assessment office conduct ratio studies by property groups and subgroups?
The districts ratio studies can be conducted by use, by addition/subdivision, and by school district. Once the GIS system is in place it will be possible to analyze identified sub groups.
- Does the assessment office have the capability of running ratio studies by user-selected combinations of property characteristics?
- Does the ratio study program compute standard measures of level and uniformity and confidence intervals?
Yes, we measure mean, median, mode and standard deviation as well as weighted.
- Does the ratio study software have graphics capabilities?
When the GIS system is in place the District will be capable of producing maps with plotted sales information.
- Does the assessment office supplement ratio study analyses with tests to ensure that unsold properties have been appraised similarly to properties that have been sold?
Yes, adjustments are made to schedules that value both sold and unsold properties alike.
Chapter 10: Personal Property Assessment
- Does the assessment office systematically employ several methods to discover taxable personal property?
Yes, personal property is discovered by physical inspection, renditions, written and verbal media, bills of sale, and word of mouth.
- Does the assessment office deliver personal property declaration forms to owners of taxable personal property?
Yes, annual renditions and notices are sent to every personal property account. We use all state recommended forms.
- Does the assessment office follow up on nonreturns by making supplemental mailings, filed inspections, and estimated assessments?
Yes. Our software makes it possible to flag the accounts, which do to have a rendition posted so we may impose the 10% penalty. Rendition forms are mailed again with Penalty Notification letters. In working the renditions the appraiser compares the current to the previous year and does contact the owner if there is a question in the integrity of the rendition. If a taxpayer refuses to co-operate, the account may be assessed using the square foot method or estimated using a comparable business and the best information available.
- Are personal property reporting forms tailored to the needs of different businesses and industries, and do they collect the appropriate data including information on fully depreciated items?
Concho CAD uses the state-mandated renditions, for general personal property, aircraft, special inventory, leased equipment, etc. We accept renditions submitted on personal or computerized forms from companies and agents as long as it is signed, dated and all the required information is included. We do not fully depreciate personal property as long as it has value in use. The bottom line depreciation varies depending on the type of equipment or whether it could be considered as salvage.
- Does the assessment office coordinate real and personal property field inspections to ensure the fixtures, trade fixtures, and leasehold improvement are identified and properly classified?
- Does the assessment office audit returns and inspect businesses to ensure complete and accurate reporting?
- Does the assessment office employ all appropriate approaches to appraisal in valuing personal property?
Concho CAD uses all appropriate approaches to appraisal in valuing personal property. Very little sales information is known. We use reported cost information along with tables and schedules to make adjustments. We have no personal property using the income approach at this time.
- In the cost approach, does the assessment office maintain separate cost trend and depreciation indexes for each class of personal property?
Yes, we have different classification of personal property and the appropriate schedule and depreciation schedules are used.
- Does the assessment office use price guides to value items that are frequently sold as used items?
- Does the assessment office use the income approach to value leased equipment?
No. We use the cost approach for leased equipment. Most leased equipment is rendered on a depreciated cost basis.
After a review of the preliminary draft of the ASR, the chief appraiser added that "the contracted firm uses the income approach for the industrial properties they appraise.
Chapter 11: Assessment Administration
- Does the assessment office update ownership and legal description information within thirty days of a transfer being recorded?
No. Short CAD staffing and limited cooperation from the clerk's office makes this an impossibility at this time. Usually just before tax statements are calculated is the only time we are able to accomplish this task within 30 days of the recording.
After a review of the preliminary draft of the ASR, the chief appraiser added that "this has improved during 2007 and we are able to accomplish this more frequently."
- Do computer records contain the source of all appraised or assessed values?
Yes, our system houses data by year and a continuous change log is maintained.
- Does the assessment office verify eligibility for exemptions or other relief?
Yes. Ownership and date of ownership records are verified along with proper mailing addresses. Obituaries are monitored and voters' registrations and drivers licenses are checked as appropriate. Address changes also trigger an investigation of continuance of an exemption. A check for multiple homesteads including previous out-of-county addresses is done. Proof of eligibility for any exemption is required. Agricultural applications are required from new owners, whenever change to the property occurs and when any question regarding the property arises. Religious and charitable organizations are required to make application and by-laws and charters are carefully checked.
- Do you ensure that properties are assigned to the correct tax rate area?
- Do you notify property owners by mail of the amount and reason for changes in appraised and assessed values, as well as of their right to appeal?
Yes. Notice of Appraised Value, ARB Procedures and Taxpayer Rights and Remedies are furnished to the taxpayer. Informal meetings with appraisal staff members are always made available to the taxpayer or their agents.
- Does your jurisdiction produce computerized assessment rolls or listings, recapitulations of the rolls, and indexes to all of the properties on the assessments rolls or listings?
Yes, the rolls are electronically stored and are printed upon request. We are working on having a web page in 2007 along with a PC available for public use.
Chapter 12: Defense of Values
- Does a supervisory agency or review body have the power to review values and valuation methods on its initiative, or is the assessment office required to submit valuations to a regulatory body for approval before taxes can be levied?
The appraisal review board has the authority to review and change values of those properties brought before it either by a taxpayer protest or a taxing unit challenge. They do not have the authority to review values on its own initiative. The ARB approves the appraisal roll before the Chief Appraiser certifies it to the taxing entities. After certification the information is submitted to the PTD for use in the property value study.
- Are owners and taxpayers encouraged to discuss concerns and complaints with the assessment office before lodging a formal appeal?
Yes. Every taxpayer is welcome to discuss their concerns before they advance to the appraisal review board. Every staff member mans the counter and phones so each person who comes in the office or calls is able to discuss their concerns or have their questions answered. If no solution is found then it is passed to the ARB scheduler. Many phone calls and questions are not documented if they are just routine information and require no action.
- Do you track the status of each formal appeal to ensure that it is appropriately disposed of and that records are properly updated?
Yes. Our software handles the protest from the time of the scheduling of the appointment to the final disposition. Records are kept of each stage of the process. After appointments are made, timely letters are mailed to the owner and/or agent informing them of the date, time and location of the hearing. A sign-in sheet is kept at the counter, the person(s) appearing is logged in and minutes kept of the hearing. A recording is also kept. Final determination letters are mailed by certified mail and reports run to see if any were missed.
- Does your office have a documented process for handling formal appeals?
Yes, the protests are monitored by the computer system until their final disposition.
Since the original answers, the chief appraiser added that "the system also maintains a history of protests."
- When the valuation is difficult and considerable value is at issue, does the assessment office obtain an independent review from another appraiser as part of the defense in a formal appeal?
The Appraisal District does not solicit independent review for the ARB that require payment. We make use of whatever contacts we have in the profession, such as checking with other districts on properties that are one-of-a-kind here, but common elsewhere, realtors, abstract companies and fee appraisers that may be willing to talk with us. Capital Appraisal Group Incorporated furnishes whatever expertise we may need on minerals, industrial and utilities. When the appeal is carried to district court or arbitration, outside expertise is retained when necessary.
Chapter 13: Public Relations
- Are you required to submit information to a regulatory body for approval?
No. There is no requirement regarding public relations that our work or policy be approved. However, the staff is instructed to provide all non-confidential information possible.
- Does your office have an active public relations program that reaches out to the public?
The CAD publishes quarter page notices for homestead exemptions, special/agricultural appraisal, and personal property renditions. The Taxpayers' Rights, Remedies and Responsibilities are always available at the counter and portions included in the appraisal notice mail outs. A copy of the Public information-news release items packet sent out by the Comptrollers office is always given to the local newspaper with a request for publishing the taxpayer information articles. The County Judge and his wife own the only newspaper in the county and none of the articles have yet to be published. Our county does not have a local radio station. We are in the process of getting a web site.
- Does the assessment office have an active program of public appearances to keep the public informed of actions that may affect them?
The Chief Appraiser has attended some of the taxing entity board meetings. But the program is not as active as it should be.
- Can property records be accessed by parcel identified, situs address, and owner?
Yes, our software offers many different ways to search for property information. Upon the taxpayer's request and for a small fee, we run lists designed by the taxpayer for many different types of information. The staff is also available for assistance in locating property and information.
- Does your office take advantage of automated mapping or GIS to facilitate public access to information?
Yes. Development of a computerized mapping/GIS system is currently under way. Portions of the District's records have been completed. Total completion is approximately four years away.
- Does the assessment office have available for public distribution a nontechnical description of how property is assessed, of appeal rights and procedures, of exemptions and other forms of tax relief, and of how property tax bills are calculated?
Yes. Taxpayers' Rights Remedies and Responsibilities are available at the counter and Truth in Taxation booklets are available at each employee's workstation. All employees are being trained to meet with the taxpayer and discuss the tax system and the appraisal procedures and methods. The CAD reappraisal plan also has valuable taxpayer information that is available upon request.