Appraisal Standards Review Protocol
Perform an Appraisal Standards Review (ASR) to Determine Whether a County Appraisal District Complies with All Appraisal Standards, Procedures and Methodologies
PTAD uses this protocol to perform an appraisal standards review of a county appraisal district (CAD). The protocol outlines the minimum number of activities that a reviewer must perform to gather the information and documentation needed to assess compliance with appraisal standards, procedures and methodologies, as called for in Tax Code Section 5.102. The Comptroller will determine whether or not the CAD is in compliance with generally accepted appraisal standards and practices.
This protocol establishes a minimum list of the data needs, including interviews, and an initial set of questions that should be asked to solicit information for the review. The reviewer may develop additional questions as required during the course of the ASR.
Generally Accepted Appraisal Practices
An appraiser must consider three general appraisal methods or approaches–cost, income and market–in determining the market value of a property. The chief appraiser must use the method most appropriate in appraising a particular property. These three approaches are outlined below.
Appraisers usually determine the value of producing mineral deposits–such as oil, gas and coal–and the value of many utility and commercial property by using the income approach to value. Most appraisal districts contract with consultants to appraise mineral and utility property. The chief appraiser of each CAD can provide information concerning the method used to appraise mineral and utility property. Additional information about the approaches may be found in appraisal textbooks.
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 the public, on request and for a reasonable charge, with cost data developed and used by the chief appraiser on property 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 any property owner, upon request, with all applicable market data that demonstrates 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 or the potential earnings capacity of the property, or both, to estimate the property's gross income potential;
- analyze comparable operating expense data to estimate the operating expenses of the property;
- analyze comparable data 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 it to the subject property.
Tax Code Chapter 23, subchapters C, D, E and H, require appraisers to use special methods for land qualifying for agricultural or timber appraisal.
- Access to maps or geographic information system documentation
- Map and list of all market areas identified by the appraisal district
- Copy of the district reappraisal plan used last year and the one for this year
- Policies and procedures documenting the district's appraisal techniques
- Copies of all appraisal district manuals for each relevant category of property
- Documentation on the agricultural use appraisal system and procedures for granting and verifying qualified lands
- Documentation on the timber appraisal system and procedures for granting and verifying qualified lands
- Documentation on the personal property appraisal system and procedures for the discovery and verification of personal property
- Copies of internal ratio studies for all categories of property for the past three years
- appraisal records
- Documentation for the district's information processing system, including contracts and specifications on the appraisal software system and the mapping/geographic information system, and a list of all hardware and other software
- Documentation on the internal control mechanisms used to ensure uniformity and accuracy of appraisals
- Copies of documentation or procedures for gathering, entering, verifying, confirming and maintaining data electronically
- Copies of written procedures for the use of electronic data in the appraisal process
- Procedures and system capabilities and controls of the electronic data systems that ensure compliance with various rules:
- 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)
People to Interview
Chief appraiser and district staff members.
Activities to be Performed
- Obtain a copy of the reappraisal plan; make a list of the activities required by Tax Code Section 25.18(b) 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 these activities.
- Compare the district's maps or geographic information system (GIS) to the International Association Assessing Officers' (IAAO's) 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 mapping or GIS 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 departments are experiencing any major problems with the system; and if any are scheduled for replacement or upgrading 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 they could be.
- Make a list of all of the market areas identified by the district. Review the maps or GIS system in conjunction with the CAD's market areas and note whether market areas have been identified and whether they appear reasonable (rural CADs may not need market areas, while more urban CADs 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 complying with Tax Code Section 23.12 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 CAD provides to staff. State the date of the last revision next to each manual, and describe their usefulness and applicability to the CAD's operations (that is, assess whether they are adapted to fit community needs, rather than being a purchased general appraisal guide). 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 they are not in compliance, state specifically how they fall short. Also, list any additional manuals that the district should provide. Make recommendations for improvements where needed.
- Obtain a copy of internal CAD 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, CAD procedures manuals and appraisal records, and interview staff to determine whether the district is reappraising according to a plan that prioritizes efforts based on the needs reflected in the internal ratio studies. Determine whether the market areas with the lowest appraisal levels are being reappraised as soon as possible after a low ratio is identified in the ratio study, and whether all property 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 where needed.
- Interview staff members regarding their procedures for obtaining sales information; review their sales procedures manuals; and inspect the CAD 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 CAD that are not being used. List sources of construction cost data and income data and other sources not being used.
- Examine and prepare a flowchart of the district's sales screening procedures (procedures to confirm that a sale occurred; verify the accuracy of sales prices, sales dates and other sales information; and 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 district's appraisal method(s) next to each category. If other methods would be more appropriate, indicate them. Next to each category, list whether the district's methods follow the requirements of Tax Code Chapter 23 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 Tax Code Chapter 23, describe the deviation.
- 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, note whether the cause is internal to the district or based on some external factor, and show what actions the district has taken or is planning to take to remedy the situation.
- 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 its 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. Detail whether the appraisal system and the mapping system/geographic information system are integrated, and if they are not integrated, detail how they could be. Examine all documentation and output to determine whether the current information system adequately ensures compliance with applicable Comptroller rules.
- Examine and prepare a diagram of 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 appraisal uniformity and accuracy and to protect data from unauthorized access. Examine existing measures for uniformity, such as ratio studies, to determine if additional controls are needed. Where control weaknesses are noted, discuss and make recommendations for improvement.
- Examine and make a diagram of the district's method for obtaining, entering and maintaining all data on the computer system(s) to determine if the methods used are in compliance with the Uniform Standards of Professional Appraisal Practice (USPAP). Where system or procedural weaknesses are noted, discuss and make recommendations for improvement.
- Using the appropriate year's Property Value Study, collect sample property included in the study and drop the information into an Excel spreadsheet. Using the spreadsheet, determine the top 10 percent and bottom 10 percent ratios. These sample property should be used in reviewing CAD appraisals. For each sample property, pull appraisal cards and review them for completeness. At minimum, the appraisal card must include all information cited in Comptroller Rule 9.3001. Note if appraisal cards are missing information and develop a chart to show findings. NOTE: If the sample property do not have a normal scattering of values or has a very low COD, contact the project manager for an alternative sample. Also, if your sample size exceeds 100 property, contact your project manager.
- Using the sample property identified in step P, and employing the oral or written procedures the CAD uses to appraise all property, appraise the property to determine the resulting value and create a table that compares the current CAD-appraised value to the appraised value determined by the consultant. This will require site visits to the property. The consultant should test only the appraisal procedures in categories that were included and tested in the property value study. Note any deviations and provide an explanation for each.
- Review vendor values for Categories G, J, F2 and L2. The district should have copies of the vendor procedures, valuation manuals, appraisals and other documentation used to support the value placed on the property. Note whether the documentation is complete or incomplete, or if it is inconsistent with the appraisal. Note all discrepancies.
- For each appraisal, the contractor must provide PTAD with detailed documentation supporting each appraisal including, at minimum, the appraisal card and the details of the contractor's appraisal.
- For each property category appraised by the contractor, the contractor will develop a separate chart/table including a legal description of property; an assessment of whether the property card is complete; CAD value; appraisal value; sale date, if available; sale value, if available; and the ratio between the contractor's value and the CAD's value.
Does the district have a board-adopted reappraisal plan as required by Section 6.05(i) of the Property Tax Code (refer to S.B. 1652, 79th Legislature, regular session) that provides for the reappraisal activities required by Section 25.18(b) of the Tax Code for all real and personal property in the district? Is the district performing the activities listed in the plan at least once every three years? These activities include:
- identifying property to be appraised through physical inspection or by other reliable means, including deeds or other legal documentation, aerial photographs, land-based photographs, surveys, maps and property sketches;
- identifying and updating relevant characteristics of each property in the appraisal records;
- defining market areas in the district;
- identifying property characteristics that affect property value in each market area, including:
- the location and market area of property;
- physical attributes of property, such as
- size, age and condition;
- legal and economic attributes; and
- easements, covenants, leases, reservations, contracts, declarations, special assessments, ordinances or legal restrictions;
- developing an appraisal model that reflects the relationship among the property characteristics affecting value in each market area and determines the contribution of individual property characteristics;
- applying the conclusions reflected in the model to the characteristics of the property being appraised; and
- reviewing the appraisal results to determine value.
What is the next year of reappraisal? Is the reappraisal plan connected to the budget and the internal ratio study? Are staffing levels and equipment needs for the reappraisal tied to the budget? What was the last year in which the district reappraised property? (Pull a sample of appraisal cards and compare appraisal roll records to verify that a reappraisal has taken place.)
Mapping and Geographic Information System
Does the appraisal district maintain complete and detailed maps or an effective geographic information system (GIS)? (Obtain examples of maps.) Does the district's mapping system comply with Comptroller rule 9.3002?
Is each map drawn to scale and delineated for lot lines or property lines, with dimensions or areas and identifying numbers, letters or names for all parcels? How are property identified on the maps? How does the district ensure that each property in the district is identified on the map? Are identifying numbers recorded on the maps and appraisal cards?
How often is the mapping system updated to incorporate any new subdivisions or property transfers? Does the district have a GIS? If not, is the district investigating acquiring a GIS? If the district has a GIS, is it fully implemented? If not, how far has the implementation progressed and what is the plan and timeline for completing implementation? Is the GIS integrated with the appraisal system? Does the district use the GIS system in data quality control?
How is the mapping system or GIS used in the appraisal process? Is it used in the identification of reasonable market areas?
Real Property Discovery
What methods does the appraisal district use to discover real property? Does the appraisal district have written procedures for the discovery of real and personal property that list discovery methods such as building permits, deed records, yellow pages searches, visual discovery and sales tax records?
What kind of property discovery system does the district use? Does the system provide for the inspection of all real property each year? If not, how often does it inspect real property? Does the district inspect new property each year? If yes, what system is used and is it adequate? Does the district inspect all real property in a reappraisal year?
Does the district accurately record the individual property characteristics (e.g., square footage, property type, property age, construction type, location) needed to appraise all property accurately? Does the appraisal district maintain complete and effective market data on property sales, construction costs and relevant income information?
Does the district maintain current and complete appraisal manuals for each property category, including:
- a residential appraisal manual;
- a commercial and industrial appraisal manual;
- a personal property appraisal manual;
- a land appraisal manual;
- an agricultural use appraisal manual (the district should have an agricultural appraisal manual showing local procedures used in conjunction with the state's Manual for the Appraisal of Agricultural Land); and
- a timber appraisal manual, if applicable, showing local timber appraisal procedures for use in conjunction with the state's Manual for the Appraisal of Timberland?
Are the district's appraisal manuals and procedures written clearly? Could untrained staff members use them to conduct appraisals without direct instruction from another appraiser?
Who developed each appraisal manual? Was local cost data used in its development? What was the source of any cost data used in the manual? Was the cost data verified for use in the manual? How?
How clear are the user instructions for each appraisal manual? Are the instructions clear enough to allow taxpayers to understand how the manual is used? Are the instructions adequate for use in training new personnel? Does the manual describe each class of property? Does it have a basic cost per square foot or other unit for each class of property? Does it have sections for additional details for each class of property? Is the manual adequate to conform to USPAP standards? Elaborate.
When was each appraisal manual last updated? How clear is the process for updating each manual? Is it described in writing? Does the district update its manuals for reappraisal years? What type of data is used to update each manual (e.g., sales, cost, etc.)?
Does each appraisal manual have a depreciation table (if applicable)? Were sales data from the local market used to develop the depreciation table? Does the manual include instructions on how to use the depreciation table? Does the manual contain instructions on how to apply economic depreciation?
If the appraisal manual is from a manual service, what kind of local modifier has been used? Does the local modifier use sales data from the local market? Was the local modifier developed by the manual service under contract with the appraisal district? Was the local modifier developed for another area and adapted for use in the district? Does the local district verify local modifiers? Does the district comply with USPAP standards in this area?
How frequently does the district perform internal ratio studies? How does the district use the ratio study to gauge the effectiveness of its appraisal efforts in terms of both the level and the uniformity of appraisal, and to determine which property categories and market areas need reappraisal? How are the budget, the reappraisal plan and the internal ratio study linked? Is the district reappraising property categories and market areas identified by the internal ratio study in an efficient and timely manner? (Property categories or market areas should be prioritized so that categories or areas with low ratios can be reappraised as soon as possible. All property should be reappraised within the three-year period required by law.)
How does the district comply with the business personal property rendition requirements in Section 22 of the Tax Code? How does the district use renditions in the appraisal process? Does the district use rendered values as market value, or does it use the rendition information as data in the appraisal process? (For instance, if undepreciated historical cost is rendered, the application of appropriate depreciation is critical in obtaining market value.)
How does the district obtain sales? What sales sources does the district use? Are there other sources? How does the district screen sales for use in its appraisal system? (For instance, sales should be verified to determine whether they correspond to the definition of market value set out in Section 1.04(7) of the Tax Code, and to ensure that the sales price, sales date and other information are correct.) Does the district have appropriate procedures for adjusting sales for date of sale, financing, personal property and other factors to ensure that the adjusted sales price reflects the market value of the real property being appraised on January 1 (see the IAAO Standard on Ratio Studies for a list of sales adjustments)? How does the district use its sales data in conjunction with property characteristics and market areas to develop appropriate appraisal models for use in reappraisal? (For instance, sales should be used in the comparable sales approach; to develop local modifiers in the cost approach; and to develop capitalization rates in the income approach.)
Does the district use the appropriate appraisal method for each property category? (For instance, the district should use comparable sales to appraise residential property unless such sales are not available.)
How does the district appraise property at market value (or the appropriate special use value)? What other local standards are used to appraise property that might arrive at something other than market value? (For example, the district may attempt to appraise property at 96 percent of market value to stay inside the study margin of error while reducing local appraisal review board appeals.)
Does the district use sales comparisons to appraise land? Does it collect and verify land sales to create a land schedule? Is this schedule arranged to allow for adjustments for location, size, utilities, topography, frontage, etc.? If the schedule is not based on sales comparisons, what method is used? Does the district define neighborhoods for land appraisal only? Does the district define different types of lots, such as lake lots versus town lots, etc.? Does the district's land value system comply with USPAP standards?
How does the district use the sales comparison approach in valuing property categories other than land?
How does the appraisal district use the income approach in the appraisal process? Does the district use the direct capitalization method? Does it use the discounted cash flow method? How does the district collect and retain income and expense data for use in the income approach? How does the district determine the capitalization rate it uses? Does income information come from local sources, if possible? How does the district develop appropriate capitalization rates or multipliers from local sales of similar property when developing a value estimate through the income method?
Does the district use replacement or reproduction cost data obtained from local sources or from a cost service? How does the district depreciate property appropriately to develop a sound value indication by the cost approach?
Do all appraisal methods comply with Chapter 23 of the Tax Code?
Invalid PVS Findings
What are the key areas of difference between the PVS and CAD values? What do the chief appraiser and/or board members believe caused the finding? How did the problem occur and was it a one-time occurrence or a recurring issue? What has the district done to address the causes identified from the previous questions?
What significant events or major decisions occurred in the tax year leading to the invalid findings? How did these events contribute to the invalid findings? What external events may have contributed to a value shift? Are there any significant changes in progress or in discussion for remedying this situation?
Have the PVS findings been improving, deteriorating or staying substantially the same over the last few years? What is making the difference? What will it take, internally or externally, to ensure the continuity of valid findings in future years?
What internal formal or informal policies or procedures increase the risk of property in the district being valued at an amount other than market value, as prescribed by law?
How are data gathered and entered into the computer system(s)? Are any data gathered electronically or are all entered manually? Who enters data into the appraisal system?
Are appraisal cards kept on the computer or in paper form? Do they contain all the data required by Comptroller rules? (Obtain samples of single and multi-family residential, commercial real, personal and land property.)
Do the computer records contain information on current property use, highest and best use and indicators of legal uses? Does the district maintain computerized data on land attributes important in the local market? Does the district physically inspect all property at least once every three years? Does the district regularly obtain and enter into its computer system copies of building permits, occupancy permits, MLS information, business set ups, etc.? Does the district maintain only data necessary in valuation or the support of values?
Are electronic appraisal cards well designed and supported by a data coding manual? Are procedures for entering information into electronic systems current and adequate? Does the district have a computerized edit program that includes range and consistency checks? Does the district collect and enter into the appraisal system income data for apartment buildings, retail stores, office buildings and other leased or rented property?
Managerial and Operational Review Supplement for Appraisal Standards Review
Activities below this point in the protocol involve other aspects of appraisal district operations. Under certain circumstances established by the Comptroller, an appraisal district receiving an appraisal standards review may have the scope of the review expanded to include some or all operational and management activities. Comptroller management will determine, before beginning the review or during the review, whether or not to expand its scope on a case-by-case basis. In the event that the Comptroller determines that an expanded scope is necessary, the reviewer will use part or all of the information outlined below to perform the additional activities.
Governance and Management
The quality of the property tax system depends on the CAD's board of directors. Individuals serving on the board should provide 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 survey
- Copy of strategic planning documents prepared over the last five years
- Copies of the board-approved budget for the three prior years; notices of public hearings posted to adopt the budget; and a budget calendar showing hearing dates; resolutions from the taxing units approving the budget
- 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 dates upon which they joined the board
- Copies of board policies
- A list of all chief or interim chief appraisers employed by the district over the last 10 years and reasons 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 appraisal review board [ARB] costs) for the last three years, as shown by retainers and hourly billings
People to Interview
Budget or Finance manager
Financial auditor, as necessary
Activities to be Performed
- Develop an exhibit with the names of board of directors, the governmental entity each represents and the date each began 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 district's budget preparation and strategic planning processes 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.
- Prepare a table showing the budget for the last three years; examine the district's budget documents for compliance with Texas Tax Code Section 6.06 requirements and, where deviations are noted, discuss them and suggest possible remedies.
- Prepare a table comparing budget and actual expenditures for the last three years, showing the percentage change from prior years for each category of the budget as well as budget-to-actual expenditure deviations. Note areas of significant change 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.
- Examine the district's most recent financial audits and determine how it has addressed any 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 their 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 written contracts in place, the key terms and conditions of each, and total budget to total actual expenditures for the last three years. Through interviews, determine how the district defends values and legal issues and how it offers legal advice.
Board of Directors
Who are the current board members? Who do they represent? How does the district's board member selection and election process work? If board members represent "all," explain their selection and election process. Are any board members elected officials? If so, what elected positions do they hold (city councilman, tax assessor-collector, board of trustees, etc.)? When did each board member begin serving on the board? Has there been significant recent or historical board turnover? If so, what were its causes?
Does the board have written policies for itself or the district? Does it have written procedures? (Obtain copies.) What evidence shows that board meetings are open to the public and that the public is encouraged to attend? Does the public attend meetings? What are the board procedures for public comment? Do any board members own businesses that provide goods or services to the district? Does the board have current conflict-of-interest statements on file in district offices? Are any board members related to district staff? (Obtain copies of representative board minutes for events such as contract signings; key personnel changes, such as hiring or firing the chief appraiser; and any other major events in the tax year.)
What board policies address the district entering into contracts with a member of the board or with a business in which a member has substantial interest (Property Tax Code, Section 6.036)?
What board policy addresses the chief appraiser hiring an individual related to himself or herself or a member of the board (Property Tax Code, Section 6.05)? Has the district hired any individual who is related to the chief appraiser or a board member (Property Tax Code, Section 6.05)?
What CAD policies and procedures encourage taxpayers to discuss concerns and complaints with the district before lodging a formal complaint? Does the policy or procedure stipulate how and when attorneys, contractors or other appraisal experts may be used for formal appeals? How does the district track the status of formal appeals to ensure that they are disposed of appropriately and the records are updated properly? Is this process formally documented in the district's policies and procedures?
Does the board establish annual goals and undertake a formal planning process? If not, why not? How often do the board and chief appraiser conduct goal-setting and planning sessions? How is the board involved in adopting annual goals to improve the district's operations?
How are district plans and goals publicized? How frequently does the district measure progress toward goal achievement? Do the planning documents establish priorities for appraisal and reappraisal goals? How does the budget document confirm that essential resources are dedicated for goal achievement? Has the district allocated adequate resources to develop and implement a realistic long-range master plan for technology and facilities? If not, why not?
Are taxing units involved in the development of a multi-year strategic plan for the district? When there are legitimate needs for improvement, how does the district communicate those needs to the local taxing units?
How are demographic and economic growth projections collected, and by who? When was the last time that the district conducted a future needs analysis and an evaluation of future capacity? Has the district developed a technology plan that realistically meets its projected demographic needs and appraisal goals within budget constraints and policy guidelines?
Budget Preparation and Management
Is the budget in compliance with Tax Code Section 6.06 requirements as to content? Did the board hold a public meeting to discuss the proposed budget, and was the meeting advertised properly? (Obtain documentation.) Does the district use budget calendars in developing its annual budget? How is the budget developed? Who participates? Does the CAD have procedures for developing the budget? Is the budget sufficient to meet appraisal needs? Was the budget amended during the year? How did the amendment process work? Did the district overspend or underspend in terms of the budget? Were funds left over in the budget at the end of the year? If so, were the funds returned to the taxing units, or were the taxing units' future payments reduced? If the funds were not returned, what did the district do with them? Was the district's budget vetoed by any of the taxing entities? If so, who did so and for what reasons? Was the budget approved by September 15? (Obtain documentation.) Were copies of the proposed budget delivered to the taxing units before June 15? If the district also performs collections, are collection and appraisal budgets separate?
Does the district arrange for an annual financial audit of its operations? Does it have a contract with its financial auditor? What does the contract outline? Is the auditor performing a complete financial audit or something less? Is a management letter included with any of the financial audits? If so, what were the stated problems and how did the district deal with them? Does the problem show up in subsequent audits? What procedures were adopted to prevent the problem from recurring? If the problem involved loss of funds, was the district compensated?
Does the district have procedures for monitoring contracts? Are these procedures written? (Obtain a copy.) Who monitors which contracts? What kind of contract monitoring does the district perform?
Does the board evaluate the chief appraiser? How–orally, in writing, or both? (Obtain a copy of the evaluation.) Does the chief appraiser have a job description? (Obtain a copy.) Ask why the process of evaluating the chief appraiser is the way it is, or how it came to be that way. Does the board have a written process for hiring and evaluating chief appraisers? Explain. When was the current chief appraiser appointed? If the appointment was recent, has there been chief appraiser turnover in the last five years? What caused it? Explain.
Is the chief appraiser registered with the Board of Tax Professional Examiners (BTPE)? Does the chief appraiser meet all the requirements of the Tax Code? Is the chief appraiser related by blood or marriage to any appraisal district staff or any board members? Is the chief appraiser related to any of the CAD's contractors?
If turnover of chief appraisers has occurred, what events caused it? What was the impact on district operations? What institutional knowledge was lost during turnover? How did staff members compensate for the loss of institutional knowledge?
Does the district have separate legal counsel for the appraisal review board? If so, please answer these questions for both the ARB and the CAD counsel, as applicable.
What is the district's local policy for the use of outside counsel concerning:
- board approval of written contracts in advance of services rendered;
- the reporting relationship of the attorney with the administration and the board; and
- the designation of individuals within the administration and board with the express authority to contact attorney(s) and incur costs?
How does the district use legal services to keep abreast of changes in the law, review policy, provide representation in legal actions and reduce the risk of lawsuits? Does the district employ an attorney (either in house, on a retainer or in a Mathisative arrangement with another district) to advise the board, review proposed policies and reduce the risk of lawsuits? Is legal counsel available to the board in a timely manner?
How many times did legal counsel appear before the CAD board and the ARB, or provide them with written opinions, in each of the last three years? How many lawsuits were active in each of the last three years? How many were settled in each of those years, and how many went to trial? How much property value was in dispute in each of those years?
What percentage of CAD legal counsel's time could be attributed to providing litigation defense and legal advice on administrative and appraisal issues? What dollar amount was 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?
Resources and Operations
The CAD chief appraiser is responsible for hiring, firing and training personnel; ensuring compliance with a wide range of legal requirements; and maintaining policies and procedures for the effective operation of the district.
Conduct a comprehensive examination and evaluation of the district's staffing, personnel qualifications and system of positions, and assess the district's human resources available to perform district functions.
- Comparative data from current Appraisal District Operations Report
- Copy of operational and personnel policies and procedures
- Copy of district organization chart
- A diagram of all CAD facilities and information pertaining to total square footage of facilities, as well as the age and condition of each
- List of all appraisal district staff, job titles, salaries, length of service in the district and certifications held
- Copies of employee handbook and appraisal district personnel policies and procedures manual
- Copies of all conflict-of-interest statements signed by staff
- 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 information technology systems
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 for day-to-day operations such as purchasing, bank reconciliations, payroll and 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 operational function; who serves as backup for each function; and the level of cross-training among staff needed to ensure that all functions can be carried out in the absence of key employees. Where staffing is inadequate, or where internal control weaknesses are found, 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 (FTE) and discuss the adequacy of the facilities and any impediments to work or taxpayer access that result from their design or size.
- Develop an exhibit that lists staff names (names will be omitted in final report), positions (titles), certifications, lengths of service with 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 current staffing information to that reported to the Comptroller in 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 among contractors, staff and supervisors. 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 as needed.
- Examine supervisor-to-staff ratios, staff-to-parcel ratios and the appraiser-to-locally appraised parcel counts. Compare these to statewide averages and to the peer districts, and note significant variances. Through interviews, determine the reason for variances and make recommendations as needed.
- 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's Chapter 2.10 provisions. Prepare a list of all contracts; the name of the contractor; the dollar amount and expiration date of the contract; the type of 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 them 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.
Does the district maintain written operations procedures? If so, which ones? (Obtain copies.) How does the district purchase goods and services? How does management ensure that policies are translated into operating procedures and followed by staff? Do administrators review and update administrative regulations and procedures annually, or on some other cycle? Who is responsible for ensuring that each department or operating unit develops procedures? How are documented procedures used to train new staff or cross-train existing staff on the processes? What formal staff training does the district provide on its administrative procedures?
Is there a clearly defined process for revising procedures that allows for staff input? What evidence shows that the system is working as it was intended? What internal or external audit findings have identified internal control weaknesses or violations of laws or policies? How have procedures been modified to ensure that such instances do not recur?
How are revised policies incorporated into operating procedures? How frequently are employee handbooks revised to reflect changes in policy or procedures? How are users informed of changes in policy and procedures (such as changes in purchasing procedures that could affect department staff as well as vendors)?
How many square feet of space does the appraisal district office have? Is the office location convenient for local taxpayers? Is it adequate for conducting the business of the appraisal district? Is it in good physical condition? When was the office built? Does the district own or rent it? How long has the appraisal district been housed at its current location?
Are the facilities used efficiently? How much actual program space does the district have? Are board and other meeting rooms easily accessible by the public?
If there are under- or overused- facilities, what plans does the CAD have to address these concerns? What measures have been effective or ineffective in maximizing utilization?
How are administrative, warehouse and other support services facility spaces allocated? Which administrative facilities are fully used? Overcrowded? Underused? What efforts are under way to improve administrative space usage?
How does the district's current organization contribute to the effective and efficient valuation of property? Do the appraisal district's organization chart and the actual day-to-day workflow ensure that each employee reports to only one manager or supervisor? Is the span of control of supervisory staff appropriate for adequate supervision? How does the current organizational structure ensure appropriate communication? How does it ensure appropriate coverage of all critical tasks, even when key employees are absent or abruptly leave the district?
What instances could be observed in the organization where bottlenecks, duplication of effort or weak internal controls might occur?
Employee Handbooks and Human Resources Policies and Procedures
How does the employee handbook encourage employee compliance with federal and state laws? How is it used to recruit and retain employees? How does it address such factors as the Americans with Disabilities Act (ADA); staff discipline; Family and Medical Leave Act (FMLA); Equal Employment Opportunity (EEO) requirements; and absenteeism?
Do CAD human resources (HR) policies designate or identify positions responsible for ADA, FMLA and EEO coordination?
What policies address hiring; job postings; promotions; staff complaints and grievances; probation, orientation or induction period; performance appraisals; equal employment opportunity statement of philosophy; the Drug Free Workplace Act; termination; benefits; and compensation and position classification?
Does the CAD have a policy that governs sexual harassment and other inappropriate workplace behaviors? Is there a defined and specific complaint procedure for staff to follow in reporting sexual harassment and other inappropriate workplace behavior?
How often do the board members review personnel-related policies? How are district policies communicated and distributed to staff? Do employees acknowledge, via their signatures, receipt of district policies during the course of employment?
Does the CAD's HR coordinator provide any policy training for managers and employees? When did the district last update and/or revise its HR policies? Are the policies viewable online?
How many employees does the district have? What are their titles, salaries and benefits? Is the district as a whole understaffed, overstaffed or on target, according to IAAO standards?
Does it appear that the district has enough of the right kind of positions to fulfill its mission? For example, are there enough appraisers to get the job done? Do appraisers or contractors have the right skills to appraise each type of property? Is there an adequate support staff to allow appraisers to appraise rather than spending inordinate amounts of time on clerical functions? What is the ratio of appraisers to support staff? Does this mix hold down staffing costs and ensure efficient and effective appraisals? Does the district ensure that all employees, regardless of their position, are used fully and productively?
How have salaries changed over the past five years? How do salaries compare with those for similar positions in similarly sized districts, or for similar positions in the district area? Does the district periodically adjust its compensation structure using verifiable salary survey information, benchmarking and analysis of comparable salary data? When did the district last perform a comprehensive salary survey? Did the board fund any pay adjustments recommended in the survey? Has the district made any internal equity and/or market adjustments to salaries within the past two years?
Are all appraisers registered with BTPE? If not, why not? (Obtain copies of all certifications.)
How does the district ensure that all of its employees receive required training? (Obtain copies of class rosters, training certificates, etc.) How much funding is allocated in the budget for staff training and travel to attend such training? What classes of employees do not receive regular training that could improve their job performance?
Contracting and Procurement
What contracts does the district have? (Obtain copies of current contracts.) How do these contracts contribute to the effective and efficient district operation and the accurate valuation of property? What is the cost benefit of district contracting? What contracts could be eliminated if qualified employees were hired for the functions? What staffing deficiencies could the district remediate by using contractors?
Does the board approve all contracts? Who signs contracts on the district's behalf? Does the district contract for appraisal services? How were the contracts developed? Were they competitively bid? How did the bid process work? How many bids were received? Are contract deliverables tied to specific dates? For extended, multi-deliverable contracts, does the district receive a progress or status report on the contractors' performance? Are there milestones in the contract that allow the district to review the contractors' performance? Does the district provide feedback to contractors on service contracts?
Staff Job Descriptions, Expectations and Evaluations
Does the district have job descriptions for each position? (Obtain copies.) When were the job descriptions last updated? Are there instances in which the job description and the work actually being performed by staff are not linked?
Does the district provide expectations to each employee and evaluate their performance in writing at least once each year? If not performed annually, how often are evaluations conducted? (Obtain copies of policies, procedures, employee evaluations for last three years or last three evaluations, discipline documentation, etc.)
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 require hundreds of staff hours; and more accurately analyze trend data to ensure accurate valuations of similar property. 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 a series of local area networks (LANs). Maintaining a strong infrastructure and integrating the district's various systems can be critical to increased staff productivity, the reduction or elimination of costly data errors and better customer service for users, community members and taxing units. Technology also is a critical part of mapping or geographic information systems.
- 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
- 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 board members
IT and mapping staff
Activities to be Performed
- Examine the disaster recovery plan and any other documents that show how the district has prepared for disaster. List the major components of the plan and how it 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 describe the district's Web site, compiling a list of information it provides. If the district does not have a Web site, outline what the district needs to do to set one up.
Information Technology Hardware;
What type of computer hardware does the appraisal district have? What type of software does it have? Does the software have a module for the appraisal of real property? Does it have a module for personal property appraisal? Does the system store more than one year of appraisal history online? Does the district have a workstation for each staff member? Does the district's system use a relational database for data storage? How often does the district evaluate its technology and what type of technology refresh schedule does it have? Does the district's current information technology meet its appraisal and mapping needs?
Disaster recovery planning
How is disaster recovery planned? Evaluated? Tested? Is information regularly stored offsite, in light of the recent increase in disasters involving floods, tornadoes and fires? Has the district developed appropriate physical safeguards and backup provisions? What offsite storage is used? Has the district developed a disaster recovery plan? How does it maintain its backup schedule? Should other areas be backed up? Have the recovery procedures been tested?
How does the current disaster recovery plan address:
- immediate response;
- incident control/evaluation;
- environmental restoration;
- functional restoration; and
- resumption of critical business functions?
How does the immediate response section of the plan address evacuation, missing/damage reports and calls for official help? How does the incident control/evaluation section of the plan address the establishment of a command center, security of physical plant and data and damage assessment? How will staff, vendors and customers be notified of the disaster?
What pre-planning measures have been taken to restore critical business functions? Where will the administration establish its new location if the administration building is desMathised or unusable? Where will supplies and office equipment be obtained? How does the district intend to restore lost transactions or recreate critical paper documents such as appraisal records? How will the remaining data be validated?
Does the district maintain data security and integrity, including an audit trail of changes in records that affect assessments? Do the district's systems adequately protect privacy and security? What security software does the district use? Does it have a firewall and virus protection software? Are the server and each personal computer protected from unauthorized use?
Does the district have a Web site? What is its address? What information does it offer? Does it provide the appraisal roll? Diagrams of property? Maps? Is the site user-friendly and easy to navigate? Is its information accurate? How often is the site updated and who updates it?
All Texas appraisal districts 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 the appraisal process is the CAD's prime mission, 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 property will receive these exemptions.
The chief appraiser is responsible for preparing the appraisal roll within a statutory time period.
- 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 the certification of tax rolls to each taxing unit over the last three years
- Documentation showing compliance with the deadline for delivery of applications for special appraisals 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
Activities to Perform
- Prepare a list of all state-mandated forms and applications, and after examining them, note if all of them comply with the Comptroller's rules found at 34 Texas Administrative Code (TAC), Sections 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 they contain all of the information required to be certified to the Comptroller annually, as set forth in Comptroller's Rule, 34 TAC, Section 9.3059, as well as with Section 26.01 of the Tax Code. Through interviews, determine how the records are maintained and when they 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 the district uses 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 the legally required certification of the appraisal roll to each taxing unit, and note the certification dates for each of the taxing units in each of the last three years. Through interviews with taxing units, confirm that CAD 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 the annual application of exemptions/special appraisals for the last two years, and 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 property with exemptions and the corresponding documentation. Prepare a written assessment– 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, Tax Code. Where system or procedural weaknesses are noted, discuss them and make recommendations for improvement.
How does the district ensure that its forms are current and in compliance with state laws and rules? Who is responsible for monitoring changes to laws and rules and making necessary changes to the district's forms?
Does the district use the Comptroller's application form for taxpayers applying for special use valuation (agricultural land, recreation/scenic land) (TAC Rule 9.402)? If not using the Comptroller's form, does the district's application form substantially comply with the model form (TAC Rule 9.402; Property Tax Code, Section 11.43)?
Does the district use the Comptroller's model form for taxpayers applying for homestead exemptions? If not, is the district's form in substantial compliance with the model form (TAC Rule 9.415)?
How does the district ensure substantial compliance with Comptroller rules and state laws when creating district forms? Who is involved in the preparation and approval of such forms?
State Reporting Requirements
On what date was an electronic submission of the roll submitted to the Comptroller? (It is required by October 1st of each year or 30 days after the chief appraiser submits the roll to the county assessor-collector.) When was a supplemental roll delivered to the Comptroller? (It is due within 30 days after the date the chief appraiser certifies a supplemental roll to the affected taxing units.)
Have any impediments prevented the district from submitting the rolls to the Comptroller on electronic media? If such a submission failed, what has the district done to improve its submission capabilities for the next required submission? If the district contracts with a vendor for submission services, who is the vendor and what service requirements are outlined by the contract?
Is the roll readable by the Comptroller's office? If not, why not? What efforts did Comptroller staff take to help the district meet the requirements? Does the district certify all changes to the previous years' appraisal rolls? If not, why not? Does the district have a complete and updated appraisal roll for each of the last five years? If not, why not? Is the appraisal roll in paper form or on a computer system?
How has the district ensured compliance with the Texas Local Government Records Act (Title 6, Subtitle C, Local Government Code), which requires that each local government establish a records management program by ordinance, order or resolution, as appropriate, no later than January 1, 1991? Has a copy of the ordinance, order or resolution been filed with the director and librarian of the Texas State Library, the executive and administrative officer of the Texas Library and Archives Commission? If not, why not? Who is the designated records management officer, and does the name in the policy correspond to the person performing the task?
Who maintains and updates the retention schedules? When was the last time that the retention schedule was updated? If there are areas of noncompliance with state-mandated schedules, what is being done to correct the problem? Who is responsible for correcting the problem? What obstacles exist to compliance?
Where are copies of the retention schedules kept? How are staff members kept abreast of the current retention schedules for items they are responsible for retaining? In what instances has a document not been retained properly? How and when was this situation rectified? Who is responsible for document destruction? Are there documents that have not been desMathised on schedule? If so, why not? What has been done to rectify this situation in the future?
Certification of Appraisal Rolls
Does the chief appraiser prepare and certify the appraisal roll to each taxing unit assessor by July 25th? If not, why not? Does the chief appraiser prepare and certify for each taxing unit a list of property under protest and therefore not on the certified tax roll? Does the chief appraiser prepare and certify to each school district an estimate of taxable value of school district property by June 7th? By May 15th or as soon thereafter as practicable, does the chief appraiser submit the completed appraisal records to the appraisal review board for review (Section 25.22, Property Tax Code)? If not, why not?
By May 15th or as soon thereafter as practicable, does the chief appraiser deliver a written notice of appraised value if (Section 25.19, Property Tax Code):
- the appraised value is greater than it was in the preceding year;
- the appraised value is greater than the value rendered by the owner; and
- the property was not on the appraisal roll the preceding year?
What difficulties does the district encounter in the timely certification of appraisal rolls each year? What major or minor problems have occurred over the years that have put the timely certification in jeopardy? What steps has the district taken to make the certification process more efficient? What quality assurance checks are in place to ensure that the certified rolls are as accurate as possible?
Are procedures for the certification of tax rolls well-written and easy to follow, should key personnel be absent at the time of certification? Are enough staff members cross-trained in the process to ensure that it can be carried out in a timely manner each year?
What evidence exists to show that, before February 1st, the chief appraiser has delivered an appropriate exemption application form to each person who was allowed an exemption in the preceding year (Section 11.44, Property Tax Code)? What mechanisms are in place to ensure that this action takes place in a timely manner each and every year?
For application for homestead exemption, does the district (TAC Rule 9.415):
- provide a list of taxing units with the homestead exemptions each offers; or
- provide the appraisal district's name and phone number on the form, with instructions to call the district to determine what homestead exemptions are offered?
Upon the death of a homestead recipient, does the district require the surviving spouse to file a new homestead exemption form (TAC Rule 9.415)? Does the district require an organization applying for charitable exemption to submit a determination letter along with the application for property tax exemption (TAC Rule 9.417)? Does the district require the application for charitable exemption to be submitted by May 1st (TAC Rule 9.417)? Does the district use the Comptroller's model form for application for motor vehicles leased for personal use (TAC Rule 9.419)? If not, is the district's form in substantial compliance with the model form?