Findings of the Appraisal Standards Review
This chapter of the report addresses findings, commendations and recommendations from the appraisal standards review of the Tom Green CAD in five sections:
2.1 Governance and Management 2.2 Generally Accepted Appraisal Practices 2.3 Resources and Management 2.4 Information Processing and Data Collection 2.5 Assessment Administration
The quality of the property tax system depends largely on the appraisal district's board of directors (board). The board provides knowledge, judgment and expertise in establishing policies and procedures for the CAD's organization and operation.
The Tom Green CAD's board of directors consists of five members (Exhibit 6).
Tom Green CAD
Board of Directors Members
Board Member Entity Member Represents Start Date Occupation Elected Official
(Yes or No)
A.H. "Chico" Dennis, III, Chairman At-Large September 1985 Rancher Yes John Phillips At-Large December 1988 President, Regal Oil, Inc. No Louis Gomez At-Large January 2000 Self-employed Accountant No Dick Burnett At-Large January 1990 Retired Congressman No Walter Pfluger At-Large January 2000 Attorney No Source: Tom Green CAD, December 2005.
Board members are selected at large. According to the chief appraiser, the board members do not consider themselves to represent a particular taxing entity. The chief appraiser notifies the taxing entities of the nomination process and sends out a copy of Section 6.03 of the Tax Code that outlines the steps in the selection process as well as board member qualifications. Each entity submits nominees to the chief appraiser. The chief appraiser prepares a ballot for each entity that is eligible to vote. Historically, each entity divides its weighted vote equally among the candidates and the five candidates receiving the most votes are elected to the board. The board chairman, A.H. Dennis, III, is also an elected official to the Lipan Kickapoo Water Conservation district.
The board has the following primary responsibilities:
- establish the appraisal district's appraisal office;
- adopt the appraisal district's annual operating budget;
- approve appraisal contracts;
- hire a chief appraiser;
- hire a taxpayer liaison officer (in counties with a population of more than 125,000);
- appoint appraisal review board members; and
- set general policy on the appraisal district's operation.
The Comptroller's office asked the board to complete a written survey about its activities. Four board members responded. The survey is broken down into board policies and procedures; chief appraiser and staff; property appraisals; appraisal review boards; and budgeting and financial management. The board members who responded gave Tom Green CAD high marks and generally gave positive (strongly agreed or agreed) responses to the survey's five sections. Two members, however, disagreed that board members attend annual board training. One member disagreed that personnel policies are distributed to staff and made available to applicants and the public upon request. This board member also disagreed that board policies are accessible to the public and that audit contracts are rotated periodically.
Tom Green CAD's appraisal contract with Thomas Y. Pickett & Co., Inc. complies with IAAO's Standard on Contracting for Assessment Services. According to the chief appraiser, Tom Green CAD's attorney reviews all contracts before board execution and the chief appraiser monitors the contracts during the contract period.
Exhibit 7 presents a summary of professional services contracts.
Tom Green CAD
Professional Service Contracts
Contract In Writing (Yes or No) Key Terms and Conditions 2003 2004 2005 Budget Actual Budget Actual Budget Actual Armstrong, Backus & Co., LLP Yes Audit Services for Collections & Expenditures $7,000 $7,000 $7,000 $7,000 $7,500 Not audited Thomas Y. Pickett & Co. Yes Mineral, Utilities, & Industrial Appraisal Services 65,500 65,500 65,500 65,500 65,500 Not audited Texas State Bank Yes Depository Services 0 0 0 0 0 0 Linebarger, Goggan, Blair & Sampson LLP Yes Delinquent Tax Collections & Attorney Representation 0- 0 0 0 0 0 Source: Tom Green CAD, December 2005.
Tom Green CAD's budget is not prepared in accordance with the Tax Code Section 6.06.
According to the chief appraiser, Tom Green CAD does not publish the budget notice in a newspaper of general circulation in the county. The chief appraiser said the cost to publish the budget is a factor, but said that funds were included in the 2006 budget for publication of the 2007 budget notice. Discussion and adoption of the budget is shown as an agenda item on the board's regular meeting's agenda.
Copies of the budgets for 2004, 2005 and 2006 were reviewed. The budgets failed to contain a listing of each proposed position showing salary and benefits. Capital expenditures in each budget were identified as a personal computer and printer.
Section 6.062 of the Tax Code requires that the board hold a public hearing on the proposed budget and publish the hearing notice in a newspaper of general circulation within the county. The notice must include the amount of the proposed budget, amount the proposed budget exceeds the current budget, and the number of employees compensated under both the proposed and current budgets. Section 6.06 also requires the chief appraiser to prepare and deliver a proposed budget to the board of directors and each taxing entity before June 15.
The chief appraiser said that copies of the preliminary budget are submitted to taxing entities before June 15 of each year, but preliminary budget allocations are furnished only if requested. The adopted budget allocations are sent to each taxing entity in December.
Section 6.06 of the Tax Code requires an appraisal district to list in its budget each proposed position with associated salary and benefits; each proposed capital expenditure; and an estimate of the amount of the budget allocated to each taxing unit in its budget. The CAD's board of directors shall approve the budget before September 15.
The preliminary proposed budget is presented to the board of directors at its June meeting. The final proposed budget is presented for adoption in a regular meeting of the board of directors in September. Discussion on the budget is held at the regular board meeting rather than a separate budget hearing. The 2004 budget was approved by the board at its regular meeting on September 16, 2003. The 2005 budget was approved on September 23, 2004 and the 2006 budget was approved by the board at its September 20, 2005 meeting.
The chief appraiser said the 2004, 2005 or 2006 budgets have not been amended since their adoption and none of the taxing entities submitted resolutions disapproving the budgets.
Exhibit 8 presents Tom Green CAD's 2004-06 adopted budgets.
The budgets summarized in Exhibit 8 do not give sufficient details for a member of a taxing unit or a member of the public to understand how CAD funds are spent. Specifically, one cannot determine who is receiving a salary or what benefits are being paid to each person receiving a salary. With more than two-thirds of the budget going toward wages and benefits, both taxing units and the public need the details required by state law to be assured the number of staff in the CAD is sufficient to perform the work and that the staff is correctly compensated. Additionally, by not receiving their proposed budget allocations by June 15, taxing entities are unable to determine the amounts they need to budget to meet their funding obligation to the CAD. Failure to publish the budget hinders public participation in the budget process.
Tom Green CAD Adopted Budgets
2004 through 2006
2004 Budget Percent 2005 Budget Percent 2006 Budget Percent Percent Increase (Decrease) 2004-2006 Administrative Board $2,500 .17% $2,000 .13% $6,200 .37% 148% Advertising & Public Notices 2,200 .15% 3,300 .21% 3,450 .21% 57% Automotive 48,900 3.33% 50,400 3.24% 56,675 3.40% 16% Capital-Furniture & Fixtures 3,000 .20% 2,500 .16% 4,500 .27% 50% Computer Expense 13,150 .89% 15,750 1.01% 15,750 .94% 20% Dues 1,350 .09% 1,310 .08% 1,580 .09% 17% Insurance-General & Building 13,315 .91% 15,755 1.01% 15,065 .90% 13% Insurance-Health 199,098 13.55% 221,650 14.27% 218,825 13.11% 9.9% Insurance-Unemployment & W/C 11,185 0.76% 13,730 .88% 12,950 .78% 15.8% Office Supplies & Forms 29,850 2.03% 28,850 1.86% 39,750 2.38% 33.2% Payroll 825,315 56.17% 863,330 55.57% 933,080 55.91% 13.1% Postage 41,725 2.84% 47,925 3.08% 54,670 3.28% 31% Professional Services 95,500 6.50% 95,450 6.14% 95,450 5.72% (0.1%) Rent & Lease & Bldg Mortg 72,435 4.93% 81,610 5.25% 88,445 5.30% 22.1% Repair & Maintenance 4,065 .28% 2,000 .13% 2,000 .12% (50.8%) Retirement 82,535 5.62% 86,335 5.56% 93,310 5.59% 13.1% Telephone & Web site 18,300 1.25% 17,450 1.12% 20,500 1.23% 12% Tuition & Travel $4,950 .34% $4,125 .27% $6,600 .40% 33.3% Tax Liaison Officer $25 .00% $25 .00% $25 .00% .00% Total $1,469,398 100.00% $1,553,495 100.00% $1,668,825 100.00% 13.6% Grand Total $1,469,398 $1,553,495 $1,668,825 13.6% Budget amount billable to Taxing Entities $1,469,398 $1,553,495 $1,668,825 13.6% Source: Tom Green CAD, 2004, 2005 and 2006 Budgets.
Jefferson CAD's budget document, for example, complies with Tax Code 6.06. The budget lists all capital expenditures, such as software, computer equipment, furniture and proposed purchases and all employees' salaries and benefits for each position. Jefferson CAD's budget provides enough details to allow members of the taxing units and the public to understand how the money in its budget is spent.
Develop, publish and adopt a budget in accordance with the Tax Code.
Tom Green CAD collects for taxing entities and the budget does not differentiate between appraisal and tax collection functions.
Tom Green CAD, by interlocal agreements, collects taxes for all taxing entities in the county. A portion of each taxing entity's budget allocation is based on its tax levy.
Tom Green CAD reported a 2005 collection budget of $543,723. The chief appraiser said that this figure was arbitrarily estimated as 35 percent of the total reported $1,553,495 budget. At the end of fiscal year 2003, the appraisal district collected and distributed $73,072,326 in current and delinquent taxes. In fiscal year 2004, the total amount of taxes collected and distributed was $75,942,472.
For example, in Exhibit 3 Tom Green CAD's parcel to staff member ratio appears low, compared to peer group averages: Tom Green CAD's parcel to staff ratio is 1 to 2,640 and the peer group average ratio is 1 to 2,948. The CAD appears to be performing below its peer group average. But if collections staff are removed from the calculation, according to the Tom Green CAD employee roster for November 2004 showing estimated collection activity for each employee, the CAD's ratio increases to 1 to 3,871, exceeding both the peer group average and IAAO Standards.
The Comptroller's Appraisal District Director's Manual, issued February 2006, states:
If an appraisal district performs collection or assessment services, a separate budget is required for the main appraisal district budget. Only taxing units using these services pay for them, so the chief appraiser shall budget separately for these services. This separation requires allocating costs only to the taxing units receiving the services.
This statement was upheld by the Texas Attorney General in a 2003 opinion (GA 0030). The Attorney General stated that appraisal district costs for assessing and collecting taxes for taxing units may not be included in the budget for appraisal district operations.
The Appraisal District Operations Survey requests separate information on appraisal and collection budgets. Taxing entities and the public have no way to distinguish or understand how each area of operation is funded and if funding is adequate for each function. By separating the collections and appraisal budgets, CAD officials and taxing units will be better able to make funding decisions. In addition, analysis of the CAD's cost to appraise each parcel of property could be distorted.
Cooke CAD, for example, breaks out appraisal and collection budgets. This allows taxing units the ability of determine how much the CAD spends on each function and how staff members are compensated.
Develop a budget that distinguishes between appraisal and collection functions.
The board does not have written policies or procedures for evaluating its chief appraiser.
Tom Green CAD has had only two chief appraisers since its formation in 1980. The current chief appraiser was appointed by the board on March 25, 1999 after the death of the first chief appraiser. The current chief appraiser has been an employee of the appraisal district since its formation.
In the document Bylaws, Rules of Order and Procedure of the Tom Green County Appraisal District Board of Directors, referred to as the board manual, the board lists as one its functions the selection of a chief appraiser, but it does not address how the individual will be selected or evaluated after being hired. A separate one-page document titled Expectations of Chief Appraiser lists responsibilities of the chief appraiser, but these job functions are not included in any written performance evaluation.
The chief appraiser said that he receives an informal evaluation each year. The board chairman said that the board evaluates the chief appraiser informally each year in executive session typically at the beginning of the year. No documentation on the chief appraiser's performance was provided to the reviewer, however, the board chairman said he and the other board members had confidence in the current chief appraiser and were satisfied with his job performance.
Chief appraisers are responsible for ensuring that competent staff is hired, procedures are documented, appraisals are performed, staff evaluations and for all other functions performed by an appraisal district. Having a qualified chief appraiser is important to effective appraisal district operations. An evaluation process that objectively assesses performance will allow the board to clarify their expectations and ensure strong and consistent leadership for the appraisal district.
Through its policies and procedures, the board determines the appraisal district's goals and operates as the decision-making body on appraisal district operations. It evaluates the effectiveness of the chief appraiser and overall appraisal process. Without an objective system in place to ensure that the board and the chief appraiser are in agreement as to what is expected of the chief appraiser, there is no way to ensure the goals of the board are consistent with the goals of the chief appraiser and that both sets of goals are in the best interest of the CAD.
In Nueces CAD, for example, the chief appraiser receives an annual performance evaluation on the anniversary date of his or her hire. The evaluation instrument for the chief appraiser is distinct from the evaluation tool used for other district staff. The instrument allows for input from all board members, and affords the chief appraiser an opportunity to address his/her own goals and objectives during the evaluation period. In addition, the evaluation sets up measurable goals and objectives for the next twelve months. By evaluating the chief appraiser in writing, the CAD ensures the chief appraiser and the board have the same goals and it serves and a record of success.
Develop an objective set of evaluation measures for the chief appraiser position and annually evaluate the chief appraiser.
There are three general appraisal methods or approaches-cost, income and market-that a chief appraiser must consider in determining the market value of property. The chief appraiser must use the method most appropriate in appraising a particular property.
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.
Tom Green CAD has a comprehensive appraisal policies and procedures manual for appraising real, commercial, and personal property. The manual also contains a section on land appraisal.
Developed in 2005, the Tom Green County Appraisal District Appraisal Manual thoroughly explains how the CAD appraises residential and commercial property, business personal property and land. The manual also contains the CAD's USPAP Mass Appraisal Report.
Through fieldwork the appraisers gather specific information about properties such as condition of the property, age of the property, construction details, and physical dimensions. In addition, the appraisers gather information about the land on which real property is located. They gather specific information about the dimensions of the land, its shape and location. The appraisers gather the same information for vacant land, whether a vacant lot or a rural tract.
Most appraisals are accomplished by entering the accumulated property characteristics into the computerized valuation model. The model, when directed, produces a market value for each property based on the property's characteristics that the appraiser then reviews for reasonableness and accuracy.
As part of their computerized model, Tom Green CAD uses cost-based schedules to appraise residential and commercial improvements. According to the CAD's senior appraiser, residential cost schedules were updated in 2005. The schedules are included in the appraisal manual. Commercial cost schedule updates are dictated by the market, according to the CAD's commercial appraiser. Some of the sources of commercial market and income data used by the CAD are area fee appraisers, publications such as Texas Hotel Performance Factbook, the internet and exchanging data with other west Texas area appraisal districts. The Marshall & Swift Commercial Valuation Guide is a resource used for commercial appraisals when market data is unavailable.
The CAD's procedures for analyzing sales and market data are also contained in the Tom Green County Appraisal District Appraisal Manual. Confirmed sales within the same category of property are appraised using existing cost tables. The resulting appraisals are compared to the sales and factors (modifiers) are calculated to either increase or decrease the appraisals to bring them more in line with the sales. When all of the sales have been reviewed and all of the factors calculated, a mean or average factor is determined. That factor becomes the local market-based modifier that is applied to the building cost table for that particular category of property.
Tom Green CAD subscribes to a multiple listing service (MLS) for real estate professionals. The CAD also researches deed recordings to identify property transactions. Tom Green CAD sends sales confirmation letters to buyers as recorded in the deed to confirm and verify the transaction and the amount of the transaction. CAD staff also research new homestead applications, new 911 addresses, and receive building permits from the City of San Angelo and septic permits from Tom Green County to gather information about new construction or construction on existing property. The CAD's confirmation and verification procedure is one that most CADs use.
The Tom Green CAD has developed a residential classification guide to promote uniformity and consistency among the appraisers in the way they classify residential properties. The guide has pictures of local houses and a description of property characteristics and attributes common to each class. For commercial appraisals, the CAD uses the Marshall & Swift Commercial Valuation Guide which also contains pictures and property descriptions.
According to the personal property appraiser, Tom Green CAD attempts to inspect as much business personal property annually as possible. Personal property values, however, are largely based on taxpayer renditions. The personal property appraiser reviews the renditions for reasonableness by comparing the rendered values to the personal property value schedule in the Property Tax Division's Field Appraiser's Guide and also values of similar businesses. Property not rendered is appraised using the square foot method by applying quality and density costs from tables found in the Field Appraiser's Guide. According to the personal property appraiser, personal property is discovered by reading the newspaper, phone book, requesting information from the sales tax division of the Comptroller's office, assumed name lists from the county clerk, radio and television advertisements, automobile registration lists from an outside vendor, word of mouth and by driving around the county. Rendition forms are mailed to all business owners every year.
Section 23.01(b), Tax Code, mandates that property be appraised by applying generally accepted appraisal methods and techniques. This section also requires appraisal districts to comply with the USPAP and requires similar appraisal methods and techniques be applied to the same or similar properties, while taking care to account for the contributions of individual property characteristics on value. Comprehensive appraisal procedures manual help ensure that these standards and requirements are attained.
Tom Green CAD has developed appraisal manuals for local procedures and practices.
Tom Green CAD took steps in 2005 to address deficiencies identified in the 2004 Property Value Study by improving procedures to gather income and market data on commercial properties.
Findings of the 2004 Property Value Study indicated that some residential and commercial properties in San Angelo ISD were being appraised below market value contributing to the school district's invalid finding. According to the senior appraiser, the CAD's reappraisal efforts concentrated on improving residential values, lake property, apartments, and hotels and motels.
Below market appraisals of high dollar commercial properties, such as hotels and motels, were a primary contributor to San Angelo ISD receiving an invalid finding in the 2004 PVS. With an overall category weighted mean ratio of below 80 percent, the study showed that the CAD needed to take steps to improve its commercial appraisals.
According to the commercial appraiser, in 2005 Tom Green CAD began an aggressive effort to obtain more reliable income and market data on commercial property. Surveys, commercial market reports, internet research and communication with business owners provide the CAD with current commercial market data. Some of the commercial property categories tested in the 2004 PVS had already been selected for review in 2005. Appraised values in Category F1, commercial real property, showed significant increases in 2005.
In 2005, Tom Green CAD reviewed and updated all of its residential cost schedules. Using sales information from 2004 and 2005, the CAD increased base residential building costs by as much as five percent. As a result, appraisal values increased in Category A, single-family residences, and Category D2, rural residential.
Tom Green CAD took steps in 2005 to address deficiencies identified in the 2004 Property Value Study.
Tom Green CAD is using value stratification as a tool to identify and eliminate unequal levels of appraisal.
Tom Green's CAD's computerized appraisal system allows the CAD to analyze its appraisals through ratio studies within and among property classifications. According to IAAO's Property Appraisal and Assessment Administration, a ratio study is a study of the relationship between appraised or assessed values and market values. Indicators of market values may be either sales or independent "expert" appraisals. Of common interest in ratio studies is the level and uniformity of the appraisals or assessments. The reviewer examined several ratio studies but focused on the studies in San Angelo ISD.
According to the senior appraiser, Tom Green CAD conducts ratio studies every year. The ratio studies are run within property categories, by school district and county at least quarterly to determine appraisal performance. The CAD was not spending a lot of time analyzing property characteristics within a category of sold properties. Property characteristics such as class, age, condition, size and value need to be considered in any ratio study to ensure appraisal uniformity and eliminate unequal levels of appraisal.
In June 2004, Tom Green CAD began using value stratification as an analytical tool in its ratio studies. The 2004 PVS final results indicated that within San Angelo ISD, Tom Green CAD was, in general, doing a good job of appraising single family residences with appraised values greater than $125,000, but was under appraising lesser valued homes. This lack of appraisal uniformity contributed to the invalid findings of San Angelo ISD and San Angelo ISD being identified as an eligible school district.
Exhibit 9 shows how the CAD is now using value stratification to analyze appraisal performance.
Exhibit 9 shows that while the average weighted mean of the 26 sales analyzed in Angelo Heights was .965, or 96.5 percent of market value, by analyzing the same data using value stratification, the CAD can see that homes valued between $54,001 and $124,800 are being under appraised.
Ratio Study Analysis
Average Weighted Mean versus Value Stratification
School: San Angelo ISD
Sub/NBHD: Angelo Heights
Sales Period: 6/1/04 - 11/22/05
Total Sales Value Total CAD Value Average Weighted Mean Number of Sales 26 $2,537,175 $2,449,000 .965 Value Stratification Number of sales Total CAD Value Total Sales Ratio $0 - $22,800 0 0 0 $22,801 - $54,000 6 $252,200 $249,400 1.011 $54,001 - $82,500 12 $740,350 $786,875 .941 $82,501 - $124,800 6 $615,950 $660,900 .932 $124,801 - or greater 2 $840,500 $840,000 1.001 Source: Tom Green CAD.
The 2004 PVS showed that residential home values in San Angelo ISD were appreciating at a rate of approximately three percent a year. The CAD's 2004 in-house ratio study did not reflect any time adjusted sales. A study of residential home sales in San Angelo conducted by the Real Estate Center at Texas A&M University confirmed that home values between 2003 and 2004 were increasing by as much as five percent a year. By carefully examining sales that occur close to the January 1 assessment date Tom Green CAD can better monitor appreciation or depreciation in the market place. The CAD's failure to recognize an appreciating residential sales market contributed to San Angelo ISD receiving an invalid finding from the Comptroller. Tom Green CAD is using ratio studies to plan appraisal maintenance programs. The chief appraiser felt the result of using ratio studies should be evident in the 2005 PVS. The preliminary 2005 PVS showed San Angelo ISD was back into the confidence interval and had valid local values.
The ratio study results indicate those market areas in the appraisal district whose values no longer reflect the market. If the ratio study in a market area shows the appraised values do not reflect the market, an appraisal district appraises the available sales to determine the market adjustment factor. The market adjustment factor is the percentage the appraisal district uses to adjust the appraisal schedules to reflect the market value.
Frequent ratio studies, and the appraisal maintenance that follows them, enable an appraisal district to keep its values at or near the market. Ratio studies are also used to determine actual appraisal performance of an appraisal district.
IAAO's Standard on Ratio Studies, Section 4, states that stratification is a basic step of a ratio study. Ratio studies are also used to determine actual appraisal performance of an appraisal district.
Tom Green CAD uses ratio studies and value stratification to eliminate unequal levels of appraisal within categories of property and to ensure all categories of property are being appraised at current market value.
Tom Green CAD's has a reappraisal plan based on a generic mass appraisal report.
Tom Green CAD revised a generic appraisal plan to represent Tom Green CAD procedures and reappraisal activities. The reappraisal plan provides some detail as to the steps to be performed, such as obtaining and using sales data in reappraising property in each market area, how market areas might be grouped to provide sufficient sales for appraisal model analysis and development and staffing levels, but the reappraisal plan does not provide specific details such as the costs associated with reappraisals, dates of reappraisals, or identify properties that are to be reappraised.
Section 25.18, Tax Code, requires appraisal districts to implement a plan for reappraisal. The plan for reappraisal shall provide for reappraisal of all real property in the appraisal district at least once every three years. A reappraisal plan is a roadmap for performing the work. It is also a communication tool that shows the appraisal district board of directors how the appraisal district staff plans to accomplish its appraisals, and if the board chooses to require the chief appraiser to submit the plan for approval, the board can direct the appraisal activities by amending the plan.
The 79th Texas Legislature, Regular Session, amended Section 25.18 and Section 6.05 of the Tax Code. Since September 2005, Section 25.18 of the Tax Code requires that the reappraisal plans include certain activities. "Reappraisal activities" include identification of properties and other specific matters that are listed in the law. A reappraisal cycle includes real and personal property; and a reappraisal plan must provide that property be physically inspected or identified. Further, the plan must be approved biennially by the district board of directors. The district must hold a public hearing to consider the reappraisal plan. The amended Tax Code Section 6.05 also requires the reappraisal plan be distributed to the taxing units and the Comptroller within 60 days of board approval. The law went into effect September 1, 2005 and requires the plan be approved before September 15 of even-numbered years.
USPAP Standard 6 provides a good resource for developing a reappraisal plan by describing the activities included in a functional reappraisal plan:
- identify and update in the appraisal records the relevant characteristics of each property to be appraised;
- define market areas;
- identify property characteristics that affect property value in each market area;
- develop an appraisal model that reflects the relationship among the property characteristics affecting value in each market area;
- calibrate the model to determine the contribution of the individual property characteristics affecting value;
- apply the conclusions reflected in the model to the characteristics of the properties being appraised; and
- review the appraisal results.
A thorough reappraisal plan discusses in detail how and when an appraisal district plans to perform each of the activities. A thorough reappraisal plan also provides for a physical inspection of the properties being appraised. Alternatively, the plan can include reliance on reliable sources of property information instead of physical inspections. Such sources include: deeds or other legal documentation, aerial photographs, land-based photographs, surveys, maps and property sketches. A complete plan would indicate instances or types of properties that will be appraised using sources of information other than physical inspection.
The primary function of every appraisal district is to appraise all taxable property equally and uniformly at market value. The chief appraiser and appraisal district staff are responsible for the day-to-day operations of the appraisal district, but the board of directors must adequately plan to accomplish these objectives and establish policies that serve as clear directives to the chief appraiser and staff. As representatives of the member taxing units, the board of directors is responsible for ensuring that the appraisal district produces an appraisal roll that reflects market value for all taxable properties. A detailed and properly executed plan would also ensure that taxpayers are treated uniformly in the payment of property taxes.
As a result, Tom Green CAD's lack of a comprehensive reappraisal plan may have contributed to receiving invalid finding for San Angelo ISD in the 2004 PVS. A detailed reappraisal plan, if executed properly, helps ensure that properties are appraised on a timely basis and that appraisals keep up with market changes.
Jefferson CAD, for example, has a detailed reappraisal plan that explains exactly how and when reappraisals take place and how sufficient resources will be allocated to follow the plan. The reappraisal plan ensures the execution of timely and accurate reappraisals on an annual basis and is reviewed each year and updated when changes are needed.
Develop a reappraisal plan that includes specific details such as the costs associated with reappraisals, dates of reappraisals, and identifies properties that are to be reappraised.
Tom Green CAD lacks a written plan and timeline for converting paper maps to computerized maps.
The CAD does not have a written plan or timeline for completing this project. According to the mapper, about one-third of Tom Green CAD has been mapped electronically. Completion is estimated to take another two to four years. New parcel splits and combinations are being mapped as they occur, while the mapper works on the remainder of the county as time permits. In the meantime, the CAD continues to rely on paper maps. The maps comply with IAAO standards and Comptroller Rules.
In 2003, Tom Green CAD began the process of converting paper maps to computerized maps as part of a geographic information system (GIS). Using Arc View software, the CAD's mapper enters metes and bounds of property taken from recorded deeds and plats. Each parcel is given a unique identifying number. Parcels can be displayed electronically as a single parcel or as part of a larger group of parcels, such as a subdivision or neighborhood. The GIS system shows parcels with relation to streets, roads, rivers, streams, and other topographical areas that can have an influence on property values. The system also identifies taxing entity boundary lines. Tom Green CAD's aerial maps are being integrated into the GIS system allowing all of the same data to be displayed on aerial maps. Upon completion, the mapping system will be integrated into the appraisal system.
Having an integrated appraisal/GIS system helps capture and verify more sales information, which it can use to improve its valuation of properties. An integrated system allows CADs to respond quickly to information requests by the public. An integrated system also allows both the appraiser and appraisal review board members access to more comprehensive information on a real time basis. It contributes to a timely and more efficient reappraisal and help to maintain consistent property valuation.
Johnson County Central Appraisal District (Johnson CCAD), for example, is actively involved in updating the GIS system by working with local governments, the county engineer, 9-1-1 coordinators and the sheriff's department to eliminate the duplication of parcel conversion. Parcel conversion is tracked and compared with monthly goals. The detailed planning establishes a completion goal as well as provides feedback for the board, chief appraiser and staff.
Develop and implement a plan and timeline for completion and integration of the GIS mapping system.
Tom Green CAD is not using the methodologies and definitions prescribed by Tax Code 23.41 and 23.51 and the Comptroller's Manual for the Appraisal of Agricultural Lands to determine agricultural productivity values for subcategories.
According to the chief appraiser, most of the county's irrigated cropland is in a classification designated "T-I-1," the most productive of the three classifications of irrigated cropland. The schedule of per acre values for agricultural lands indicates the value for this classification was $388.20 in 2004. The weighted average per acre value reported for the school districts in the CAD was $384.25; therefore, the overwhelming majority of irrigated cropland is in this category, versus T-I-2 with a per acre value of $369.70 or T-I-3 with a per acre value of $332.73.
In determining productivity values for irrigated cropland, the appraisal district determined that the typical lease rate was $45.98, $45.00, $48.00, $50.00, and $50.00 for 1998 through 2002, respectively. After deducting expenses for taxes and management, the five-year average net-to-land was determined to be $36.97. Dividing this average by the 10 percent required capitalization rate resulted in a per acre value of $369.70. Instead of assigning this value to T-I-1, since it was the typical irrigated cropland and must be represented by the typical lease rate, it was assigned to T-I-2. The value for T-I-1 is $369.70 times 1.05, or $388.20. The value for T-I-3 is $369.70 times .90, or $332.73.
In developing schedules for determining productivity value, the district establishes a per acre cost for the most typical category of property, which in Tom Green CAD was T-I-1. The typical cost in this instance was $369.70. The district, however, set this as the T-I-2 value and multiplied the typical value by 1.05, thus getting a higher value for T-I-1 than would be expected.
The Comptroller's Manual for the Appraisal of Agricultural Land provides that districts develop a typical value per acre of agricultural property and index this value to fit the type of agricultural land being appraised, that is, some property may be valued at a rate above or below the typical property value based on the classification of the property. In Tom Green, the typical property, or most common property, was T-I-1, but was assigned a value per acre higher than the typical value.
Using this method, the weighted average per acre value for irrigated cropland in the appraisal district would have been closer to $365.00 and closer to the per acre value determined by PTD. Comparing the weighted average per acre value for dry cropland and native pastureland reported by the appraisal district to the values determined by PTD indicate a similar situation might exist in these categories of agricultural land.
Section 23.41, Tax Code, states that land designated for agricultural use is appraised at its value based on its capacity to produce agricultural products. S.B. 760 and H.B. 2491, enacted during the 2005 Regular Session, now requires chief appraisers to determine agricultural productivity values for subcategories based on soil type, soil capability, irrigation, topography, and other factors influencing productivity. Section 23.51 of the Tax Code provides definitions used in the appraisal of agricultural land, such as qualified open-space land and agricultural use, net to land and exotic animal and wildlife management. Appendix D of the Comptroller's Manual for the Appraisal of Agricultural Lands provides an example to demonstrate some of the steps necessary to develop agricultural productivity values.
Review the determination of agricultural productivity values to assure compliance with the Property Tax Code and the Manual for the Appraisal of Agricultural Lands.
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.
The Tom Green CAD staff is profiled in Exhibit 10.
Tom Green CAD Positions, Certifications, Years with Tom Green CAD and Salaries
Position BTPE Certification(s) Years
Salary Appraiser RPA Class II 4 $26,500 Senior Appraiser/Supervisor RPA 24 $58,500 Chief Appraiser RPA 25 $68,250 Computer Programmer 21 $61,035 Executive Secretary RPA Class II, RTA 25 $45,025 Cashier 3 $19,555 Head Bookkeeper/Supervisor 24 $39,700 Residential Appraiser RPA 24 $44,625 Appraisal Clerk RPA Class II 2 $21,250 Abstractor 4 $23,400 Residential Appraiser RPA 24 $44,625 Systems Administrator/Supervisor 8 $42,650 Appraisal Clerk RPA Class I 6 $29,150 Commercial Appraiser RPA 4 $37,000 Personal Property Appraiser RTA Class III, RPA 24 $40,325 Mapper/Appraiser/Supervisor RPA 21 $51,235 Cashier 8 $21,325 Receptionist/Cashier 8 $27,535 Exemption Clerk 25 $34,325 Bookkeeper RTC Class I 3 $21,250 Residential Appraiser RPA 2 $38,825 Cashier Vacancy Source: Tom Green CAD, December 2005.
District employees who conduct appraisals must be registered professional appraisers (RPAs) or be working towards certification as an RPA; the latter must be certified within five years of their hire date. Interim certifications include Class II and Class III. In addition, RPAs must recertify every five years to remain registered. All Tom Green CAD appraisers are properly registered.
Tom Green CAD relocated to a new office which is more conducive to work and easily accessible to the public.
Prior to 2001, Tom Green CAD had been located in a county annex building owned by Tom Green County. It occupied about 6,000 square feet on the second floor with 800 square feet of storage in the basement.
Tom Green CAD sought out a better facility and purchased a 14,500 square foot office building that was built in 1984. According to the chief appraiser, the mortgage payments on the 15 year note are less than the rent the CAD had been paying to the county.
The office building was formerly a bank and contains cashier booths and a drive through window for tax collections. A fireproof vault secures cash drawers and computer backup discs after hours. Each appraiser has an office which provides privacy when meeting with taxpayers. The mapping, deed, computer and bookkeeping departments have their own separate work areas. Ample parking is available to the public and staff. A large board room is used by the board of directors and the appraisal review board and serves as a classroom for professional development classes.
Tom Green CAD offices now serve as a regional education center allowing professional tax organizations, such as the Texas Association of Assessing Officers, to hold education classes. By hosting professional development classes, the CAD is able to reduce the cost of educating its staff by eliminating travel costs to other locations.
Tom Green CAD sought out and purchased office facilities that are accessible to the public and provide staff a comfortable and productive workplace.
With the exception of the appraisal manuals, Tom Green CAD does not have well documented and updated policies and procedures to guide the day-to-day operations of the CAD in areas such as tax collections, payroll, accounting, and purchasing.
The head bookkeeper is responsible for the daily accounting functions and overseeing the daily operation of the bookkeeping department including the collection of current, delinquent taxes for the CAD and acts as a relief cashier. Additional responsibilities include processing invoices for payment, maintaining the general ledger and keeping payroll records. The three cashiers collect current, delinquent and partial tax payments, prepare tax exemption applications and requests for refunds. The head bookkeeper and cashiers are also responsible for providing public information to taxpayers and the general public.
These employees have an assortment of memos, handwritten notes, and copies of computer print screens to assist them in the procedural aspects of their work. The chief appraiser said that the CAD relies on one-on-one training in applying many of its policies and procedures, with the older more experienced staff training new and reassigned staff, using several old copies of procedures. According to the chief appraiser, almost half of Tom Green CAD's staff has been employed for more than 20 years and long term memory guides them through the day to day processes.
Some policies and procedures are adopted by the board are recorded in the board minutes, such as policies concerning nepotism and the Plan for Providing Assistance to Non-English Speaking and Handicapped Persons Wishing Access to the Board; however, there are no written policies or procedures dealing with the day to day operations such as the Delinquent Tax Payment policy also mentioned for tax collections in the board minutes. The chief appraiser is responsible for insuring that polices are implemented and followed by staff, but it is unclear how polices and procedures are translated into day to day practice in the district.
A policy tells a person, department, or group of individuals what they must do, whereas as procedure enumerates how it can be accomplished.
Well-written and organized procedures:
- implement and assure compliance with board policies as well as documenting the intent of those policies;
- protect the institutional knowledge of an organization, so that as experienced employees leave, new employees have the benefit of the others' years of experience;
- provide the basis for training new employees; and
- offer a tool for evaluating employees based on their adherence to procedures.
In the absence of well documented procedures and policies, the work of the appraisal district may be at risk if there are changes in key personnel.
In order to be effective, policy and procedure manuals are updated and kept current at all times. This requires setting up a system for regular updates and distribution, as well as periodic reviews to ensure that all old policies are removed when no longer needed.
Policies and procedures are developed to identify the day to day procedures used by and appraisal district to meet its statutory obligations, as well as the staff responsible for achieving these tasks. In the absence of well documented policies and procedures, the work of the appraisal district may be at risk of not meeting statutory obligations.
Jefferson CAD, for example, has an excellent set of written policy and procedures manuals for district operations. Jefferson CAD maintains a policies and procedures manual for the board of directors to follow and another set for the everyday operation of the district.
Develop administrative policies and procedures to guide day-to-day operations.
Tom Green CAD's employee manual does not include a systematic approach for employee evaluation.
Each employee has a written job description, but the CAD does not have written procedures for evaluating job performance. According to the chief appraiser, the CAD does not evaluate employees. The chief appraiser feels that evaluations are unnecessary as long as there is a tenured staff and counsel's staff only when necessary for disciplinary reasons.
Employee evaluations establish avenues for recognizing outstanding staff and staff achievements. Evaluations provide meaningful feedback and point out any short falls or inconsistencies in staff performance. Inconsistencies in staff performances may lead to inconsistencies in overall CAD operations, such as under appraising.
The employee's performance of assigned duties and other job-related criteria provides the basis for employee evaluations. Employees need to be informed of the criteria on which they will be evaluated. A detailed job description is essential for effective evaluations and performance appraisal ratings need to be based on an evaluation.
Each employee needs to have at least one evaluative conference annually to discuss the written evaluation and may have as many conferences about performance of duties as the supervisor deems necessary. Evaluation records and forms, reports, correspondence and memoranda are placed in each employee's personnel records to document performance. All records that support appraisal ratings need to be maintained for at least two years. By developing procedures to evaluate staff performance, the chief appraiser can set employee goals and evaluate staff performance.
Official appraisal records should be maintained throughout a person's employment with the CAD and for two years after an employee ceases to be employed with the CAD. All employees need to receive a copy of their written evaluation. A proper personnel evaluation process is essential to employee development and high morale. The CAD was unable to provide any recent performance appraisals of staff.
IAAO's Property Appraisal and Assessment Administration in Chapter 16, "Administration," states, "Although employees may improve their skills by their own efforts and the help of peers, managers have organizational responsibility for employee development. They use training, education, counseling, and performance reviews to identify talents and help employees grow."
Nueces CAD, for example, provides a good example of a systematic approach for annual performance evaluations. Evaluations are based on an evaluation instrument and performance data gathered by supervisors and each Nueces CAD employee has at least one evaluative conference annually to discuss the written evaluations.
Develop an annual personnel performance evaluation system to evaluate all CAD staff.
Computers have become a necessity for all appraisal districts. The use of computers allows an appraisal 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 an appraisal 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.
Technology is a critical part of managing large amounts of data effectively and appraisal districts use appraisal systems and mapping or geographic information systems to improve appraisal accuracy and uniformity.
Exhibit 11 presents a list of appraisal and administrative software used in Tom Green CAD
Tom Green CAD
Appraisal and Administrative Software
Name of Software Standalone or Integrated When Installed Last Upgraded Planned Upgrade In-house Written Appraisal & Collection Integrated 1980 Ongoing Ongoing Greenbriar Diagnostics (Sketching) Standalone 2000 Not applicable Not applicable Microsoft Office Standalone 2000 2005 As Announced Quick Books Standalone 1995 2005 2006 Arc View 3.3 Standalone 2003 2005 (9.1) 2006 Source: Tom Green CAD, December 2005.
Tom Green CAD does not electronically submit appraisal rolls to the Comptroller's office as required by Comptroller Rule 9.3059.
In 2004, the CAD submitted appraisal roll information on paper forms. According to the chief appraiser, the limitation of resources available for the enormous amount of programming required for Electronic Appraisal Roll System (EARS) has prevented the CAD from participating in EARS; however, Tom Green CAD does submit some data such as sales and deed information on compact disc. The chief appraiser has not done a formal study of the actual costs and has no plan to convert the present submission of appraisal rolls.
CADs with automated systems spend about 3 percent of their annual budget on software maintenance. For Tom Green CAD, 3 percent of its annual budget would be approximately $45,000. In Tom Green CAD's 2006 budget, the CAD budgeted $15,750, .94% of its total budget, for computer expenses; this amount doesn't include software maintenance because Tom Green CAD's appraisal system was developed in house.
Comptroller Rule 9.3059 states that effective September 5, 2005 appraisal districts are to provide appraisal roll information according to the Electronic Appraisal Roll Submission Record Layout and Instructions Manual. According to the manual, EARS requires districts to provide appraisal roll information in a standard electronic format. The information is the minimum appraisal roll data the division needs to develop local school district values and determine the amount of property tax exemptions granted by a school district.
Electronically generated reports of local property value can be more accurate than hard copy reports, which are vulnerable to human error. When appraisal roll data is received electronically the Comptroller can generate stratification reports and randomly select properties for appraisal in the Property Value Study. Appraisal districts benefit from participating in EARS because they do not have to complete several required hardcopy reports and the ability to stratify PVS samples greatly enhances the accuracy of PVS results. By budgeting, planning and creating a timeline to participate in EARS, the CAD is less vulnerable to human error.
In 2004, 204 of 253 appraisal districts sent their appraisal roll data to the Comptroller electronically. Young CAD, for example, was able to submit their appraisal rolls electronically in 2005 by contracting with a new software vendor.
Prior to 2005, Young CAD had to submit long forms in order to provide data for the PVS. Young CAD realized it could comply with the Comptroller's Rule 9.3059 by upgrading its appraisal software. Young CAD developed a plan and budget, upgraded its appraisal software and began submitting its appraisal roll electronically for the 2005 PVS.
Budget, plan and create a timeline to comply with EARS.
Tom Green CAD needs to determine the cost of making changes to its software, or upgrading the system, and use this information to develop a plan and timeline for compliance with Comptroller's Rule 9.3059.
Tom Green CAD does not have a comprehensive disaster recovery plan.
According to the CAD's systems administrator, daily computer system backups are performed for all work and a weekly system backup is kept offsite at city hall in San Angelo. This location was selected because the city has the same AS/400 system. The reviewer found no documentation showing that the recovery plan has ever been tested.
Tom Green CAD's one page Emergency Recovery document states that in addition to the City of San Angelo, Concho Valley Electric Coop has a compatible AS/400 system. The document lists eight steps to be taken in case of an emergency:
1. place call to establish time frame and availability of system
2. gather backup tapes
3. gather other information and tools
4. load data on back up system
5. contact local hardware service provider, establish time when system will be repaired/replaced and ready for operation
6. restore programs to CAD system
7. test programs and data
8. resume normal operations
The plan lacks sufficient detail, such as the critical staff necessary to carry-out the recovery operation needs to be identified. State and local governments, taxpayers, vendors, and the general public need to know how and when to contact the Tom Green CAD. In the case of loss of district facilities, district staff need a written plan directing them where and when to report to work if facilities are uninhabitable.
An effective disaster recovery plan addresses:
- immediate response;
- incident control/evaluation;
- environmental restoration; and
- resumption of critical business functions.
Prudent appraisal districts have a plan to recover data and continue appraisal district operations with minimal interruptions in disaster situations. Key items in the plan include instructions for alternate office locations and communications, and recreating appraisal, mapping and tax collection systems. With an effective disaster recovery plan, the CAD will ensure business continuity for the CAD, taxpayers and the taxing units.
The Texas State Library and Archives has an example of a disaster recovery plan available for use by local governments. It can be accessed on their Web site http://www.tsl.state.tx.us/slrm/disaster/recovery_plan.pdf.
Expand the CAD's disaster recovery plan and test it.
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.
The chief appraiser has legal responsibilities for preparing the appraisal roll within a statutory time frame. Evidence provided to the reviewer indicated that appraisal rolls were certified in a timely manner.
Section, 5.07, Tax Code, requires the Comptroller to prescribe forms for the administration of the property tax system in the state. The forms must be uniform but the Comptroller may prescribe or approve substitute forms. Appraisal districts must also file various reports to the taxing units and the state and comply with a host of laws, rules and regulations. The Comptroller also is required to prescribe a uniform record system to be used in submitting data for the annual Property Value Study.
Tom Green CAD links directly to the Comptroller's Web site and uses the latest forms and applications promulgated by the Comptroller for exemptions, special use appraisals, tax certificates, renditions and a variety of other assessment and administrative functions. Proper notice of application requirements are also furnished to the public.
Tom Green CAD annually publishes notices in an area newspaper informing residents of their rights to various exemptions and their responsibility to render business personal property. The notices explain how, where, and when to file the necessary forms and applications.
The Tom Green CAD has written procedures for administering exemptions. Some of the steps in the validation process are:
- determining if an application is required by the Tax Code;
- reviewing criteria for ownership and use;
- on site field inspections; and
- written notification of action taken (grant, denials, need additional information).
Sections 11.43 and 11.44 of the Tax Code requires the filing of various forms and applications with the appraisal district before exemptions and special use appraisals can be granted. The code also requires public notification of taxpayer rights and responsibilities with respect to exemptions, special use appraisals, and renditions.
By linking to the Comptroller's Web site, Tom Green CAD ensures the latest forms and applications are available and there is sufficient public notification.
Tom Green CAD does not comply with Local Government Code and has not filed a records control schedule with the Texas State Library.
According to Tom Green CAD's executive secretary, the CAD relied on Tom Green County's records management program. The records control schedule and accompanying documents provided to the reviewer were filed with the Texas State Library by the county in 1994. Until 2001, the CAD and all of its records were housed with county offices in a county annex building. The CAD is in the process of filing its own record retention schedule with the Texas Sate Library.
As long as old records are retained those records must be managed and are subject to open records requests.
According to the Texas State Library, the benefits of records management are:
- complying with legal requirements;
- destroying records that no longer have value to the government;
- providing legal protection to the government when destroying records;
- retaining records of permanent value;
- improving protection of vital records;
- providing security for records with confidential or sensitive information;
- efficiently using office space for active records;
- moving inactive records into less expensive storage areas, if possible;
- releasing equipment and reusable media for other productive uses; and
- maintaining records in the formats offering optimum cost-effectiveness.
Local Government Code, Sec 203.041(a) requires that each local government must develop a records control schedule and file the schedule with the Texas State Library. Sec 6.13 of the Tax Code states that appraisal districts shall comply with the requirements of the Local Government Code.
Matagorda CAD, for example, has written procedures for document storage, retention and destruction. Matagorda also has a records control schedule on file with the Texas State Library. The schedule identifies various appraisal district records and their retention periods. The CAD also developed procedures for storing, retaining, and destroying documents.
Develop a plan and timeline for completing a records control schedule.