Domestic Energy Assessor Quality Assurance Requirements England & Wales and Northern Ireland Regions Effective Date 1 st August 2012 Sampling Approach Random Sampling Overall, a minimum of 2% of lodged EPCs per calendar year must be audited by Schemes through a process of random sampling. The method of assessing these EPCs will be a desk-based audit which complies with the requirements set out in DCLG s Scheme Operating Requirements. The calendar year is 1 st January to 31 st December. The quarter periods are January 1 st to March 31 st, April 1 st to June 30 th, July 1 st to September 30 th and October 1 st to December 31 st. Minimum Checks All members will be subject to a minimum check of: i) One EPC audit per quarter, unless they lodge no EPCs in that quarter; ii) 1% of their EPCs over the calendar year. New Members New members shall be assessed within their first 30 days of membership. If no EPCs are lodged during this period, the first available EPC will be audited. Following this, the sampling rate for newly registered assessors shall be at least 5% of lodged EPCs during the first six months of their membership. New members to a Scheme are those who are: i) New to the EPBR; or ii) New to the Scheme, unless they are currently members of another Scheme or Schemes, and checks with all Schemes of which they are members have demonstrated that the individual is not subject to heightened QA by any other Scheme; or iii) Have not lodged an EPC within the previous two years.
Audit Feedback In all instances of an EPC audit, the Scheme will provide feedback to the assessor via e-mail. This feedback may also be accessed via Elmhurst s QA Hub. Targeted Sampling Random Sample Failed Audit Where there are errors which result in an EPC failing an audit, the assessor shall be given feedback as to why, along with appropriate remedial action to both replace the defective EPC and ensure that similar failures do not reoccur. The remedial action will also take into account any history of failures associated with the individual assessor. Where a random sample EPC audit is assessed as a failure and the EPC marked as defective, the Scheme shall audit TWO further EPCs including at least one EPC lodged within the 30 day periods both prior to and following the date at which the audit feedback is given to the assessor. If this is not possible, the Scheme shall select TWO EPCs for audit that were lodged within the 30 days following the date of the initial call for audit, or the next TWO EPCs to be lodged if this time limit is exceeded. An additional exception to this is if the calculation conventions have changed in the period of 30 days prior to feedback being given to the initial audit failure. In this situation, the first TWO EPCs produced since the introduction of the new calculation conventions shall be selected for audit. Targeted Sample Failed Audit If an assessor passes both targeted audits triggered by the initial audit failure, they will revert to the audit schedule appropriate to their status as either a new or established member. If an assessor fails one of the two targeted audits triggered by the initial audit failure, the Scheme will make a judgement as to the remedial action, based on the seriousness of the failure: i) If the error was due to, for example, an oversight or misunderstanding of a software protocol which is easily corrected, and so the error is unlikely to be repeated, the assessor shall be informed and their future work checked to see that they have learnt from the feedback;
ii) iii) If the error indicates that the assessor lacks basic understanding, they shall be suspended until the results of suitable training convince the Scheme that there is low risk of repetition; If the error indicates fraudulent practices, the assessor shall be suspended pending further investigation. If an assessor fails both of the two targeted audits triggered by the initial audit failure, they will be automatically suspended until the results of suitable training convince the Scheme that there is a low risk of repetition. Auditing Regime after Return from Suspension After the return from suspension, the assessor will be subject to whichever is the greater of the following: Auditing of 10% of lodgements over the next six months, subject to at least five EPCs being assessed during the period; or An audit of five EPCs within six months; or The next five EPCs lodged. Appeals Against Audit Results Members are entitled to appeal against the outcome of a QA audit if they have reason to believe that the result is incorrect and all such appeals will be heard by a suitably qualified person other than the original QA auditor. Appeals should be forwarded to the Scheme s QA Administrator at deaqa@elmhurstenergy.co.uk, stating the reasons why the assessor believes that the audit result is incorrect. Please note: Failure due to the non-provision of mandatory survey evidence, or provision of insufficient evidence, does not constitute grounds for appeal. Additional Audits In addition to random and targeted audits (detailed above), members will be subject to additional QA audits under the following circumstances: Failure To Provide Evidence Where the assessor fails to provide any evidence within the mandatory timescales.
Failure To Provide Sufficient Evidence Where the assessor fails to provide sufficiently good evidence to allow the QA auditor to undertake the EPC audit. Use of Stock Photographs Where there is compelling evidence that an assessor has used stock photographs but does not have their membership revoked. Replacement of Defective EPCs EPCs produced to replace those which have been failed shall be audited. Consumer Complaints These would normally result in an audit of the EPC in question. High Lodgement Rates Where an assessor lodges a particularly high number of EPCs in a calendar month, and multiple certification/sampling and cloning techniques have not been used, the Scheme is expected to undertake additional checks to ensure that the assessor has visited the properties. Excessive Use of the Help Desk Assessors who make unusually high use of the help desk, without obvious reason such as dealing with an unusual building, or whose queries suggest they are at high risk of producing defective EPCs shall trigger, as a minimum, the auditing of the next available EPC and a sampling rate of 5% over the next six months. Other Risk Factors Where a Scheme is concerned that an assessor may be at high risk of producing a defective certificate, the next EPC lodged by the assessor may be requested for audit, as a minimum. DCLG Specified Audits The Scheme shall undertake QA checks on specified EPCs if requested to do so by DCLG. Provision of QA Evidence Requests for QA audits will normally be sent out to assessors via e-mail. Requests and reminders can also be tracked by assessors via Elmhurst s QA Hub. Assessors must ensure that all necessary evidence is submitted to Elmhurst within 15 working days of the initial request. It is recommended that all evidence is submitted via Elmhurst s QA Hub in order to ensure safe and prompt receipt. Alternatively, evidence may be submitted via post or e-mail although any
assessor choosing to submit evidence this way should understand that this may lead to a delay in the receipt of their submission. The submission deadline can be extended in cases where the assessor is, or will be, late for legitimate reasons. These reasons may include absence from work due to illness, holiday or similar, coupled with no lodgement activity. An extension can be allowed to cover a period of up to working 5 days after the assessor s return to work. In order for this to be considered, the assessor must contact the Scheme prior to the expiry of the initial fifteen working day period. Failure by an assessor to provide satisfactory evidence within the mandatory deadlines shall trigger immediate suspension from the Scheme. This suspension shall only be lifted if the assessor provides a reasonable and compelling case as to why the information is not available. Where the suspension is lifted, the Scheme shall undertake two further audits from the subsequent 30 days following the date of the initial call for audit, or the next two EPCs lodged if this time period is exceeded, except where the assessor provides a reasonable and compelling case as to why the information is not available. An example of a reasonable and compelling case would be where there is a specific client requirement that no photographs shall be taken or other information provided (e.g. MoD living accommodation). If it is not possible to undertake the audit based upon the limited evidence available, the Scheme shall select another EPC for audit, where the same constraints do not apply. An example of a reasonable and compelling case which depends on the number of times the excuse, or similar excuses, are used would be where an assessor has given an excuse which is not client-directed (e.g. camera or PC malfunction, loss of photograph files due to lack of backups etc). Multiple uses of this, and similar, instances shall lead to the Scheme suspending the assessor who fails to provide the data requested more than twice in any given 12 month period following the initial failure to provide evidence. Suspension shall only be lifted after the Scheme has investigated the assessor and is assured that the assessor shall meet future requirements associated with evidence provision. Where an assessor simply does not respond to a QA audit request, they shall remain suspended. Should the assessor eventually respond to the request, but without a reasonable
case, the Scheme shall investigate the reason for late provision of data and impose appropriate measures. Sampling and Multiple Certification Where a number of similar properties are being surveyed and a sampling approach is adopted, the following evidence is expected: Photographs, floor plans and site notes for the median property The schedule of properties from which the groups have been selected Records confirming external visual inspections of properties in each group A calculation to show how the number of properties to sample was determined How the median property was selected EPC results for each of the surveyed dwellings A comparison of the results to show that they are within acceptable tolerances. Please refer to the table below: Parameter SAP rating EI rating Floor area Tolerance 90% of the sample properties should have a SAP rating within + 4 SAP points of the SAP rating of the median record; and 95% of the sample properties should have a SAP rating within + 6 SAP points of the SAP rating of the median record 90% of the sample properties should have an EI rating within + 4 EI points of the EI rating of the median record; and 95% of the sample properties should have an EI rating within + 7 EI points of the EI rating of the median record. 90% of the sample properties should have a floor area within + 5% of the floor area of the median record; and 95% of the sample
Recommendations properties should have a floor area within + 7.5% of the floor area of the median record. 95% of reports should contain identical recommendations; and No reports should contain recommendations that would be fundamentally inappropriate for other properties in the sample. Common Values Approach For dwellings that share some similar characteristics, but are not suitable for the multiple certification approach, the minimum requirements for the monitoring of surveys lodged in this way will be: The schedule of properties from which the groups have been selected A calculation to show how the number of properties to sample was determined Records of inspection and photographs for the assessed properties EPC results for each of the surveyed dwellings Failure To Provide Evidence Of Sufficient Quality Where a Scheme QA auditor is unable to audit an EPC due to unsatisfactory evidence, such as poor photographs or site notes, the Scheme shall fail the audit and mark the EPC as defective. The assessor shall be informed of the shortcomings and given instructions on how to improve their performance. The Scheme shall audit a further two EPCs lodged within the 30 days following the date at which the audit feedback was given or, if insufficient lodgements are made, the next two EPCs. If any of these targeted audits fail due to a failure to provide evidence, the Scheme shall suspend the assessor. Reinstatement shall only occur if either: i) New, satisfactory evidence is provided; or ii) The assessor can demonstrate without doubt that the reason for the non-provision of evidence was beyond their control, and that the assessor has taken steps to ensure that further instances do not occur. On return from suspension, the assessor shall be subject to increased QA auditing at a rate of:
i) Whichever is the greater of either 10% of their EPCs over the next six months or five EPCs over the next six months; or ii) The next five EPCs lodged after the six month period if requirement i) cannot be met. Stock Photographs & Failure to Visit The Property Where there is evidence that an assessor has used stock photographs or failed to visit dwellings when required, the assessor shall be suspended pending investigation which shall include: i) Discussions with the assessor; ii) A formal interview with the assessor; iii) A review of all photographic evidence provided by the assessor for auditing purposes over the past two years; iv) A review of other evidence available to the Scheme, including any which the assessor provides. The assessor shall only be reinstated if the Scheme is confident that all of the following apply: i) The assessor is visiting dwellings as required; ii) The assessor has shown the use of stock photographs was not intended to mislead. An example would be where an assessor mistakenly submits photographs previously submitted for a different audit. Where there are multiple instances of use of the same photographs, this shall be taken as clear evidence that an assessor has intended to mislead. iii) The assessor has undertaken not to use stock photographs again under any circumstances. Following reinstatement, Schemes shall implement the following additional checks: i) Two new EPCs lodged in the succeeding 30 days following the lifting of suspension or, if this is not possible, the next two shall be subjected to QA audits. ii) All subsequent random sampling audits for at least the next year shall include checks that stock photographs are not being used. The suspension shall only be lifted if the Scheme is satisfied that the assessor has visited the property in accordance with DCLG s requirements. In this case, the additional check detailed above shall apply.
If the Scheme is satisfied that the assessor has not visited the property when this was required and/or the assessor is found to have been using stock photographs (apart from exceptional circumstances and where there was no intention to mislead),the assessor s Scheme membership shall be revoked. Accuracy Requirements The Scheme target set by DCLG is for no more than 5% of random sample EPC audits in any month being defective. Whether an EPC is defective shall be assessed by a Scheme QA auditor, shall be evidence based and the quality and availability of the evidence used by the Scheme shall be such that the QA auditor s assessment can be replicated by DCLG. The QA audit will fail and the EPC will require replacement if any of the following criteria are met: The sum of the absolute errors between the assessor s and QA auditor s SAP score exceeds 5 SAP points Errors in the dwelling s description result in a change to the recommendations made The dwelling s description is sufficiently inaccurate to cause Customers to doubt the accuracy of the SAP rating. Sufficiently inaccurate means information in the EPC which is demonstrably incorrect and capable of correction within the bounds of the SAP current at the time of the assessment on the basis of what the assessor should have observed Where an EPC is not assessed as defective, but where a SAP error means that the EPC banding changes, either upwards or downwards, the Assessor is required to replace the EPC. Such an occurrence shall not be recorded as an audit failure, and nor shall there be any other actions placed on the Energy Assessor other than to replace the EPC.
Replacement of Defective EPCs If an audited EPC is deemed to be defective, the assessor will be informed and a mandatory re-lodgement of the EPC will be required. The assessor must notify the Scheme of the RRN of the replacement EPC in order that the original certificate can be made not for issue. The assessor must ensure that the mandatory re-lodgement is completed within 10 working days of notification by the Scheme. Failure to comply within this timescale will result in the suspension of the assessor and continued refusal to replace the defective certificate may lead to expulsion from the Scheme. Where an assessor replaces a defective certificate, the replacement EPC shall be audited by the Scheme to ensure that it is satisfactory. If the replacement EPC fails the audit, the assessor shall be suspended until the Scheme has assessed the nature of the failure, the likelihood of future EPCs being defective, and suitable remedial action has been successfully completed. Expulsion from the Scheme Where an assessor does not respond appropriately to the suspension process, or where there are repeated incidents of suspension which demonstrate a lack of competence or failure of corrective actions, the assessor may face expulsion from the Scheme.