Department of Climate Change and Energy

Efficiency

Compliance activities – Household Sustainability

Assessment Scheme Assessor Accrediting
Organisations
October 2010

This report and PricewaterhouseCoopers deliverables are intended solely for the Department of Climate Change and Energy Efficiency internal
use and benefit and may not be relied on by any other party. This report may not be distributed
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other partyy without PricewaterhouseCoopers’
PricewaterhouseCooper prior written consent. PricewaterhouseCoopers accept no liability or responsibility to any other party
who gains access to this report.

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 Contents

1. Executive Summary 2
2. Methodology 6
3. Compliance with key elements of the Protocol for
Assessor Accrediting Organisations 8
Appendix A: Engagement scope 22
Appendix B: DCCEE and ABSA representatives 27

Version History

Version Date Details

0.1 10/2/2010 Initial draft for review
1.0 22/2/2010 Updated to reflect comments received from the
Department
2.0 9/7/2010 Updated to reflect comments provided by ABSA and a
response to ABSA’s comments by the Department
3.0 2/9/2010 Revision to reflect the Department’s feedback on version
2.0
4.0 8/10/2010 Revision to reflect the Department’s feedback on version
3.0
11/10/2010 Report accepted & issued
1. Executive Summary

In accordance with our scope of 3 February 2010 (Appendix A), we have

performed a review of selected elements of the Association of Building
Sustainability Assessors (ABSA’s) operations as an Assessor Accrediting
Organisation (AAO) under the Home Sustainability Assessment (HSA)
Scheme.

Our work was undertaken in order to understand and evaluate the

procedures and processes used by ABSA in carrying out its obligations
under the Protocol, particularly in relation to initial assessor accreditation,
and periodic assessor QA procedures that may be undertaken by ABSA
from time to time.

As indicated at Section 2 – Methodology, some months have passed

between issue of the draft report and its finalisation. We have reviewed all
documentation provided to us and made updates to this report in
accordance with the described methodology. In addition, we have performed
further procedures to verify certain information subsequently presented by
ABSA and the Department.

Overall findings

The following key findings have arisen from our work:

1. ABSA have demonstrated their adherence to the requirements of the

Protocol document, consistent with their accepted application to become
an AAO, in many areas.

These include ensuring applicants hold appropriate insurance cover,

obtaining evidence that an applicant is a “fit and proper person” under
the Protocol, and confirming that the applicant agrees to abide by the
Assessor Code of Professional Practice. The organisation is also
providing appropriate support services to its members under the
Protocol.

2. The review team noted a number of areas where ABSA are not in strict
accordance with Protocol requirements. Protocol obligations appear to
have not been met as a result of one or more of the following:

a. Differing Protocol interpretations. For example, in the case of the

Protocol requirement to publish a Trainer Qualification and Experience
Policy, the Department holds that ABSA should set minimum standards
for any trainer proposing to deliver the approved HSA course.
Conversely, ABSA have asserted that such a policy is the responsibility
of the training organisation itself and have not published any statement.

b. Differing views on the applicability of Protocol requirements.

ABSA’s written application to become an AAO set out certain areas
where compliance was dependent on access to information, and areas

2
 where ABSA believed they would not be able to comply with the
requirements of the Protocol. ABSA believes that when their application
was accepted by the Department, this act implicitly amended their
obligations under the Protocol.

Since receiving version 1.0 of this report, the Department has received
advice from its in-house legal counsel on whether the accepted
application implicitly amended ABSA’s compliance obligations. The
advice indicated that the Department’s acceptance letter to ABSA
acknowledges that the proposal is consistent with the published
Protocol. While indicating a probability that the Protocol is likely to take
precedence over the application in the event of inconsistency, the advice
goes on to state that there is no indication of how inconsistencies
between the Protocol and ABSA’s proposal should be resolved. The
Department has indicated it holds a differing view to ABSA’s, in that it
believes all obligations specified in the published Protocol stand.

c. The Department taking responsibility for a particular function or task.

In the case of continuing professional development, the Department
engaged the University of Tasmania to provide a series of CPD units.
ABSA await the provision of these units and to date have not provided
CPD materials to assessors themselves, although provision to do so has
been made on the HSA scheme website.

d. Information necessary to support Protocol requirements is not

readily available. For example, at the time of the fieldwork in February
2010 a scheme auditor had not been appointed. Although this has since
occurred, as yet no quality-related findings or themes arising from audit
activity have been made available to ABSA. ABSA believe that the
absence of access to auditor findings has impeded their ability to satisfy
the Quality Assurance requirements under the Protocol. The
Department believe that this should not affect ABSA’s ability to meet
their obligations under the Protocol.

e. The approved training course is currently unaccredited. ABSA is

required to confirm that applicants hold a Statement of Attainment in
Professional Household Sustainability Assessments in accordance with
the Australian Qualification Framework (AQF). The developed course,
while addressing all required competency areas, is unaccredited and is
content-based. As a result, training organisations are unable to issue a
“Statement of Attainment” (they issue certificates of attendance) and
cannot recognise prior learning. We note that the intent to accredit the
course is clear and action is underway to achieve this.

Under the Protocol, in the absence of a Statement of Attainment, ABSA

should confirm whether applicants hold competencies across eight
overarching areas specified in the Protocol. In the absence of a
competency-based accredited course, ABSA believes that there is no
practical means of meeting their obligation to confirm that an applicant
has achieved a minimum level of competence in all of the required

3
 competency areas. Ultimately, this exposes both ABSA and the
Department to assessor competency risk.

The Department have advised that accreditation of the Home

Sustainability Assessment Course is underway, with the proposed
Certificate IV course having been submitted to States and Territories for
endorsement. The Department have indicated that a determination on
course endorsement is expected to be made in September 2010.

Further, at the time of fieldwork the review team noted that fifty two
organisations had issued course attendance certificates. Up until
September 2009, the approved course could be delivered by
organisations other than RTO’s, providing the organisation had access
to the approved course materials. ABSA took a decision to recognise
only RTO’s from September 2009 onwards.

ABSA provided evidence to show that agreement on many of their Protocol

departures had been sought from the Department, however it is understood
that discussions to arrive at an updated Protocol agreement have not
reached a conclusion. In correspondence dated 6 July 2010, the
Department acknowledged that the role and responsibilities of the two
parties do need to be clarified in relation to a number of requirements set out
in the Protocol, and has indicated that it will work with ABSA based on the
findings of this report.

4
Key actions
The following actions are suggested in order for the Department to address
the findings noted in this report. Suggested actions are presented in an
illustrative time sequence order in the list below.

1. Develop a suitable means to verify the competence of every registered

assessor in the immediate future (such as a compulsory examination for
all existing assessors covering each domain area).

2. Implement a mechanism to identify assessors more likely to have issues

arising from their training. This could include undertaking a desktop
audit of all training organisations involved to determine the degree of
rigour attached to their enrolment acceptance processes and course
materials delivery, and generate a training organisation risk profile, or
some other means considered suitable by the Department.

3. Complete the development of Continuing Professional Development

(CPD) units through the University of Tasmania, and provide them to
ABSA for publication for the benefit of all assessors.

4. Obtain accreditation for a HSA training course and carefully consider the
need for any grandfathering arrangements for existing assessors. The
Department have since advised that accreditation of the Home
Sustainability Assessment Course is underway, with the proposed
Certificate IV course having been submitted to States and Territories for
endorsement. The Department have indicated that a determination on
course endorsement is expected to be made in September 2010.

5. The Department and ABSA should conclude discussions to update the

existing Protocol for Assessor Accrediting Organisations and formally
agree on a revised set of achievable obligations for ABSA as an AAO.
The Department should assign a relationship manager to oversee the
application of the Protocol and ensure governance and compliance
obligations are met in a demonstrable and timely manner.

6. Leverage the results of (1) and (2) to inform the content of upcoming
CPD units. For future CPD purposes, the Department should consider
how best to give ABSA access to information that could assist in
identifying knowledge gaps so that appropriate CPD activities can be
provided.

7. ABSA should perform a reconciliation between their internal database,

IMIS, and assessor applications to ensure that all applications are
reflected in the database and that key details impacting ongoing
accreditation (such as insurance expiry dates) are accurately recorded.

5
2. Methodology

Our approach involved reviewing ABSA’s accreditation of HSAS applicants

to determine whether ABSA have adhered to key obligations as an AAO and
to report the results of those procedures to the Department. In scope areas
included assessment of an applicant for accreditation and quality assurance
requirements of the Protocol.

Our review was performed in four stages. These involved:

Stage one – initiation

This stage involved gaining a clear understanding of the Departments’

requirements for the report and to understand what the Department believes
ABSA’s roles and responsibilities are.

Discussions were held with Department representatives to obtain

background information on the program and to understand how the Protocol
was developed and implemented.

Stage two – information gathering

The aim of this stage was to visit ABSA’s premises in Sydney to gain an
understanding of ABSA’s obligations as an AAO through:

 reviewing available documentation, including the Protocol document,

ABSA’s application to become an AAO, and other documentary
evidence including correspondence between ABSA and the
Department

 discussions with ABSA representatives

 gaining an understanding of in scope processes through review of

available documentation, discussions with key ABSA
representatives and an observation and walkthrough of the
application checks performed

 identifying key points of internal control within the process

 evaluating process design against AAO obligations

 validating key points of internal control through limited testing where

appropriate.

6
Stage three - reporting

During this stage we analysed our findings from stages one and two to
report our factual findings and suggest key actions. A draft report was issued
in February 2010 and circulated to Department stakeholders for comment.
The draft report was updated and the Department subsequently released it
to ABSA for their review and response.

Stage four – report finalisation

During this stage we analysed further information provided by ABSA in June

2010 in its formal response to the Department, and information provided by
the Department in August 2010 in relation to ABSA’s response. PwC
reviewed all documentation provided and performed further procedures to
validate claims made in the Department’s or ABSA’s responses. This report
was updated to reflect the subsequently provided information and the results
of our further procedures where appropriate.

Throughout this engagement, our procedures were performed solely to

assist the Department in performing compliance activities over aspects of
the Energy Efficient Homes Package. This report is not to be used for any
other purpose and is solely for the information of the Department.

7
 3. Compliance with key elements of the Protocol for Assessor Accrediting Organisations

The following table lists the Protocol requirements and identifies the procedures that ABSA was performing at the time of the fieldwork in February 2010.
We note that there are several instances where ABSA’s application to be an approved AAO clarified or expanded on the Protocol and these areas have
been described in the first column of the table below, in red text. Since receiving version 1.0 of this report, the Department has received advice from its
in-house legal counsel on whether the accepted application implicitly amended ABSA’s compliance obligations. The advice indicated that the
Department’s acceptance letter to ABSA acknowledges that the proposal is consistent with the published Protocol. While indicating a probability that the
Protocol is likely to take precedence over the application in the event of inconsistency, the advice goes on to state that there is no indication of how
inconsistencies between the Protocol and ABSA’s proposal should be resolved.

The table below also identifies an inherent risk rating to the Department in the event that the requirements were not met, and indicates if ABSA is
presently meeting the Protocol requirements.

Protocols for Assessor Accrediting Inherent Is ABSA Responses / Procedures performed by ABSA
Organisations Risk meeting?

4.1.1 Recognition of prior accreditation

Assessors accredited under the Nationwide House
Energy Rating Scheme and holding a Statement of
Attainment in the qualification Building Thermal
Performance Assessment prior to the
commencement of this Protocol, under systems
approved by the Australian Government, may be
considered to have met competency 4.1c.
4.2 Statement of Attainment in Professional Household Sustainability Assessment
The course in ‘Professional Household Sustainability
Assessment’ has been developed for the purposes
of this section. Other courses may be developed
and approved by the National Administrator as being
appropriate for preparing persons to undertake
Household Sustainability Assessments for the
Scheme.
ABSA requires that all applicants have completed the approved Professional Household
Sustainability Assessment four day course (the only approved course which includes all
the competency areas stipulated in section 4.1).
Low Yes
The Professional Household Sustainability Assessment course was developed for the
Green Loan program by ABSA under contract from the Department. The contract
required that training course materials be developed for instructors and HSA’s, that the
course should cover the competency areas specified in the Protocol and the course was
developed as a non-accredited course. Discussions between ABSA and the
Department in July 2008 and October 2008 to develop a National Qualification for HSA’s
High Yes
under the AQF (including seeking accreditation for the training course) did not progress
to contract.

In February 2010 the Department acknowledged the content of an eight day course in
Victoria, however the course does not currently meet the HSAS requirements and a six
hour bridging course would be required. This bridging course has yet to be developed.

8
 Protocols for Assessor Accrediting Inherent Is ABSA Responses / Procedures performed by ABSA
Organisations Risk meeting?

A person who has successfully achieved a Course attendees can only receive Statements of Attainment after successfully
Statement of Attainment in Professional Household demonstrating that required competencies have been attained after attendance at a
Sustainability Assessment in accordance with the competency-based training course that has been accredited under the AQF, or through
Australian Qualifications Framework is considered to Medium Yes recognition of prior learning against the required competencies.
satisfy the competencies required in 4.1
. As a result Training organisations can only issue a certificate of attendance/completion.

4.2.1 Recognition of prior learning

RTO's delivering the Professional Household ABSA have not published a statement of RPL policy and practice for the HSAS, as they
Sustainability Assessment course may award the believe it is not possible to recognise prior learning for an unaccredited short course that is
qualification based on recognised prior learning (RPL) not competency based. ABSA require all assessors to complete the Professional Household
in accordance with the Australian Qualifications Sustainability Assessment course. No RPL is currently offered for this course.
Framework.
The Department indicated that the Victorian Home Sustainability course could be recognised
Assessor Accrediting Organisations must publish a but this would still require a six hour bridging module in order to cover all the required
statement of their RPL policy and practice, and are competencies under the HSAS. Such a bridging module has not yet been prepared or
required to recognise the right of Registered Training approved.
Organisations (RTO’s). to award qualifications based
on recognised prior learning. The National
Administrator can require changes or revoke the
accrediting organisation’s status if its RPL policy or
practices are deemed unsatisfactory.
High No
Inconsistencies between ABSA’s accepted
application and the Protocol:
ABSA's application to become an AAO stated that the
NatHERS RPL policy would be amended for the HSAS.

9
Protocols for Assessor Accrediting
Organisations
Assessor Accrediting Organisations must publish a
statement of their current Trainer Qualification and
Experience policy for RTO’s offering courses in
Professional Household Sustainability Assessment,
setting out minimum standards. The National
Administrator can require changes or revoke the
Accrediting Organisation’s status if its Trainer
Qualification and Experience policy or practices are
deemed unsatisfactory.
Inconsistencies between ABSA’s accepted
application and the Protocol:
ABSA's application to become an AAO stated that
current NatHERS policy would be adapted to suit the
HSAS.
5. Assessor accreditation
Following the attainment of the required qualification or
equivalent, Assessors may seek accreditation from an
Accrediting Organisation.
5.1 Basis of accreditation
Accreditation must be based on:
a. confirmation of the required minimum level of
qualification and experience; and
Medium
Inherent Is ABSA Responses / Procedures performed by ABSA
Risk meeting?
ABSA have a policy on trainer qualification and experience which relates to trainers engaged
directly by ABSA to deliver accredited courses on their behalf. For delivery of other
accredited training, all RTO’s are required to have their own organisational policies which
include the delivery of training.
Prior to the commencement of the Green Loans Program, 1,000 individuals had been trained
by ABSA and other organisations selected by the Department as part of pilot testing of the
training course, at the request of the Department, and prior to ABSA being appointed an
High No AAO. Shortly after appointment as an AAO, ABSA ceased delivering training to avoid a
conflict of interest and as such ABSA did not believe that it was necessary to publish a
Trainer Qualification and Experience Policy for HSAS. As such there is no published
guidance on trainer experience and qualifications apart from the requirements of the
Australian Qualification Framework (AQF), applicable to RTO’s only.
Note that prior to September 2009, any organisation with access to the materials could
deliver a course. However, post September ABSA only accepted certificates issued by
RTO’s.
For information only. Applicable to Assessors, not the AAO.
The Protocol states that ‘a person who has successfully achieved a Statement of attainment
in Professional Household Sustainability Assessment in accordance with the Australian
Qualification Framework is considered to satisfy the competencies required in 4.1’.
However the four-day course is content-based (rather than competency based) and
training organisations are unable to issue a “Statement of Attainment”. In the absence
No of a Statement of Attainment to confirm competence in each of the Protocol-required
areas, ABSA believes that there is no practical means of meeting their obligation to
confirm that an applicant has achieved a minimum level of competence in all of the
required areas.
10
Protocols for Assessor Accrediting Inherent Is ABSA Responses / Procedures performed by ABSA
Organisations Risk meeting?

At the time of the fieldwork in February 2010 ABSA required the following information:
 Completed application form with payment
 Professional Household Sustainability Assessment course certificate of completion
signed by a representative on the Statutory Declaration Signatory List.
 Copy of National Criminal History check sighted and signed by a representative on
the Statutory Declaration Signatory List.
 Signature on the registration form to indicate agreement to abide by the Code of
Professional Practice and its terms
 Two recent passport sized photographs
 Proof of Public Liability and Professional Indemnity insurance (Certificate of
currency) meeting minimum requirements of $10 million Public Liability Insurance,
and $2 million Professional Indemnity Insurance

During the site visit a sample of applications was reviewed to ensure that the appropriate
documentation had been provided and that details had been correctly entered into ABSA’s
database system, IMIS. Of a sample of ten applications reviewed:
 100% of applications had all necessary documentation on file
 80% of applications had all details available in IMIS
 10% applications had missing information in IMIS
 10% had no corresponding information in IMIS

ABSA is reliant on the training organisations to enforce pre-existing skill requirements

described in section 4.1, and delivery of all course materials with care and skill. As the
course is not accredited, training organisations cannot reliably assess whether an applicant
holds competency in these areas. The Department may find benefit in a review of training
organisation course enrolment requirements and in the robustness of course delivery to gain
comfort over this risk.
The review team performed a walkthrough of ABSA’s accreditation process as described
below.

Step 1: Application data entered into IMIS

Application data is keyed into an aggregated spreadsheet. This was previously performed
by ABSA staff, however due to the volume of applications ABSA have recently outsourced
data entry to an external company. The aggregated application spreadsheet is provided to
ABSA’s IT Manager who uploads it into the IMIS database.

11
Protocols for Assessor Accrediting Inherent Is ABSA Responses / Procedures performed by ABSA
Organisations Risk meeting?

Step 2: Application data checked

ABSA operators visually check all documentation provided with the application for
completeness and adherence to requirements. At this stage the information is not checked
back to what has been entered into IMIS.
Risk: Procedures are not documented, and decision criteria have not been
developed.

Step 3: Data match

ABSA operators perform a visual check that the information in the application matches the
information in IMIS. Changes are made to IMIS as necessary.
Risk: Not all necessary data fields are mandatory items in IMIS. During our testing
we noted incomplete records in the database.

Step 4: Payment
If the application is complete with no exceptions, ABSA process payment by either credit
card or cheque. After payment has been made a receipt is emailed to assessors. Member
credit card details are not recorded in IMIS.

Step 5: Assign HO Number to applicant

HO numbers are issued and assigned to the applicant record in IMIS. Note that HO
numbers are assigned in advance of cheque payments being cleared by the bank.

Step 6: Scan ID photo, print ABSA membership card and post to member.

12
Protocols for Assessor Accrediting Inherent Is ABSA Responses / Procedures performed by ABSA
Organisations Risk
b. agreement to:
i. adherence to the Assessor Code of Professional
High
Practice;
ii. an ongoing quality assurance system that includes
monitoring of Household Sustainability Assessment
services, Assessor training and support; and
Inconsistencies between ABSA’s accepted
Medium
application and the Protocol:
ABSA's application to become an AAO stated that it is
the Department’s responsibility to engage a scheme
auditor to undertake audits of assessor quality.
iii. recognising the right of the National Administrator to
arrange auditing of the quality of services under this
Scheme. Low
5.2 Confirmation of qualification
Assessor Accrediting Organisations are required to
confirm that the applicant is suitably qualified and
appropriately experienced to conduct Household
Sustainability Assessments (see Section 4 for
description of minimum requirements). Assessor
Accrediting Organisations may require reasonable
educational or experience requirements in addition
those detailed in Section 4.
Medium
meeting?
Yes The application process requires the applicant to indicate this by signing the form.
ABSA have not implemented the requirements of the Quality Assurance system described in
the Protocol. Their application to be an approved AAO indicates that the Department is
responsible for engaging a scheme auditor who will undertake audits of assessor quality.
No There are no standards to guide monitoring of assessor training. This is one example where
the Department and ABSA do not appear to share a common understanding of the Protocol
requirements.
ABSA recognise this right and released a positive press release on the day of this review.
Yes
Given the nature of the approved training course ABSA do not have access to information to
enable them to confirm the qualifications of the applicant. The training course should be
accredited in order for this requirement to be realistically achievable.
ABSA do not require any additional proof of prior experience. Some RTO’s may require
prerequisites before the course can be completed, however ABSA do not have any
involvement with the training requirements. Refer also to 5.1 above.
No
ABSA provided a list of 52 training organisations that have delivered the course since
program inception. Initially ABSA did not require that the course be delivered only by an RTO
or its partners.
In September 2009 ABSA sought clarification from the Department as to who was suitable to
deliver the course, and received advice that this was for ABSA to decide. ABSA
subsequently determined that it would only accept certificates from RTO’s and their
approved partners for the HSA course.
13
Protocols for Assessor Accrediting
Organisations
5.3 Assessor Code of Professional Practice
Assessors must act with due diligence and
professionalism in carrying out Household Sustainability
Assessments. The National Administrator will publish
an Assessor Code of Professional Practice and
Assessor Accrediting Organisations must make
adherence to this code a requirement for continuing
accreditation.
The Assessor Code of Professional Practice outlines:
a. the level of diligence and professionalism required by
Assessors, including the accuracy of Household
Sustainability Assessments and the level of
documentation to be maintained;
b. requirements to ensure that Assessors maintain the
competencies in 4.1;
c. the level and type of insurance to be maintained by
Assessors (refer 6.2.1); and
d. a process for dealing with complaints made to the
Assessor Accrediting Organisation about Assessors.
Inherent Is ABSA Responses / Procedures performed by ABSA
Risk meeting?
A search on the Department of Education, Employment and Workplace Relations website
identified that 7 of the training organisations are RTO’s (although ABSA also recognises
partnering in training delivery under the AQF, where organisations with technical expertise
can deliver under the auspices of an RTO, who specialise in the training and quality
aspects).
Our testing of accreditation documentation submitted by applicants also noted that courses
do not always run for four days. ABSA have indicated that one training provider, when
queried by ABSA, indicated that the training course had been tailored by the provider to
reflect the skillset of the training group such that some of the course material was not
covered in the same depth.
ABSA require all applicants to complete an application form which requires a box to be
completed which declares that the applicant has acknowledged that they accept the Code of
Professional Practice.
High Yes
Information only – not a compliance requirement for the AAO.
All complaints are registered through the Department’s complaint system. Any complaint
ABSA receives is fed back to the Department, however there is no formal process.
14
Protocols for Assessor Accrediting Inherent Is ABSA Responses / Procedures performed by ABSA
Organisations Risk meeting?

5.4 Insurance
Assessor Accrediting Organisations must require that
Assessors maintain suitable insurance commensurate
with the volume and scope of the work that they
undertake.
Inconsistencies between ABSA’s accepted
application and the Protocol:
Minimum expected insurance cover for an AAO is
specified in the Protocol regarding type but not amount.
ABSA’s accepted application specifies $5m
Professional Indemnity Insurance; and $5m Public
Liability Insurance.
5.5 Fit and proper person
Assessor Accrediting Organisations must ensure that
applicants are fit and proper persons to enter homes
and conduct inspections of private property. Sufficient
evidence shall include, but is not limited to, conducting
a national police check. Assessor Accrediting
Organisations may seek character references or other
information to determine whether the applicant is a fit
and proper person.
ABSA require assessors to hold $10 million Public Liability Insurance, and $2 million
Professional Indemnity Insurance.
ABSA only accept individual applications and as such only require $2 million Professional
Indemnity Insurance. The Department should note that their recommended limit for
companies is $5 million Professional Indemnity Insurance. The Department should consider
Low Yes
whether there is another check of insurance that can be completed when they enter into
contracts with companies.
ABSA require all applications to contain a police check. Where issues are identified in the
police check, the application is reviewed by an independent panel. Formal business rules
have not been developed to help determine when an issue would prevent the application
from being accepted (e.g. significant time passed, minor offence etc). Generally if the offence
High Yes was committed more than 10 years ago, it is deemed to be insignificant, however it would
depend on the severity of the offence.
No other character references are required.

5.6 Fees
Assessor Accrediting Organisations may charge
reasonable fees including:
a. Application Fee – a charge associated with
conducting checks to determine the fitness of
candidates and other application administration Low Yes
processes; and
b. Registration Fee – an annual charge associated with ABSA charge an annual registration fee of $660 for each of its members. In the initial pilot,
the provision of quality assurance and other services to members were charged a lesser sum as the assessment tool was not yet developed.
Assessors.

15
Protocols for Assessor Accrediting Inherent Is ABSA Responses / Procedures performed by ABSA
Organisations Risk meeting?

The Registration Fee should be commensurate of the Fees are published.

volume of assessment services provided by the
Assessor. Assessor Accrediting Organisations are
required to publish the list of fees.
5.7 Notice of accreditation
Upon satisfying the accreditation criteria in 5.1, 5.2, 5.3, ABSA issue HO numbers to assessors after they have checked each application and
5.4 and 5.5 and the payment of applicable fees, the ensured that all required information has been provided and that payment has been
Assessor Accrediting Organisation must notify the received. There is a small risk that cheque payments will bounce as ABSA do not wait for the
Assessor in writing of their accreditation, specifying: cheque to clear before issuing a HO number.
Low Yes
a. the Assessor’s unique accreditation number; and

b. any limitations to their accreditation including any

period of probation.

5.8 Register of accredited assessors

Assessor Accrediting Organisations are required to ABSA provide the Department with a list of new members daily. The information provided to
establish and maintain a register of accredited the Department includes each assessor’s unique HO number.
Assessors. Assessor Accrediting Organisations must
keep records of current and past members to ensure ABSA records all assessor information in IMIS, a membership software program which has
indemnity cover is maintained, and to deal with Low Yes been customised for ABSA’s requirements.
customer complaints and claims. Such records must
be maintained according to applicable privacy laws.

6. Quality assurance of assessor services

An Assessor Accrediting Organisation must have a No HSA specific quality assurance systems were identified at ABSA beyond the Assessor
quality assurance system in place for ensuring support mechanisms described at 6.2 below.
Assessors conduct Household Sustainability
Assessments in a satisfactory manner.

16
Protocols for Assessor Accrediting
Organisations
6.1 General requirements
The quality assurance system must be consistent with
this Protocol and cover:
a. use of the Household Sustainability Assessment
Procedures;
b. an Assessor Code of Professional Practice;
c. ongoing technical support; and
d. ongoing professional development opportunities to
maintain competencies;
Details of the quality assurance system must be lodged
with the National Administrator as part of the application
to become an Assessor Accrediting Organisation, and
maintained for currency.
Inconsistencies between ABSA’s accepted
application and the Protocol:
ABSA noted for Section 6 of the Protocol that it will
need to have access to the procedures and results of
audits of assessments. This could occur through either
the provision of physical copies or specific reporting
and collaboration with the appointed auditor.
ABSA planned to use information from the scheme
auditor to identify errors assessors were making. This
information could assist in identifying areas where
training needs to be improved and in developing
information packages for assessors to improve their
skills.
ABSA proposed to set up a reference group with
existing sustainability services and the scheme auditor
to meet the quality assurance requirements of Section
6.
Inherent Is ABSA Responses / Procedures performed by ABSA
Risk meeting?
At the time of the fieldwork in February 2010, ABSA noted that a scheme auditor had not
been appointed by the Department. ABSA is of the opinion that their ability to perform quality
assurance is questionable without access to the results of audit activity which reduced
ABSA’s ability to satisfy requirements A and B of section 6.1 and section 6.4 Quality
Assurance over assessments. The Department believe that this should not affect ABSA’s
ability to meet their obligations under the Protocol.
In August 2010 the Department provided documentation confirming that AECOM Australia
Pty Ltd was engaged in April 2010 to conduct an audit program of assessor
organisations and individual assessors, as well as Green Loan recipients. The target for
total number of audits to be completed is 12,600 with the audit strategy consisting of the
following components:
 a minimum of 9,000 Desktop Assessor Audits – comprising a desktop review of
available data, householder telephone survey and an audit report
 site-based Assessor Audits of 20 percent of all Desktop Assessor Audits –
conducted where further information/evidence is considered to be necessary.
 a minimum of 450 Green Loans Desktop Audits – a desktop review of data and a
High No householder phone call to confirm details and request documentation.
 site based Loan Audits of 20% of all Desktop Green Loan Audits – conducted
where further information/evidence is considered to be necessary.
 60 site-based Audits of Companies – site-based audits of companies with teams
of assessors undertaking HSA's.
The Department has advised that as of 13 August 2010 1,638 of the 12,600 target audits
are underway or complete.
The results of these audits have not been provided to ABSA.
Requirement B has been met by the Department publishing the Code and requirement C
(also met) is addressed at 6.2 below.
.
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Protocols for Assessor Accrediting
Organisations
6.2 Assessor support
Assessor Accrediting Organisations must provide the
Assessors that they have accredited with ongoing
technical and professional support, including advice in
relation to the competencies in 4.1. (Note: This service
may not be expected to extend to advice on the
operation of software where it would reasonably be
expected to be provided by the software developers
and/or distributors.)
Assessors must be able to access support services
from the Assessor Accrediting Organisation via no less
than e-mail and telephone. Upon receipt of a request
for support from an Assessor, Assessor Accrediting
Organisations must provide advice within three working
days.
Inherent Is ABSA Responses / Procedures performed by ABSA
Risk meeting?
Assessor technical and professional support includes a website http://www.hsas.net.au/
which contains various communications and sources that can be accessed by assessors.
The website includes a link
(www.environment.gov.au/greenloans/assessors/accreditation.html) to the Department's
accreditation process and competency requirements.
Low Yes
The website includes details of key contact points, email addresses, IT support details, and
calculator assistance, and includes pages for frequently asked questions, a factsheet,
insurance requirements and updates on the booking system.
Refer above to website details.
Technical support for use of the calculator is available to the assessors, where they can have
their questions answered via email, over the phone or via the website forums.
The forums provide a platform for Certified Home Sustainability Assessors to:
- communicate with fellow assessors
- ask technical questions
- post responses
- learn about activities in other states and postcodes.
The website has a Green Loans Technical Help page which includes support and information
Low Yes on:
- recommendations when using the Home Sustainability Tool, offline data-import tool,
background info on tool, reporting problems, future work, entering assessment information
and thermal performance houses.
The website also lists helpful contacts for assessors including phone and email contact
details.
ABSA do not currently have the capability to track response times to support services as
requests for assistance. Queries are handled as part of a workflow (first in first out).
18
Protocols for Assessor Accrediting Inherent Is ABSA Responses / Procedures performed by ABSA
Organisations Risk
6.3 Continuing professional development (CPD)
Assessor Accrediting Organisations must offer
professional development activities to Assessors that Low
they have accredited. This should include:
a. the distribution of regular electronic updates at
appropriate intervals; and
Medium
b. co-ordination of a professional development program
for Assessors. (Note: This may include workshops,
seminars and e-learning opportunities on topics of
High
interest and/or advanced training in specific areas of
relevance to Assessors.)
Professional development opportunities must be
provided no less than four times per calendar year.
Formal training must be provided in accordance with
the Australian Qualifications Framework. The National High
Administrator retains the right to require additional
professional development at its cost.
Assessor Accrediting Organisations must include in
their annual report to the National Administrator, a
statement of their CPD policy. The National
Administrator may withdraw recognition of an Assessor
Accrediting Organisation whose CPD policy and
practice is deemed unsatisfactory.
Medium
meeting?
For re-accreditation ABSA requires assessors to complete CPD activities to renew their
N/A membership each year. This has not yet occurred in relation to the HSA scheme whose first
anniversary is 1 July 2010.
At the time of the fieldwork in February 2010 no evidence of this was provided. A working
group was expected to be set-up working in collaboration with the scheme auditor and
No existing providers. The group was to publish bulletins and information on instances of poor
practices, investigation of assessors and remedial actions being taken. This is yet to occur.
At the time of the fieldwork in February 2010, ABSA had run three workshops (April 2009,
November 2009 and January 2010) to meet their CPD requirements under the Protocol.
Yes
At the time of the fieldwork in February 2010 ABSA had noted that the University of
Tasmania has a service agreement with the Department to design the CPD modules. ABSA
was informed that the initial plan was for the suite of CPD modules to be available between
No July 2009 and October 2009. ABSA noted that to date that these modules have not been
made available for Assessors to complete. In the light of other findings relating to assessor
competency risk the completion of these units and/or another means of verifying competence
is important.
At the time of the fieldwork in February 2010 an annual report had not been completed.
The review team subsequently noted that this requirement was met in April 2010. The
Annual Report includes commentary around ABSA’s CPD policy that is consistent with the
content of this report.
Yes
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Protocols for Assessor Accrediting
Organisations
6.4 Quality Assurance processes for Household Sustainability Assessments
Assessor Accrediting Organisations must recognise
government required and/or managed auditing systems,
but are responsible for quality assurance support for its
members to ensure:
a. consistency and accuracy of assessment services;
b. that Assessors are complying with the Assessor
Code of Professional Practice; and
c. that Assessors are conducting Household
Sustainability Assessments in line with the Household
Sustainability Assessment Procedures.
High
Inconsistencies between ABSA’s accepted
application and the Protocol
Refer to section 6.1 above.
Quality assurance is to be carried out by persons with a
high degree of competency and experience. The person
may be a fellow Assessor provided they do not have a
conflict of interest with the Assessor for which they are
assuring the quality of assessment services.
A quality assurance report must be included with the
annual report to the National Administrator and include
details of actions taken and a risk analysis of the
Assessor Accrediting Organisation’s quality assurance
system. The National Administrator may withdraw
recognition of an Assessor Accrediting Organisation
whose quality assurance policy, practice, reports or risk
Medium
analysis are deemed unsatisfactory. The National
Administrator, on behalf of the Australian Government,
will retain the right to revoke the status of an Assessor
Accrediting Organisation if disciplinary actions are
deemed by the Australian Government to be insufficient.
Inherent Is ABSA Responses / Procedures performed by ABSA
Risk meeting?
ABSA do not offer common QA system elements such as communications designed to
improve assessment quality, independent / peer review mechanisms, or other such activities
to help assure the quality of assessor’s work.
At the time of the fieldwork in February 2010, ABSA noted that a Department appointed
scheme auditor has not yet been introduced, which has reduced their ability to satisfy
requirements A and B of section 6.1 and section 6.4 ‘Quality Assurance over assessments’.
Reference was made to Section 6.5 ‘Auditing of Assessors and Household Sustainability
Assessments in accordance with the Scheme and any applicable Australian law is the
domain of governments and is not the responsibility of Assessor Accrediting Organisations.’
No The ABSA CEO noted that this was communicated to the Department via email in relation to
reviewing the Protocol on 9th November 2009. ABSA also noted that their ability to perform
quality assurance is questionable without a 'feedback loop' particularly in regards to
consistency and accuracy.
At the time of the fieldwork in February 2010 an annual report had not been completed and
the Review team highlighted this requirement to the ABSA CEO at the time of our fieldwork.
The review team subsequently noted that this requirement was met in April 2010. The
Annual Report includes details of ABSA’s quality assurance system consistent with the
content of this report.
Yes
20
Protocols for Assessor Accrediting Inherent Is ABSA Responses / Procedures performed by ABSA
Organisations Risk meeting?

6.5 Auditing of Assessors Not a requirement on ABSA

6.6 Process for dealing with complaints
Assessor Accrediting Organisations must establish a ABSA have the following communication points for receiving complaints:
system for responding to complaints about Assessors. 1. Through the hsas@absa.net.au email account,
This includes a process for: 2. 1300 889 438 dedicated phone number
a. logging complaints; and
b. responding to complaints in a timely manner. It was also noted at the time of the review that ABSA's website included the Department's
current contact details including the dedicated enquiries phone line and various Green Loans
email addresses.

ABSA Management noted that the nature of the complaints received vary from complaints by
assessors about other assessors poaching jobs, assessors pushing requirements to obtain a
loan, to more general matters such as the calculator and IT issues. Management also noted
that ABSA have not received many complaints from householders.

The Operations Manager actions the complaints received, escalating any serious complaints
Low No to the CEO. ABSA’s response varies depending on the type of complaint, and generally
action will only occur where evidence supports a complaint. Anecdotal complaints that
cannot be verified are not actioned. The complaints management process is informal with no
formal logs or registers in place keeping track of complaints made, the nature of complaints,
the number of complaints and the assessor they relate to.

ABSA do not have access to the assessors bookings register or access to completed
assessment reports to investigate particular complaints. If required, the Operations Manager
notifies the Department, however there is not a specific channel that complaints are
forwarded to, rather it depends on the nature of the complaint. For example a complaint
made by an assessor about bookings would be passed onto the Booking Call Centre at the
Department. Alternately some complaints are passed onto the Green Loans team. It was
also noted that ABSA have not received any correspondence from the Department in relation
to complaints that were passed on to the Department. ABSA have not removed any
assessors from membership as a result of complaints made.

21