[FoCHAT] CHAT--Improved policies for the Road Home Program

Wed Nov 28 21:51:03 PST 2007

Good news!

  1. CHAT posts an old but important and frequently overlooked change policy document at our website http://chat.thinknola.com

  We only recently obtained this document.

  If you had a mistake in your prestorm value calculated by the Road Home and you are in appeal (not dispute resolution), according to the last provision of this CP document (CP49E) you are entitled to RH providing you with a full LA certified appraisal if you did not get your own. Just ask for it according to change policy 49E (see our website for definition of change policy). It is in the fourth CP file, on p. 15, at our website (or follow the link below to almost the end of the document, p. 15)

  http://thinknola.com/files/chat/CP_40-44_AssistCenters_47_SelfCertifInsur_49E_PSV&LA_CertAppraisals_1_14_07.pdf 

  Also, two changes long advocated by CHAT have been signed into policy for the Road Home Program

  Posted at our website
  2. New Change Policy    Field Review Appraisals for Applicants Who Provided Post Storm Appraisals not Accepted by RH; CP188G

  In effect since the second week of November.

If you are entitled to a field review appraisal of your LA certified appraisal according to this policy and are having trouble getting the proper help from ICF, first refer the ICF staff to CHAT's website and to CP 188G. If that does not work, please send an email to chatlra at yahoo.com describing in full your situation, if you would like us to forward this to LRA or OCD officials.   
  Description:
  This change proposal recommends the use of a Louisiana-licensed appraiser to perform a field review appraisal of homeowner-provided 1004 appraisals of pre-storm value. This change applies to all instances during the program (in processing, in resolution and appeals, etc) when a homeowner-supplied 1004 appraisal of pre-storm value conducted by a Louisiana licensed appraiser exceeds 120% of the Road Home program’s estimate of pre-storm value, such as a BPO, AVM, or “market study” (2055) appraisal. The 120% standard has been used by the program to track whether appraisals are outside of an industry standard norm for differences in appraised values. This also assumes that no other better estimate of value exists, such as a pre-storm appraisal or lender supplied appraisal. The existence of a pre-storm appraisal negates the need for a market study or other program analysis of value, and is assumed to be more accurate than any post-storm determinations of value including a
 homeowner-supplied 1004 appraisal.
  When the homeowner supplied 1004 appraisal is outside of the 120% threshold, the program shall automatically assign the case to a Review Appraiser, who shall conduct a Field Review Appraisal of the property. This review process shall be noted in the homeowner’s file, but a homeowner does not need to request it in order for this process to occur. The Field Review Appraisal shall determine whether the homeowner supplied appraisal is valid, or shall assign and justify an alternate value. In those instances where the reviewing appraiser cannot validate on or determine an accurate value, the review appraiser shall notify the Road Home Program which will then order a 1004 Appraisal to be performed by a different Louisiana licensed appraiser.
  Regardless of whether the post storm supplied homeowner appraisal of value is confirmed or changed by either a Field Review Appraisal or a 1004 appraisal, the value determined by this process will represent the pre-storm value used to calculate an applicant’s Road Home award. This process for a field review appraisal or 1004 appraisal as described above applies to applicants whose PSV (as opposed to estimated cost of damages) is used to determine the level of benefits.
  The methodology required to be followed is as follows:
  1) Review of existing documentation (documents provided by the Road Home and the homeowner-supplied 1004 appraisal) regarding Road Home pre-storm values for the damaged residence.
  2) For properties with pre-storm values above 120% of the program’s market study or another determination of value by the program, the Road Home shall order a Field Review Appraisal for an in-person inspection of the exterior of the applicant’s property and review the comparable properties used in the homeowner-supplied appraisal. If the field review appraiser affirms that the homeowner-supplied appraisal was accurately produced and adequately represents the property’s value in comparison to the program’s PSV estimate (including but not limited to the property’s correct square footage and adequate comparables for the neighborhood), it shall be accepted by the program.
  3) If the review appraiser using the Field Review protocol cannot affirm that the value contained in the homeowner-supplied appraisal, the review appraiser shall determine his or her own professional opinion regarding the property’s pre-storm value. To this end, the review appraiser must provide a well documented report that demonstrates the analysis and supports the reviewer’s conclusions.
  4) If the review appraiser cannot affirm the value of the homeowner-supplied appraisal and cannot determine an accurate pre-storm value with the information available, the review appraiser shall notify the Road Home program which will then order a 1004 Appraisal to be performed by a different Louisiana-licensed appraiser. The 1004 appraisal value will be used as the final pre-storm value by the Road Home. The review appraiser who recommends a 1004 appraisal shall not have his contractually agreed upon compensation reduced.
  5) The review appraiser shall complete a Road Home review appraisal checklist that documents the steps taken to make the decisions about value and ensures consistent methodology by all Final Review appraisers.
  Other considerations:
  Applicants whose benefits are based on PSV (as opposed to estimated cost of damage) and who submitted a post-storm appraisal of pre-storm value that exceeded 120% of the program’s estimate of value will have their file automatically submitted for a Field Review Appraisal. The following applies for these applicants: 
• The Field Review Appraisal process will represent the applicant’s pre-storm value, either by validating the homeowner-supplied appraisal, recommending an alternate value, or ordering a full 1004 appraisal. 
• The applicant cannot receive from Road Home nor provide to the Road Home any other estimate of value or appraisal, including another 1004 appraisal, during any stage of the process.
  With the homeowner’s submission of a post storm 1004 appraisal of pre-storm value, they are indicating that they believe that value to be an accurate and acceptable reflection of the property’s pre-storm value. For that reason, the program will automatically initiate the field review appraisal process when the 120% threshold is exceeded. Homeowners should be informed if they contact the program for a status of their file when they are in this field review appraisal process, in accordance with the Road Home Statement of Principles. However, written notification by the program to the homeowner is not required, nor is the homeowner required to request the field review appraisal in order for it to be conducted.
  Reason(s) for Change Proposal:
  To improve the current process for determining pre-storm value when a homeowner supplies a post storm 1004 appraisal of pre-storm value that exceeds the industry standard norm variations in appraised values. To establish additional checks and balances in the program. To address homeowner disagreements with pre-storm value (the most common issue transferred to dispute resolution and appeal).

  3. New, approved, but not yet instituted change policy

  Title of Proposed Change: Written documentation required at all critical stages of the Road Home process: CCB189A; goes into effect only on Jan. 1, 2008

  Description: 
Current procedure: The Road Home program, in an apparent effort to process applicants more quickly, has adopted the practice of providing information relating to homeowner status verbally at critical stages of the process in lieu of written documentation, a practice which has had a major impact on homeowners’ ability to make informed decisions regarding their grant awards. Moreover, this practice has been widely reported by homeowners to have adversely affected their ability to demonstrate that something was communicated verbally by Road Home staff relating to the status of their application as they have moved through the process in a number of ways, namely, that they are deprived of written documentation supporting the information they were provided verbally, in most instances over the phone.
  Proposed procedure: Written Documentation shall be furnished to homeowners regarding Road Home application status
  Written Documentation shall be the required method used to communicate Road Home application status to homeowners. Although verbal communications regarding application status are permissible, oral communications made in person or by telephone by Road Home advisors to homeowners shall be followed by written communication, either by U.S. mail, electronic mail, or facsimile within 5 business days reflecting the same information advised of verbally regarding critical stages of the application. Critical stages include the following:
  1) The exact amount of the grant award under options 1, 2 and 3, elevation amount and any Affordable Compensation Grant awarded as would have been reflected in the actual Benefit Option Selection Form;
2) Dispute Resolution status and outcomes which will serve to reconcile verbal inconsistencies and conflicting information reported to homeowners by Road Home advisors;
3) Current Status of the application accompanied by a easy to understand/non-technical explanation of missing information still requiring verification including but not limited to ownership and occupancy, title search, pre-storm value determination and Estimated Cost of Damages.
  Written Support Documentation relied on by the Road Home by which award calculations are based
  Upon request by the homeowner, the Road Home program shall provide homeowners with supporting documentation used to determine the following at all stages of the process:
  1) Pre-storm value (Broker’s price opinion or licensed appraisal report);
  2) Estimated Cost of Damages (component by component cost breakdown, square footage measurements, etc) including the percentage of damages assigned to an applicant’s home.
  Point by Point Dispute Resolution and Appeals processed explained in writing
  All Benefit Option Selection forms shall include instructions which provide a point by point explanation of the dispute resolution and appeals process explaining the applicant’s right to dispute any calculation reasonably believed to be unjustified forming the basis of the Road Home grant.
  Reason(s) for Change Proposal:
  To provide the status of Road Home applications in writing at critical stages in order to enhance homeowners’ ability to make informed decisions regarding their grant awards and to confirm in writing the information that may have initially been was communicated by Road Home staff relating to the status of a homeowners application as they move through the process.

  Best wishes,

  Melanie Ehrlich
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