What appraisal standards must Kansas county appraisers follow when valuing property for property taxes, and are property owners considered intended users of that appraisal?

Plain-English summary

Kansas property taxes start with an appraisal, and this directive tells every county and district appraiser in the state which professional standards that appraisal has to meet. For the 2024 valuation year and every year after "until otherwise notified," appraisers must do all appraisal work in conformity with the 2024 Edition of USPAP -- the Uniform Standards of Professional Appraisal Practice, written by the Appraisal Standards Board of The Appraisal Foundation. K.S.A. 79-505(a)(1) requires it.

The directive maps specific USPAP Standards onto specific jobs. Standards 5 and 6 govern developing and reporting a mass appraisal -- the computer-model approach (Kansas uses the Orion CAMA system) that values most property in the state at once. Standards 1 and 2 govern a single property appraisal, which is what an appraiser must fall back on when a parcel "cannot be credibly appraised with a mass appraisal model." Standards 3 and 4 govern appraisal review.

The most consequential passage for ordinary property owners is about who the appraisal is for. The directive states that county commissioners serve as the client and the taxing districts are the intended users. Then, citing USPAP Advisory Opinion 36, it says plainly: "Taxpayers and property owners are not intended users of the appraisal prepared for ad valorem taxation in Kansas unless specifically stated as such in the appraiser’s Scope of Work document."

The directive also lists jurisdictional exceptions -- places where Kansas law overrides USPAP. The big one is agricultural land, which Kansas taxes on use value rather than market value.

What this means for you

Kansas property owners appealing a valuation

Two points from this directive matter in an appeal. First, the county or district appraiser has an affirmative duty to "analyze all relevant property appraisals provided by a property owner during the appeals process" -- so a private appraisal you submit is supposed to be analyzed, not ignored. Second, the directive says a comparison of descriptive data between the mass appraisal and a single-property appraisal report, together with an explanation of the findings, "does not constitute a Standard 3 review." A side-by-side data comparison is not the same thing as a formal appraisal review.

Be aware of the intended-user language above. It does not stop you from appealing -- Kansas gives you that right by statute -- but it does mean the appraisal was not prepared for you in USPAP terms.

Owners of agricultural land

Kansas requires agricultural land to be appraised at both market value and use value under K.S.A. 79-1476, and the use value estimate is what is actually used for taxation. The directive treats the prescribed use-value methods as a jurisdictional exception to USPAP, because they are a statutory requirement rather than an appraiser's market judgment.

Owners of taxable personal property

For subclasses that Kansas requires to be appraised at fair market value -- manufactured homes, oil and gas interests, well equipment, tax-roll motor vehicles with a 24M tag, non-business trailers, commercial and industrial machinery no longer producing income, and "other personal property not elsewhere classified" such as aircraft, golf carts, snowmobiles and watercraft -- the appraiser has two routes. The default is to follow the Division's published appraisal guides. Alternatively, under K.S.A. 79-1456(b) the appraiser "may deviate from the guides on an individual property," in which case a single-property appraisal must be developed under USPAP Standard 7 and reported under Standard 8.

Non-exempt commercial and industrial machinery and equipment (class 2, subclass 5) and certain motor vehicles are different: their value is set by a statutory mathematical formula in K.S.A. 79-5105a, and the director expressly invokes a jurisdictional exception to USPAP for them.

Appraisers and tax professionals

Note the documentation duty: "Supporting documentation must be developed and reported for all model component overrides and adjustments," and the mass-appraisal work file must "provide an understanding of individual property valuation results." The directive invokes USPAP Advisory Opinion 32, the PREAMBLE, and the ETHICS RULE to require that any communication of mass-appraisal results for a single property be meaningful and not misleading.

The four Kansas-specific scope-of-work assignment elements are the client/intended-user identification, the K.S.A. 79-503a fair-market-value definition, the January 1 effective date under K.S.A. 79-1455, and the minimum standardized property characteristics under K.S.A. 79-1477.

Common questions

Q: Which USPAP edition do Kansas county appraisers have to follow?
A: The 2024 Edition, "[f]or the 2024 valuation year, and all subsequent years until otherwise notified." Because the Division re-issues this directive as editions change (this one supersedes Directive #23-051), check the Division's directive list for a newer one before relying on the edition named here.

Q: Am I an "intended user" of my county's appraisal of my own property?
A: Under this directive, no -- not unless the appraiser's Scope of Work document specifically says so. The directive names county commissioners as the client and the taxing districts as the intended users, and cites USPAP Advisory Opinion 36 for the point that parties who receive a copy of an appraisal because of disclosure requirements do not thereby become intended users. This is a USPAP classification and does not by itself affect your statutory right to appeal a valuation.

Q: Does my county appraiser have to look at the private appraisal I paid for?
A: The directive says it is "the responsibility of the county and district appraiser to analyze all relevant property appraisals provided by a property owner during the appeals process."

Q: Why is my farmland valued differently from my neighbor's commercial lot?
A: Kansas appraises land devoted to agricultural use at use value, not market value, under K.S.A. 79-1476, and the directive identifies that statutory requirement as a jurisdictional exception to USPAP.

Q: Can I rely on this directive for my own tax situation?
A: Not as a ruling. It is internal guidance to county appraisers on how to do their appraisal work, not a determination about any one taxpayer's property. It tells you the standards your appraiser is supposed to meet.

Citations and references

Kansas statutes:

• K.S.A. 79-505(a) and 79-505(a)(1) (director's directive authority; USPAP conformity requirement)
• K.S.A. 79-503a (fair market value definition)
• K.S.A. 79-1455 (January 1 appraisal date)
• K.S.A. 79-1477 (minimum standardized property characteristics)
• K.S.A. 79-1476 (agricultural land: market value and use value)
• K.S.A. 79-1456, 79-1456(b); K.S.A. 79-1412a sixth; K.S.A. 79-1412(b) (PVD guides and deviation)
• K.S.A. 79-5105a (statutory formula for class 2 subclass 5 machinery and certain motor vehicles)
• K.S.A. 79-1468, 79-1801, 79-1803, 79-1806 (purpose of ad valorem taxation: financing taxing districts)
• K.S.A. 79-5a27, 12-5250, 12-1775, 79-1409, 79-1411a, 79-1411b (appraisals become assessments used by taxing districts)

Professional standards referenced:

• Uniform Standards of Professional Appraisal Practice (USPAP), 2024 Edition, Standards 1-8, PREAMBLE, ETHICS RULE, and JURISDICTIONAL EXCEPTION RULE
• USPAP Advisory Opinion 32 (mass appraisal results for an individual property)
• USPAP Advisory Opinion 36 (intended users)
• USPAP FAQ 106 (disclosure of jurisdictional exceptions)

Related directive: This directive supersedes Directive #23-051.

Source

• Landing page: Kansas Property Tax Directives
• Original PDF: PVD Directive 24-051

Original ruling text

Division of Property Valuation
300 SW 29th Street Phone: 785-296-2365
PO Box 3506 Fax: 785-296-2320
Topeka KS 66601-3506 www.ksrevenue.gov
Mark Burghart, Secretary Laura Kelly, Governor

                                   DIRECTIVE #24-051

TO: County Appraisers
SUBJECT: Uniform Standards of Professional Appraisal Practice
This Directive Supersedes Directive #23-051

This directive is adopted pursuant to the provisions of K.S.A. 79-505(a) and shall take effect and
be in force from and after the Director’s approval date.

For the 2024 valuation year, and all subsequent years until otherwise notified, the county or district
appraiser shall perform all appraisal functions in conformity with Uniform Standards of
Professional Appraisal Practice (USPAP), 2024 Edition, the Appraisal Standards Board of The
Appraisal Foundation, as required by K.S.A. 79-505(a)(1) and as further defined herein.

USPAP Standard 5 shall be followed in developing a mass appraisal for ad valorem taxation
purposes. USPAP Standard 6 shall be followed in reporting a mass appraisal for ad valorem
taxation purposes. Standards 5 and 6 may also be adhered to in revaluing individual properties that
initially have been appraised through mass appraisal methods and techniques, but whose value
estimates are reexamined and reconsidered as a result of the hearing and appeals processes.
Supporting documentation must be developed and reported for all model component overrides and
adjustments.

USPAP Standard 1 shall be followed in developing a “single real property appraisal” and USPAP
Standard 2 shall be followed in reporting the results of a single real property appraisal. Most
properties in Kansas can be valued though the Orion computer assisted mass appraisal (CAMA)
system; however, some parcels in Kansas do not lend themselves to mass appraisal methods and
techniques. If a parcel cannot be credibly appraised with a mass appraisal model (see Standards
Rule 5), USPAP Standards 1 and 2 would apply.

USPAP Standards 3 and 4 shall be followed in developing and reporting an appraisal review. An
appraisal review is the process of developing an opinion about the quality of an appraiser’s work
that was completed as part of an appraisal or appraisal review assignment. It is the responsibility
of the county and district appraiser to analyze all relevant property appraisals provided by a
property owner during the appeals process. A comparison of descriptive data, including subject
property characteristics and comparable property information between the mass appraisal and

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single property appraisal report, and explanation of the findings, does not constitute a Standard 3
review.

A county or district appraiser will be required to report the assignment results for a single property
that was appraised as part of a mass appraisal assignment. USPAP Advisory Opinion 32 advises
there may be many mass appraisal models used to value a universe of properties, and while a
property record may describe the valuation of a specific property, to understand the individual
property result valued through mass appraisal requires an examination of all information required
in Standards Rule 6-2. The second sentence of the PREAMBLE states: It is essential that
appraisers develop and communicate their analyses, opinions, and conclusions to intended users
of their services in a manner that is meaningful and not misleading. Additionally, the ETHICS
RULE states an appraiser must not communicate assignment results with the intent to mislead or
defraud, and that an appraiser must not use or communicate a report that is known by the appraiser
to be misleading or fraudulent. If a Kansas county or district appraiser communicates mass
appraisal results for a single property, USPAP requires the communication to be meaningful and
must not be misleading.

The work file for the mass appraisal assignment shall contain the information and analyses to
support the valuation models developed for all properties in the jurisdiction and provide an
understanding of individual property valuation results. Substantial documentation and justification
shall be provided for model adjustments and overrides made to individual parcels.

Appraisals developed for ad valorem taxation in Kansas must comply with Kansas law, and
regulations promulgated by the director of property valuation. Most of these requirements do not
preclude compliance with any part of USPAP, but some place specific requirements on the scope
of work. The director of property valuation has identified the following assignment elements that
are necessary in Kansas to properly identify the ad valorem appraisal problem and develop credible
assignment results:

• The purpose of ad valorem taxation is to finance the taxing districts in Kansas (see K.S.A.
79-1468, K.S.A. 79-1801, K.S.A. 79-1803, and K.S.A. 79-1806). County or district
appraisers are required to develop the appraisal estimates that become the assessments used
by the taxing districts (see K.S.A. 79-5a27, K.S.A. 12-5250, K.S.A. 12-1775, K.S.A. 79-
1409, K.S.A. 79-1411a and K.S.A. 79-1411b). Therefore, county commissioners serve as
the client and the taxing districts are the intended users of the appraisal. This scope of work
compliance requirement applies to Standards Rule 1-2(a), 2-2(a)(i), 3-2(a), 4-2(a), 5-2(a)
or 6-2(a), as applicable. The definition of intended user has a specific meaning in USPAP.
Parties who receive a copy of the appraisal as a consequence of disclosure requirements do
not become intended users of the report. (USPAP Advisory Opinion 36). Taxpayers and
property owners are not intended users of the appraisal prepared for ad valorem taxation in
Kansas unless specifically stated as such in the appraiser’s Scope of Work document.

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• The definition of fair market value for ad valorem appraisals in Kansas is found in K.S.A
79-503a. This scope of work compliance requirement applies to Standards Rule, 1-2(c), 2-
2(b)(v), 3-2(c), 5-2(c) or 6-2(e), as applicable.

• The effective appraisal date for all property in Kansas is January 1, as required by K.S.A.
79-1455. This scope of work compliance requirement applies to Standards Rule 1-2(d), 2-
2(vi), 3-2(d)(ii), 4-2(d), 5-2(d), 6-2(d), as applicable.

• A minimum standardized set of physical property characteristics has been determined
relevant and necessary for the effective and efficient mass appraisal of real property in
Kansas, as required by K.S.A. 79-1477. This scope of work compliance requirement
applies to Standards Rule 5-2(e) and 6-2(i).

Kansas laws and regulations which prevent compliance with a part of USPAP may require the
appraiser to invoke The USPAP JURISDICTIONAL EXCEPTION RULE. Only the part of
USPAP negated by law or regulation becomes void. Law includes constitutions, legislative and
court-mandated law, and administrative rules and ordinances. Regulations include rules or orders
having legal force, issued by an administrative agency, such as appraisal directives issued by the
director. Instructions from a client do not establish a jurisdictional exception. Following are
jurisdictional exceptions for ad valorem appraisal assignments which must be disclosed if invoked
by the appraiser (USPAP FAQ 106):

• Land devoted to agricultural use in Kansas shall be appraised at both market value and use
value as required by K.S.A 79-1476. The market value appraisal of agricultural land shall
follow USPAP rules. However, the prescribed methods used to develop use values are a
statutory requirement. Use value appraisal estimates shall be utilized for ad valorem
taxation of agricultural land. The requirement to value agricultural land by use value for
assessment purposes is a jurisdictional exception.

• Kansas statutes require the following subclasses of tangible personal property to be
appraised at fair market value: manufactured homes, oil and gas interest, material and
equipment used in operating oil and gas wells, tax roll motor vehicles (with a 24M tag),
trailers (non-business use), commercial and industrial machinery and equipment no longer
being used in the production of income, and other personal property not elsewhere
classified (such as aircraft, hot air balloons, golf carts, snowmobiles, watercraft and boat
trailers). The county or district appraiser may choose from one of two options to develop
and report the appraisal of such property:

   ➢ The appraisal methodologies developed and adopted by the Division of Property
     Valuation and published in appraisal guides shall be followed by the county appraiser.
     (see K.S.A. 79-1412a sixth, K.S.A. 79-1412(b), K.S.A. 79-1456.

   ➢ County or district appraisers may deviate from the guides on an individual property.
     Single property appraisals shall be developed by following USPAP Standard 7 and
     reported under requirements of USPAP Standard 8 (see K.S.A. 79-1456(b).

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• The valuation of non-exempt commercial and industrial machinery and equipment (class
2, subclass 5) and certain motor vehicles is prescribed by statute (K.S.A. 79-5105a and
amendments thereto). These valuation methods are based upon a mathematical formula and
the director of property valuation invokes a jurisdictional exception to USPAP.

Approved: November 27, 2023
David N. Harper
Director of Property Valuation