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Lesson 7: The plan review process and report format

TDLR RAS Procedures · 14 practice questions

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Reading

Lessons 3 through 6 covered what a RAS checks. This lesson covers how a RAS actually conducts a plan review and what the resulting report has to contain, drawn from TDLR's own RAS Procedures document (effective December 3, 2018, still the version TDLR links on its RAS page). This is the paperwork side of the job. The Procedures set required content, format, and deadlines, and TDLR can audit a RAS's work, so a correct finding delivered in the wrong format, or late, is still a procedural problem.

Before the review starts

Plan review is tied to construction. Under Government Code Section 469.101, plans for a subject building with an estimated construction cost of at least $50,000 must be submitted for review, and under Rule 68.50 the design professional with overall responsibility submits them to a RAS not later than the 20th day after issuing them, not counting weekends and legal holidays. Before conducting the review, the RAS must have in hand the AB Project Registration Form (when the RAS registers the project), a Designated Agent Form signed by the owner if the owner has named one, a Proof of Submission Form signed by the design professional if one applies, and the construction documents to be used for construction. A RAS who starts reviewing drawings without these in the file is working outside the procedure before the technical review has even begun.

What the report must contain

The plan review report has to be typewritten and must include: a heading identifying it as a "Plan Review Report" or "Plan Revision Report," the RAS's name and license number, the report date, the TABS project number, the facility name, the project name and address, and a detailed listing of deficiencies, each one referencing the specific TAS reference number, its location in the building, and the possible violation. A completed Attachment "A" is also required. Attachment "A" is TDLR's prescribed transmittal letter, "Plan Review/Revision Completed." If the review finds no deficiencies at all, the procedures (Section 3.9.1) allow that transmittal letter to be used instead of a full deficiency report, but that shortcut only applies when there is genuinely nothing to report. Under RAS Bulletin 2023-05 (effective September 1, 2023, citing Rule 68.53(b)), TDLR also prescribes the results, action, and disclaimer paragraphs that transmittal letters carry, so use TDLR's current wording rather than writing your own.

Submission timeframes

The RAS must issue the report to the owner or designated agent within 30 days of the report's completion date, and must upload it to the TABS system, TDLR's online project tracking system, within 30 days of the report date as well. These two 30-day clocks run in parallel from essentially the same date, not one after the other, so a RAS working toward the deadline should be treating both delivery to the owner and the TABS upload as due at the same time, not sequential steps with 30 days each.

Why the deficiency listing has to be this specific

A deficiency entry that just says "restroom noncompliant" is not useful to an owner trying to fix it, and it is not what the procedure requires. Each deficiency has to name the TAS section the drawing fails, where in the building it occurs, and what the potential violation is. Lessons 3 through 6 gave you the actual technical vocabulary, the section numbers and dimensions, that a properly written deficiency entry draws on. "Section 604.5.1: side-wall grab bar shown at 36 inches, 6 inches short of the 42-inch minimum, men's restroom, first floor" is the kind of entry the procedure is asking for.

How this connects forward to the inspection lesson

A plan review happens before construction, checking the design. Lesson 8 covers the inspection process, which happens after construction is complete, checking what was actually built against the same TAS technical chapters. The two processes share the same underlying technical standard and much of the same report structure, but they happen at different points in a project's life and use different report attachments, which lesson 8 covers directly.

Plan review process sequence Four stages: gather the registration and construction document forms, conduct the technical review against TAS, write the typewritten report with Attachment A, then issue to the owner and upload to TABS, both within 30 days. Gather formsRegistration, agent, docs Technical reviewAgainst TAS chapters Write reportDeficiencies + Attachment A Issue + uploadOwner and TABS, 30 days No deficiencies found: a transmittal letter may substitute for the full report
The plan review sequence runs from gathering required forms through the technical review to a report issued and uploaded within 30 days.

Practice questions

1. What must a RAS have in hand before starting a plan review?

  1. The registration form if the RAS registers the project, applicable agent and submission forms, and the construction documents
  2. Nothing; a RAS may begin as soon as the owner verbally asks for a review of the drawings
  3. Only the construction documents, since the forms are collected after the review is finished
  4. A signed contract with the owner's attorney and a copy of the building permit

2. What heading must the plan review report carry?

  1. No specific heading is required as long as the RAS signs and dates the report
  2. "Compliance Certificate" issued under the Texas Accessibility Standards
  3. "Plan Review Report" or "Plan Revision Report"
  4. "Preliminary Findings Memo" followed by the RAS license number

3. What identifying information must the report include, beyond the deficiency list?

  1. The building owner's Social Security number and the contractor's license number
  2. RAS name and license number, report date, TABS number, and facility and project name and address
  3. Only the RAS's name and signature, along with a notarized statement from the building owner about the project
  4. Only the project address, the estimated construction cost, and the contractor name and telephone number

4. What must each deficiency entry in the report reference?

  1. Only a general description of the problem, with no code citation
  2. The contractor's bid amount and the estimated cost of the correction
  3. Only a photograph or marked-up sketch of the condition, with the owner's initials on it
  4. The TAS section, its location in the building, and the potential violation

5. Which attachment must accompany a plan review report?

  1. Attachment "D"
  2. Attachment "E"
  3. No attachment is required for plan review
  4. Attachment "A"

6. What shortcut does the procedure allow when a plan review finds no deficiencies at all?

  1. A transmittal letter may substitute for the full report
  2. The RAS may skip the technical review entirely on the next project
  3. The owner may waive the review fee
  4. No report of any kind is needed

7. Within how many days of report completion must the RAS issue the plan review report to the owner or designated agent?

  1. 90 days
  2. 7 days
  3. 15 days
  4. 30 days

8. Within how many days of the report date must the RAS upload the report to TABS?

  1. 30 days
  2. 60 days
  3. There is no upload deadline
  4. 10 days

9. Do the owner-delivery and TABS-upload deadlines run sequentially or in parallel?

  1. They are the same single deadline with no separate tracking
  2. In parallel, both measured from essentially the same date
  3. Sequentially, TABS upload only after the owner has responded
  4. The TABS upload deadline only starts after 60 days

10. What is wrong with a deficiency entry that just reads "restroom noncompliant"?

  1. It is too long, and the Procedures ask for a one-word summary of each finding
  2. It fails to cite the specific TAS section, location, and potential violation the procedure requires
  3. It should cite ADA Title III and DOJ regulations rather than TAS for any restroom deficiency
  4. Nothing; the Procedures prefer short general descriptions when the owner is a public entity

11. What is TABS, as used in RAS reporting?

  1. The vendor that develops and administers the RAS licensing exam for TDLR
  2. A private accreditation body for accessibility consultants and design firms
  3. A federal court system that hears appeals of TDLR variance decisions
  4. TDLR's online project tracking system where reports are uploaded

12. Does a plan review happen before or after construction?

  1. Plan review and inspection happen at the same time
  2. Plan review only happens for renovation projects
  3. Before construction, reviewing the design
  4. After construction, reviewing what was built

13. A RAS finds a side-wall grab bar shown at 36 inches on the drawings. What TAS section from lesson 4 does this deficiency reference?

  1. Section 404.2.3
  2. Section 304.3
  3. Section 604.5.1
  4. Section 208.2

14. Why does TDLR treat the report format itself as part of the regulated function, not just paperwork?

  1. Because TDLR only reviews reports at renewal time, when the license is up for renewal
  2. Because the format is optional and left to each RAS's preference and the owner's approval
  3. Because the Procedures set required content, format, and deadlines, and TDLR can audit them
  4. Because report format has no bearing on how TDLR or the owner treats the finding

Glossary

AB Project Registration Form
Form required in the project file before a RAS begins plan review, when the RAS registers the project.
Attachment "A"
TDLR's prescribed transmittal letter, "Plan Review/Revision Completed," required with every plan review report.
TABS
TDLR's online system for tracking RAS project files and report uploads.
Transmittal letter
A shortened alternative to the full report, permitted only when no deficiencies are found.
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