Fair Appraisals for Bosque County
On Thursday, March 27, 2025, at 11:30 AM, Deputy Chief Appraiser Justin Neuman sent an email with the subject “State Comptroller’s Audit on Property Values for 2024,” attaching results from the 2019–2023 School District Property Value Study (SDPVS; Publication #98-1059). While the intent may have been to demonstrate support for the Appraisal District’s valuation methods, this use of the audit could be misleading.
While the School District Property Value Study (SDPVS) is a critical tool used by the Texas Comptroller to assess whether overall property values are within acceptable ranges for school funding, it is important to note its limitations. The study is based on a sample of properties, not a comprehensive review of all individual appraisals. Therefore, a passing result on the SDPVS does not confirm the accuracy of each individual valuation, nor does it address the specific concerns of property owners.
Moreover, the SDPVS report cited pertains to values through 2023. It does not evaluate or validate the 2024 appraisals, which are the subject of current public concern. Relying on this report to defend the 2024 valuation process may be misleading, as it conflates different timeframes and overlooks the scope of the study.
Mr. Neuman's email references results, which are often seen as a general indicator of whether overall property values are within the required range for state funding purposes. The SDPVS is a broad, district-level review designed to assess whether property values align with market values within a 5% margin of error. It does not, however, confirm that every individual property is accurately valued or that the methods used to determine those values fully comply with state law.
While the SDPVS results suggest that the district’s overall values meet the state’s criteria, the study does not directly evaluate specific valuation practices or address all potential concerns raised by property owners. The SDPVS does not review issues such as potential inconsistencies in appraisal methods or the handling of specific cases, including those involving senior citizen tax caps or other concerns about valuation techniques.
It’s important to note that passing the SDPVS does not automatically confirm that every aspect of the appraisal process is free from dispute or compliant with all legal standards.
The SDPVS results, while important, do not resolve all public grievances related to appraisal practices, such as concerns regarding the use of mortgages in property valuation or the handling of tax caps for senior citizens. These issues remain outside the scope of the PVS and have not been specifically addressed in the correspondence.
While the School District Property Value Study (SDPVS) offers useful insights into district-level valuation trends, it should not be marketed as a blanket validation of the appraisal district’s overall practices. A district can meet the minimum statistical thresholds set by the state while still facing legitimate questions about specific appraisal methods, transparency, or legal compliance. Meeting the SDPVS standard is one measure, but not the only one that matters to taxpayers.
“The state has certified the values we have in place for our county are accurate, equitable, and reflect 100% market value.”
This statement may be misleading or exaggerated, as the School District Property Value Study (SDPVS) evaluates whether aggregate district values generally align with market standards, not whether individual property appraisals are accurate, equitable, or free of error. It does not serve as a comprehensive validation of every assessment conducted by the appraisal district.
“The audit process ensures that property values are appraised consistently and fairly across various property types, house types, neighborhoods, and school districts.”
This statement could be seen as an overstatement, as the School District Property Value Study (SDPVS) focuses on district-wide consistency in relation to market values for school funding purposes. It does not evaluate whether individual properties are appraised fairly, accurately, or uniformly across different neighborhoods or property types.
The Texas State Comptroller’s School District Property Value Study (SDPVS) is an important tool used to assess whether local appraisal districts’ property assessments reflect market values. However, it’s important to understand what the SDPVS measures and what it does not.
The SDPVS is conducted by the Texas Comptroller of Public Accounts to compare property values in local appraisal districts to those determined by the state. This study is a broad review covering various property types, including residential, commercial, agricultural, and vacant land.
The goal is to ensure that the values are:
Consistent: Property values across similar properties should be equal and uniform.
Accurate: The values should reflect the true market value of the properties.
Fair: Property values should be assessed according to legal requirements, such as using comparable sales data.
While passing the SDPVS is a significant milestone for an appraisal district, it does not automatically guarantee that individual property valuations are fair or comply with legal standards. Here’s why:
General, Not Specific: The SDPVS evaluates overall district values to ensure they are within a 5% margin of error when compared to state values. It does not evaluate individual properties, the specific methods used to assess them, or practices that may be seen as problematic, such as allegedly basing values on mortgage amounts.
Market Value vs. Local Practice: Even if a district passes the SDPVS, it does not confirm that the methods used to determine market value for individual properties are in full compliance with legal standards. Concerns have been raised in Bosque County regarding the use of mortgage amounts in property valuations rather than the required market value approach, which would need to be addressed separately under the Texas Property Tax Code.
Doesn’t Address Specific Complaints: The SDPVS results do not consider individual complaints or concerns such as potential retaliatory tax increases for property owners who challenge appraisals, nor does it examine issues like the removal of state-mandated tax caps for senior citizens, which have been reported by taxpayers in Bosque County.
Passing the SDPVS Doesn’t Excuse Alleged Unethical or Possibly Illegal Practices.
Alleged Retaliatory Tax Increases: Concerns have been raised that individuals may experience tax increases after questioning or contesting their appraisals.
Alleged Improper Valuation Practices: There are reports of using mortgage amounts in valuations rather than a proper market-based analysis.
Alleged Unlawful Removal of Tax Caps for Seniors: Issues have been raised about the removal of legally protected tax caps for senior citizens, potentially leading to unfair tax increases.
Although the Bosque Central Appraisal District's passage of the SDPVS confirms that overall property values fall within the state's acceptable range for school funding purposes, this does not absolve the Chief Appraiser, Deputy Chief Appraiser, or the District itself from accountability.
The SDPVS does not assess individual appraisal practices, nor does it examine whether property owners were treated equitably. It is not a substitute for transparency, fair process, or responsive governance — especially when numerous residents have raised concerns about accuracy, consistency, or fairness in their valuations.
The SDPVS report cited covers property values through 2023. It does not analyze or validate the 2024 appraisals currently in question. Using it to justify 2024 values misrepresents the timeframe and scope of the study and Publication #98-1059.
The SDPVS is conducted to ensure school funding accuracy, not to evaluate fairness or consistency at the individual property level. A district may meet audit benchmarks while still facing valid local concerns about how appraisals are carried out.
State audits like the SDPVS are retrospective. They do not account for valuation changes, concerns, or protests that emerged after the 2023 appraisal cycle, including those tied to the 2024 valuation process.
A “passing” status in the SDPVS means values are within a statistical range suitable for state funding calculations. It does not guarantee uniform appraisal standards or equitable outcomes for taxpayers across the board.
In his email, Mr. Neuman references the School District Property Value Study (SDPVS) as evidence supporting the district’s appraisal methods. However, the results provided in his attachment reference the 2023 audit, not the 2024 findings certified earlier this year. Regardless of which year is cited, it is critical to understand the SDPVS’s limited scope.
Mr. Neuman’s email could be interpreted as oversimplifying or misrepresenting the intent of the School District Property Value Study (SDPVS). Passing the SDPVS is notable, but it does not confirm the accuracy of all appraisal methods, nor does it resolve taxpayer concerns about individual valuation practices or potential inconsistencies. The SDPVS is designed to assess general compliance with state funding requirements, not to evaluate the fairness or precision of each appraisal conducted by the district.
We asked for them!
On March 27, 2025, Deputy Chief Appraiser Justin Neuman replied to an official inquiry by pointing to a series of links on the State Comptroller’s website. While helpful, these links lead to highly technical documents—ratio studies, stratified categories, and statistical worksheets—spread across multiple pages and formats.
🔗 School District Summary Worksheet
🔗 Field Studies Category Worksheet
🔗 Utilities Category Worksheet
In his message, Mr. Neuman emphasized one line buried mid-page:
“THE SDPVS FOUND YOUR LOCAL VALUE TO BE VALID AS A RESULT OF THE SDPVS, AND LOCAL VALUE WAS CERTIFIED.”
The state found the local values acceptable for school funding purposes, not necessarily accurate on an individual level or fair to taxpayers. The School District Property Value Study (SDPVS) is a funding compliance audit, not a full appraisal review.
We asked for transparency and instead we got a technical dump!
Let’s look at just one key line item from the state’s own findings for Walnut Springs:
Local Appraisal (BCAD): $46.18 million
State Estimate (PTAD): $40.71 million
Ratio: 1.1343 → That’s 13.4% over the state’s estimate
Walnut Springs ISD has the largest overvaluation among all Bosque County districts - more than DOUBLE the margin seen in any other district.
Who's Overvaluing Your Home? 2024 SDPVS: Breaking Down the Numbers - BCAD Property Appraisals Across Bosque ISDs vs State Estimates
Download the PDF: Table showing each Bosque County ISD's Single-Family appraisal data, with the percentage over/under the state estimate rounded to two decimal points with clickable links to the official Texas Comptroller audit results.
In plain terms, the Bosque County Appraisal District valued the majority of our Homes higher than the state believed they’re worth. And yet, the Comptroller still stamped the data with:
✅ “THE SDPVS FOUND YOUR LOCAL VALUE TO BE VALID.”
Why? Because it fell within the state’s +5% margin of error for audit purposes.
But what about the percentages that exceed the +5% margin of error?
It's confusing... We know!
An overvaluation in one category—like Single-Family Homes—can still slip through unnoticed if other categories are undervalued, balancing out the district wide average. That’s because the ±5% margin of error used by the state applies to the overall weighted mean ratio for all sampled properties across the school district, not to any one property type or neighborhood. This system is designed for funding compliance, not to ensure individual fairness for taxpayers. So even if your home was appraised far above what the state believes it’s worth, the district can still be marked “valid,” and you’re still stuck with the bill.
It means the state didn’t reject the numbers because they were close enough for school funding purposes. But that doesn’t mean your appraisal was fair. It doesn’t mean the process was transparent. And it certainly doesn’t mean taxpayers are being treated equitably.
State education dollars are based on these values, not necessarily your actual home’s worth.
If your property was over-appraised, you're likely paying more in taxes than you should be.
Certification by the state doesn’t guarantee fairness. It just means the Bosque County Central Appraisal District stayed within an acceptable margin or error for them, not for you.
While the audit results are an important data point, they should not be presented as definitive proof that appraisals are fair, accurate, or beyond scrutiny. Local oversight, public transparency, and open dialogue remain essential to maintaining trust in the appraisal process.
If you have experienced unfair valuations or suspect unlawful practices, it is important to share your story. The PVS does not excuse unethical or illegal practices.