Here, “audit” means an internal portfolio screen—not an IRS examination. The objective is to turn scattered project history into an organized inventory that shows what is known, what is missing, and which gaps are realistically solvable.
A useful screen does not begin by multiplying every building’s area by a maximum rate. It begins with owner identity, project dates, actual design scope, installed systems, and supporting records. Those facts determine whether deeper technical and tax work is warranted.
Inventory
Capture the project before estimating the opportunity
For each project, record a stable project ID, legal owner, location, gross area, building type, designed systems, responsible discipline, and the documents that show technical authorship. Keep owner status separate from occupant name and project marketing language.
Do not upload sensitive client records to a public screening page. Use the inventory as a private index to controlled files, with an assigned reviewer and a next action for each project.
Illustrative portfolio-screening funnel
The counts show workflow attrition, not expected conversion rates.
Initial internal list
Ownership still requires verification
Technical authorship appears supportable
Date and technical records are available
| Item | Value | Note |
|---|---|---|
| Projects inventoried | 20 | Initial internal list |
| Tax-exempt-owner candidates | 8 | Ownership still requires verification |
| Clear design evidence | 5 | Technical authorship appears supportable |
| Ready for deeper review | 3 | Date and technical records are available |
Four clocks
Construction start, service, deduction year, and filing date are different
Construction-start evidence addresses the current-law cutoff. Placed-in-service evidence helps identify when qualifying property became ready and available. The deduction year depends on the governing route and facts. The filing date addresses when the return or other permissible procedure was used.
Do not label a prior year open from the project date alone. Refund limitations generally depend on actual filing and payment facts, while some partnerships may use administrative adjustment procedures rather than ordinary amended returns. The CPA should own that procedural conclusion.
Evidence fields
Add allocation, certification, labor, and prior-deduction status
A promising owner and design role can still stall without a written allocation, technical model, field inspection, certification, eligible-cost support, or required labor records. Track each category explicitly rather than collapsing them into a single confidence score.
The construction cutoff excludes property whose construction begins after June 30, 2026 under current law. Preserve property-level evidence; a contract date by itself should not be described as conclusive proof.
Evidence-completeness matrix
Missing categories guide follow-up; they do not calculate eligibility.
| Review point | Evidence or measure | Why it matters |
|---|---|---|
| Project A | Ready | Owner, dates, design records, and technical file present. |
| Project B | Missing evidence | Request allocation contact and placed-in-service record. |
| Project C | Not currently supportable | Owner identity and technical authorship remain unresolved. |
Three queues
Prioritize solvable gaps—not the largest hypothetical number
Use three queues: evidence ready for technical review, evidence missing but potentially obtainable, and not currently supportable. A smaller project with a clear owner, strong specifications, reliable dates, and accessible contacts may deserve attention before a larger project built on assumptions.
Review the queues on a recurring schedule. Assign one responsible person, document the next request, and set a milestone. If the evidence changes, move the project without treating the movement as an eligibility determination.
One sample project changes queues
A document request can improve readiness without guaranteeing qualification.
Missing
No service record
Request
Obtain commissioning file
Received
Validate date and scope
Technical review
Proceed conditionally
Prepare the review
Give the reviewer one row that answers the next question
- Project ID, address, area, and legal owner
- Designed systems and named technical author
- Construction-start evidence
- Placed-in-service evidence
- Potential deduction and filing years kept separate
- Allocation and owner-contact status
- Model, inspection, and certification status
- PWA records or applicable exception review
- Prior building deductions and eligible-cost records
- Assigned reviewer and next milestone
Continue the review
Common questions
Practical answers before the review
How far back should we inventory projects?
Inventory can begin broadly, but a tax adviser must assess the governing historical rules and filing procedures before any year is treated as available.
Which fields should we collect first?
Start with project ID, legal owner, address, area, systems, design author, construction start, service date, and available evidence.
Does a screening score establish eligibility?
No. Screening only prioritizes work; it does not replace technical certification, allocation, or tax analysis.