Reimbursement Guidance Work Authorization

Purpose Clarify the Work Authorization Process Understand updates/changes to the Work Authorization Process Understand how to use the 007 AAF

Objectives Review the work authorization process Explain proper use of Proposed and Contingent Units Explain how incomplete or deficient reports are to be handled Explain use of the new 007 AAF

Definitions Pre-Approval = Authorization = Pre-Authorization Work Performance Period = the start and end of a phase or sub-phase; has nothing to do with reimbursement

The Work Authorization Process: pre-approval Release Reported DEQ Assigns PC# and Case Manager Consultant/RP and DEQ discuss Work Scope Consultant Prepares/edits Scope/AAF and submits to DEQ DEQ reviews Scope/AAF OK? NO Consultant/RP And DEQ Sign AAF YES Work ! own risk Discuss with GWM RP to cover $

Confirmed Release Letters For combined IA/SCR Reports, DEQ Case Managers will specify a single due date For separate IA and SCR Reports, DEQ Case Managers will specify separate due dates for the deliverables

AAF Pre-Approval DEQ & Consultant/RP discuss scope Consultant/RP develops AAF DEQ reviews AAF and discusses needed changes w/ consultant/RP Consultant/RP amends AAF as necessary DEQ signs AAF and returns to consultant/RP

The Work Authorization Process: change in work scope Site Conditions Require Change/Increase In scope Consultant/RP Contacts DEQ Case Manager to Get approval for Additional units Contingent Units Sufficient? NO YES Work Consultant/RP documents Approval! Approval received? YES NO own risk Discuss with GWM RP to cover $

Proposed and Contingent Units Proposed Units Units to complete entire work scope Based upon existing knowledge of site Contingent Units Units for reasonable changes to work scope Changing or unknown site conditions Circumstances arising during work Rationale for use must be supported

The Work Authorization Process: verification Consultant/RP Submits Deliverable & Work-performed AAF to DEQ DEQ Case Manager Reviews deliverable NO YES DEQ Case Manager Verifies AAF (30 days) Deliverable Complete? Work DEQ Case Manager Sends VAAF to DEQ CO DEQ Case Manager Conveys Denial info to Consultant/RP To Reimbursement

AAF Verification DEQ Case Managers may request additional documentation Consultant/RPs must document rationale for contingent unit use DEQ Case Managers must document rationale for denials (comments field) DEQ Case Managers have 30 days to complete

Deliverables Deliverables must be well defined at time of pre-authorization Deficient deliverables shall be returned for completion – no additional units authorized Addenda – additional units shall be authorized for expanded/new scope of work

Deficient Reports Standard and/or requested report items missing with no rationale Incorrect work, e.g. calculations are wrong, improper well construction, contours are wrong, etc Poor quality, e.g. illegible, obviously boilerplate (wrong references, not site specific), report is self-contradictory, missing rationale, unsupported conclusions

Deficient Reports (cont) Supporting documents missing, e.g. analytical reports, manifests, correspondence, access agreements, photos, field logs, etc Incorrect work, e.g. calculations are wrong, improper well construction, contours are wrong, etc. Incomplete scope of work (field work)

Addenda New/additional work needed - not in original scope of work Phased approach being used Unforeseen circumstances: e.g. undocumented utilities encountered, weather difficulties, land use or planned land use affecting scope of work (use or planned use not in existence before finalizing scope of work)

The 007 AAF Landscape format No pre-printed T-Codes Scope of work broken into Activities New field order - Code and Description Separate comment fields

The 007 AAF Monitoring Well Installation M0089Equip Mob/demob event11Possible 2 nd wk drilling M01235 in. mon well inst foot804 20/60 X001Titanium Widget unit1Est. cost = $250

The 007 AAF

Reimbursement Period JanFebMarAprMayJun AAF Lab Invoice Lab Invoice Report Writing Report Writing Sub-Phase Period Phase Period

Electronic AAF Microsoft Excel spreadsheet Automatically populates code descriptions Documents tracking of changes Summarize Total units Easily ed

The Work Authorization Process: Reimbursement Claimant Prepares a Reimbursement Claim Package Claimant Submits Claim To DEQ CO NO YES Claim Complete? From: Verification Process Claim And Yield Decision DEQ CO QA/QCs claim Decision Reject Claim or Request Additional info from Claimant VAAF Received from RO? Decision Mailed Return Claim to Claimant YES NO Claim Passes QA/QC NO YES Payment

The Work Authorization Process: Reconsideration Claimant Receives Claim Decision Seek Recon? From: Reimburse- ment DEQ CO copies docs to RO Claim Reviewed Claimant Files Reconsideration Claim & Supporting Docs to DEQ CO (45 days) Additional Info Needed? Analyze Claim, Render a Draft Decision NO YES Payment Stop RO Reviews & Responds to DEQ CO Decision & Conversion ltr To Claimant Panel Type? Panel Convenes & Renders Final Decision RO Input Needed? Decision Mailed YES NO YES M W

Transition to Sub-Phases JanFebMarAprMayJun PSCRMon Sub-Phase Period 198 SCR JulAugSepOctNovDec PSCRMon Sub-Phase Period PSCRMon Sub-Phase Period 2007