Reimbursement Guidance

1. Reimbursement Guidance Work Authorization

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

3. 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

4. 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

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

6. 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

7. 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

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

9. 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

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

11. 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

12. 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

13. 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

14. 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)

15. 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)

16. 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

17. The 007 AAF Monitoring Well Installation M0089 Equip Mob/demob event 1 1 Possible 2nd wk drilling M0123 5 in. mon well inst foot 80 60 4 wells @ 20’/ X001 Titanium Widget unit 1 0 Est. cost = $25

18. The 007 AAF

19. Reimbursement Period AAF Report Writing Lab Invoice Sub-Phase Period Jan Feb Mar Apr May Jun Phase Period

20. Electronic AAF • Microsoft Excel spreadsheet • Automatically populates code descriptions • Documents tracking of changes • Summarize Total units • Easily emailed

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

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

23. Transition to Sub-Phases PSCRMon Sub-Phase Period PSCRMon Sub-Phase Period PSCRMon Sub-Phase Period 198 SCR Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 2007