Underground Storage Tanks

Which states have successfully implemented PFP in their LUST programs?

A number of states (PDF) (1 pg, 837K, About PDF) - Vermont, New Hampshire, Florida, South Carolina, Oklahoma, Utah, California, Nebraska, and Michigan-are using pay for performance (PFP) cleanups in their leaking underground storage tanks (LUST) programs. Florida, South Carolina, and Oklahoma have reported that their pay for performance cleanups have resulted in faster and more effective tank cleanups. Other states using PFP have also benefitted from PFP cleanups.

South Carolina, Oklahoma, and Florida have reported that PFP cleanups have enhanced the ability of their LUST programs to clean up LUST sites and thus protect human health and the environment. You can read case studies from Oklahoma (PDF) (3 pp, 52K, About PDF), South Carolina (PDF) (2 pp, 45K, About PDF), and Florida (PDF) (2 pp, 47K, About PDF) and find out what state staff have to say about the benefits of using PFP contracting (all from LUSTLine, Bulletin # 36, November 2000)

South Carolina

South Carolina began its first active PFP cleanup (see LUSTLine, No. 36, November 2000) in spring 1997 and quickly made PFP mandatory for all on-going cleanups that could not be completed within six months. South Carolina conducts open competitive bidding for its PFP cleanups, with the award made to the lowest bidder on state-lead sites. A site's owner/operator may opt to use a higher priced contractor, but the maximum amount the state will reimburse is the amount of the lowest bidder. The state's bid package includes the site characterization, cleanup goals and a time limit to attain them.

South Carolina requires performance bonds of contractors on all state-led cleanups. PFP contracting is the standard approach to all cleanups; even emergency response cleanups are done on PFP terms. In emergency response cases, the state may authorize in writing a contractor to begin corrective action before completion of its public notice and permit approval process. South Carolina quickly and successfully implemented PFP contracting.

Cleanup Contractors Profit From PFP Contracts

Most of South Carolina's PFP cleanups have time limits between two and three years to reach their environmental goals. Most South Carolina PFP cleanups are reaching their goals on time or occasionally sooner. The state sets time limits individually for each site, based on transport time to the nearest receptor to be protected. The contractor must attain the environmental goal of the cleanup within this time period, typically 24 to 36 months.

Most PFP sites report interim results that South Carolina staff routinely review. Staff review quarterly contamination-level monitoring reports from each PFP site and confer with the cleanup contractor if there is indication that contamination reduction may be stalling at a PFP site.

Open competition and lowest-bid award produce low-priced, effective PFP cleanups. Open Bid Competition Produces Lower Prices

South Carolina's use of open competitive bidding and lowest-bid award/pricing illustrates how PFP can save states significant amounts. By making UST cleanups subject to economic incentives and price-competition to lower prices, they spur environmental results, as shown by the following table:

These data compare bid prices of similar UST cleanups solicited privately from three or four bidders by the responsible party to bid prices advertised publicly statewide by the state. The average lowest-bid award price for the "three bid" offers ($238,000) is more than twice as much as the average low-bid award price ($108,000) for bids solicited statewide. The state reports that responsible parties often had difficulty getting the minimum number (three) of bids and that this often delayed starting their cleanups. The state now requires that the responsible party solicit bids publicly statewide in the state's publication South Carolina Business Opportunities.

Big differences in high and low bids indicate UST cleanup prices can be reduced significantly.

Big differences between lowest and highest bids on the same sites continue to occur as shown in the table on the right. This indicates that there is great "elasticity" in cleanup prices. It also implies that continuous competition among bidders is necessary to ensure that low bids are in fact offered. There is no consistent downward trend in low-bid cleanup prices because some sites involved larger plumes and more complex conditions that are inherently more expensive. Note, however, that some high bids (voluntarily submitted) were as much as four times the lowest bids. Had the high-bid estimates been used to negotiate, the ultimate price would likely have been significantly higher than the lowest-bid award price.

Lowest-bid pricing can produce engineering excellence in cleanups.

The Consulting Engineers of South Carolina association has awarded the state's UST PFP program its Engineering Excellence Award first and second places for environmental work of less than $500,000. South Carolina's lowest bidders do not "cut corners" and can produce timely, environmentally effective, profitable cleanups. Lean, agile, and technology-savvy management kept that way by price-driven market competition is proving to be a stronger guarantor of environmentally effective and cost effective cleanups than were government-imposed unit costs and other cost-control techniques the state had previously used.

To learn more about South Carolina's UST program, visit its website at http://www.scdhec.net/ust.

Oklahoma

Oklahoma Converted UST T&M Cleanups To PFP To Spur Their Progress

Oklahoma has successfully used PFP (see LUSTLine, Bulletin # 36, November 2000 (PDF) (3 pp, 52K, About PDF)) to spur further contamination reduction at existing UST cleanup sites that had failed to reach goals even after extensive treatment. Oklahoma began PFP by identifying ongoing cleanups where, despite significant site expenditures, contamination levels had stopped going down. Then state staff met with the responsible party and the cleanup contractor regarding this problem. Sites where neither the contractor nor the responsible party was able to show a way to reach the cleanup goals within a reasonable time were converted from T&M to PFP terms. In some instances the existing cleanup contractor was replaced; in others, the existing contractor was kept but paid on PFP terms. At some sites the existing treatment system was used; at others, new systems were installed.

Failing T&M cleanups began producing environmental results under PFP terms.

The environmental effects of converting seemingly hopeless T&M cleanups to PFP terms in Oklahoma have been dramatic. When these "flatlined" sites were converted from T&M to PFP contract terms, contamination levels spiked downward quickly and continued to decline over time. This pattern of sudden reductions, followed by a moderate to slight rebound then trending downward is typical of results from converting T&M sites to PFP.

PFP can avoid the excess costs of using T&M.

Oklahoma found that it had paid out approximately $4.5 million in excessive costs at 35 UST T&M sites before converting the sites to PFP terms using air sparging and soil vapor extraction treatment technologies. Had these cleanups been working on PFP terms from their outset rather than on T&M terms, the state says these costs would have been avoided.

Florida

Florida Adopts Innovations In Procuring And Applying PFP Cleanups

Florida's PFP cleanups typically address contaminated groundwater that must be cleaned up to drinking water standards. Many of Florida's UST PFP cleanup sites pose problems; the state expects to take a relatively long time, up to six years, to reach and sustain the cleanup goals.

Florida has adopted a practice termed the "PFP warranty period." During the warranty period the site must stay at or below contamination goal levels; otherwise the contractor may have to resume active treatment until goals are sustained. Florida's warranty period is a minimum of 12 months.

Although Florida's PFP program is not yet mature or extensive enough to weigh its environmental results, state officials have been highly innovative in experimenting with different ways to price PFP cleanups and to apply PFP principles.

Competitive bidding pilot test produces six bids lower than the state's price estimate.

In a competitive bidding pilot test (see LUSTLine, Bulletin # 36, November 2000 (PDF) (2 pp, 47K, About PDF)) Florida requested bids for PFP cleanup of a bundle of three sites, all to be awarded to the cleanup contractor who submitted the lowest bid. The state prepared a package of information including site characterization data, cleanup goals, and typical PFP terms for payment. Eleven contractors offered bids ranging from $227,000 to $1,064,000. Six of the 11 bids were lower than the state's own internal estimated price for this group of sites. State officials observed that higher bids generally came from the larger contractors. Subsequent bidding experience has continued to show significantly lower prices in comparison to that which would have been generated by applying the state's standard cleanup prices. The state has since shown that competitive bidding can spur contractors to offer site characterizations according to state specifications at prices 40% to 60% below the state's standard estimated prices.

Florida tries "bundling" (also referred to sometimes as multi-site clean up agreements) sites in PFP cleanups.

Bundling (also referred to sometimes as multi-site clean up agreements) is offering a group of cleanup sites for a single fixed price to be paid out on PFP terms. Several such "bundled" PFP experiences are described below.

Florida negotiated the price for a bundle of 30 PFP cleanups with the contractor for a single responsible party over a two-day period. Some issues affecting all the sites were resolved on one site and then applied to the other sites. Compromises were reached on prices, with the contractor seeking higher prices because of factors such as offsite access and site closure expenses. Although the state did not get a big reduction in price compared to its estimated T&M price, the state succeeded in launching a large set of cleanups quickly, thereby more effectively protecting the environment and human health.

Florida has also successfully piloted another variation of "bundling" (also referred to sometimes as multi-site clean up agreements). In this experiment a contractor offered to conduct PFP cleanups at 10 sites for a total of $1,350,000 ($135,000/site) or, 5 sites for $825,000 ($165,000/site), with the state allowed to choose the sites. The contractor reasoned that by cleaning up several sites concurrently it could cut its internal costs by economies of scale, for example, using portable equipment at multiple sites and combining on-site visits. The contractor also figured that the number of sites at the prices offered lowered the business risk by spreading the financial risk of underpricing any single site over multiple sites. Some sites may incur unexpected expenses, but others will turn out to be less challenging than expected and become profit sources. The 10 sites chosen by the state included some clusters of contiguous sites and about 6 non-contiguous sites in the Panhandle region of the state. The state has begun offering other contractors the same type of deal.

Monitored natural attenuation goal attainment is expedited by PFP.

Florida has also pilot-tested PFP to expedite goal attainment at state-subsidized natural attenuation sites where the state requires (and will subsidize) only monitoring costs. To apply PFP to such sites the state simply offers to pay the contractor the state's standard price for full-term monitoring of the site as soon as the site reaches its natural attenuation levels. Under PFP at monitoring-only sites, the contractor typically identifies and remediates the remaining contamination aggressively and quickly, rather than simply wait for its natural attenuation.

This arrangement serves the interests of site owners who want to clean up a property quickly to resell or refinance, or to relieve their business of the liability it poses. PFP at monitoring-only natural attenuation sites serves the interest of the state fund by keeping its spending at the site commensurate with the risk the state has judged the site to pose. It serves the interest of the cleanup contractor in that it produces income and profit sooner than would quarterly billings for the fixed price of monitoring over a four- or five-year period.

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How do I know if my state is ready for PFP?

You may have decided that you would like to consider pursuing pay for performance (PFP) contracting but are not certain whether or not you are poised to act. This section provides information about issues a state should consider before beginning work on a PFP contract or program. It includes a checklist to help you assess your readiness to proceed with PFP and highlights those things that you may need to work on before tackling a specific PFP contract.

Readiness Checklist

Is funding available for PFP cleanups?

• What will be the source of the funding?
• What is the cashflow status of this funding, and are there fund-solvency concerns?
• What will be the effect on the funding of potential savings from PFP sites?

Are there suitable sites in the state for PFP cleanup terms?

• Are there existing or new sites?
• What is the state's standing to apply PFP to these sites?

Will the state consider individual or multi-site PFP agreements?

Has site characterization occurred at the sites proposed for PFP cleanup?

• Is the site characterization routinely done separately from the active remediation?
• Is there existing data on this site that will assist in setting the price for the cleanup?
• Can the state specify what site-data are required in a characterization?

Does the state have the authority to set firm fixed price for reimbursement?

• Does the state have the legal authority to set a firm fixed price for a cleanup or bundle of cleanups?
• How are payments currently processed and can this process be altered to pay for the delivery of contamination-reductions rather than for time and materials?

What is the current method of determining a reasonable price and what is the authority basis for this?

How will the state set the fixed price--through competitive bidding or by negotiation?

• Could the state leverage existing authority to require owner/operators to get competitive bids?
• Does the state have the capability to develop a negotiating team and use pricing data?

Is the state able to measure contamination reduction for purposes of payment and progress oversight?

• Does the state have the staff capacity to field-supervise split-sampling events?
• Is the state able to establish defensible baseline measurements?

Does the state have safeguards against contractor default or cleanup failure?

• Does the state have the authority to require performance bonds?
• Can the state bar a contractor from performing any further cleanups in event of default?

What are the organizational arrangements within the state Agency for oversight and coordinating performance with payment?

• If the regulatory program is separate from the fund, what coordination is required to allow for verification and payment

Is the CAP before or after the RFP?

• How does the CAP approval process interact with PFP?
• Who is the approving official, and does the approval process need to be specified in the PFP contract?

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How are stakeholder concerns about PFP contracts addressed?

It is essential to consider all stakeholders early in the process and to address any concerns they have about moving from T&M-type contracts to PFP cleanups. PFP cleanups can be in the best interest of the sites's responsible party, the cleanup contractor, and other stakeholders, as well as the government. Stakeholders to consider in the PFP process include: state staff, UST owners/operators, cleanup contractors, government auditors, legislators and legislative staff, and environmentalists and the general public.

State Staff

The use of PFP contracts will benefit state government staff. Under a PFP contract there is no need to review monthly invoices and labor justifications; therefore, staff can focus on the more important aspect of the project-achieving environmental results. State staff will spend less time overseeing a PFP contractor than under a traditional T&M contract.

UST Owners/Operators

For tank owners/operators, PFP is more efficient in terms of both time and money for cleaning up contaminated sites. For example, an owner who wants to sell the property will be interested in PFP because the site will be cleaned up much faster, thereby ensuring the overall value of the land and profit on the sale of the property. A speedy cleanup will also minimize the possibility of incurring liability for third-party damages due to plume migration. A PFP cleanup also lessens paperwork and hassle for the owner (no need to keep track of contractor's time and materials used in the cleanup). UST owners/operators will find PFP contracts quicker and more cost effective.

Cleanup Contractors

PFP can improve both the profitability and the quality of a contractor's business. PFP contracts can lead to higher profits from better management, smarter use of equipment, and better technology. The performance-focused administration of PFP gives the contractor more control of internal costs.

PFP may put more financial risk on the contractor, but assuming this risk may lead to increased profits. In addition, the contractor is paid more quickly under a PFP contract because payments are not based on review of monthly reports and invoices but on the actual level of contamination reduced. Cleanup contractors can make a profit on PFP contracts.

Auditors Of PFP Contracts

Most UST cleanups are subject to audit by independent government auditors, and PFP cleanups leave a much cleaner audit trail than traditional T&M cleanup agreements. In PFP, there is not as much paperwork to review because the invoices, receipts and documentation required by a T&M contract are not required. A PFP contract purchases contamination reductions rather than labor and materials. The contract will clearly be fulfilled by a reduction in contamination at the site. For auditors, an audit of PFP contracts is more clear cut than audits of traditional contracts.

Legislators

PFP is one way to control government spending without compromising environmental protection. PFP contracts include a fixed price, reducing the uncertainty that often comes with UST cleanups. The environmental cleanup goal is clear, as is the price for the cleanup. This improved predictability makes it easier to appropriate and budget the necessary funding. Legislators will not have to pursue as many constituent complaints about delays in starting cleanups and payment for work performed under T&M contracts because PFP contracts eliminate the lengthy work plan review and approval process as well as simplify the payment process. Legislators will welcome the reduced cost and uncertainty with PFP contracts.

Environmentalists And The General Public

Many times private citizens are the first to bring contaminated groundwater or soil to the state's attention. PFP focuses on reducing contamination at a site as quickly and efficiently as possible rather than on the technology used to clean up the site. The public will be able to better understand what is occurring at a site in their neighborhood because PFP focuses on measurable results of contamination reduction. In addition, the cost savings that come with PFP cleanups, especially through competitive bidding, can lead to more cleanups within the state. Environmentalists and the general public will benefit from more cleanups, performed faster, within the state.

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How do I begin to implement PFP?

You may have decided to implement pay for performance (PFP) in your state, but how do you get started? This section provides information to enable states to optimize PFP opportunities. Some questions to be considered include:

• How have other states started their PFP programs?
• Who is the best person on my staff to champion PFP?
• Why do a pilot study?
• Who needs to know about PFP and why?
• How does PFP fit into the state's organizational structure?
• What are the common challenges to launching a PFP pilot? What are the solutions?

Ways Some States Started Their PFP Programs

A number of states have launched PFP programs (PDF) (1 pg, 837K, About PDF) to reduce the cost and to increase the pace of cleanups. South Carolina and Oklahoma tank programs have converted all their underground storage tank cleanups to PFP terms.

Oklahoma Converts Flat-Lined Sites

Recognizing that the concept of performance-based cleanup contracting made a lot of sense, the Oklahoma Petroleum Storage Tank Division voluntarily implemented a PFP program in 1996. Oklahoma began its PFP program by identifying on-going cleanups where, despite significant site expenditures, contamination levels had stopped declining. Sites were chosen where neither the cleanup contractors nor the responsible party could show a way to reach cleanup goals within a reasonable time. These sites were converted to PFP cleanups.

You can read case studies from Oklahoma (PDF) (3 pp, 52K, About PDF), South Carolina (PDF) (2 pp, 45K, About PDF), and Florida (PDF) (2 pp, 47K, About PDF) and find out what state staff have to say about the benefits of using PFP contracting (all from LUSTLine, Bulletin # 36, November 2000)

Possible Ways To Succeed With PFP

Experience and several hundred PFP cleanups have produced some common sense lessons about starting and managing PFP programs and cleanups.

• Consider pilot testing procedures at 20-25 sites with several contractors. Starting with fewer sites will not provide enough experience to fine-tune the PFP program. Involve several different contractors to create implicit competition.
• Try a PFP pilot; then fine-tine the process as new cleanups are started.
• Consider shifting the state level of effort to ensure complete, accurate, and timely site assessment and characterizations. Paying more for thorough site characterizations lowers the business risk and the ultimate price of the cleanups.
• Competitive bidding with award to the lowest qualified bidder can produce environmentally successful PFP cleanups, but negotiating the first few contracts may help attract cleanup consultants and build their comfort with PFP contracting.
• Small- to medium-sized firms will often bid on PFP cleanups because their operating costs are typically lower, and they may be trying to break into the cleanup business.
• Awarding a single contract for the cleanup of multiple sites (otherwise known as "bundling") can increase the business appeal of PFP terms. This approach gives contractors more "wiggle room" for error in bidding and provides greater confidence that they will make a fair profit on these cleanups.

Championing PFP

The right mix of state staff, candidate sites, and cleanup contractors is essential to starting a successful PFP program. States who have successfully launched PFP say that choosing a PFP champion is the most important first step. As in launching any new initiative, it is important to identify a person who likes innovation, is persuasive, and has strong leadership skills. The PFP champion will need to persuade internal staff and managers as well as external stakeholders like owners/operators and cleanup contractors of the benefits of making a paradigm shift.

A PFP champion should also have a proven record of problem solving, experience pricing cleanups, knowledge of contamination measurement and monitoring, ability to develop standard guidance documents and train others, as well as the ability to focus on confirming contamination reduction instead of reviewing engineering reports.

For state staff, technical knowledge of contamination measurement and monitoring techniques is more important than knowing how to engineer a cleanup design in PFP cleanups. One or more of the PFP staff should have sufficient technical knowledge of contamination measurement and monitoring to develop robust contamination monitoring criteria for paying the contractor. The state's role and responsibility in PFP is:

• Ensuring a thorough, accurate, up-to-date site assessment/characterization;
• Monitoring a contractor's performance on a PFP site to be sure agreed upon milestones are met in a timely fashion;
• Confirming contamination goals/milestones are met; and
• Paying invoices quickly.

State staff review of cleanup technologies used in PFP cleanups should be limited to establishing that the proposed treatment approach:

• Is allowable under the state's statute and regulations;
• Is a plausible technique to reach the goals set for the site; and
• Has performance measurements suitable for the technology used and for the risks posed by the release.

A Quick Step-By-Step Approach

• Find a PFP champion.
• Review the Readiness Factors to determine whether there are any legal or regulatory barriers to doing PFP.

• Decide which sites to try PFP on--considering existing sites for conversion to PFP or new cleanup sites.
• Identify all appropriate stakeholders and meet with them to promote the concept of PFP contracting, perhaps via a PFP startup workshop (see State PFP Contracting Presentations).
• Review the site characterization and determine cleanup milestones for payment.
• Determine how to price the PFP cleanups-whether to bid or negotiate the contract.
• Draft and issue the solicitation notice (MS WORD) (15 pp, 115K, You may need MS Word Viewer to read the file ).
• Choose the contractor and sign the contract.
• Monitor concentration levels to ensure the contractor reaches cleanup goals by the contract deadline.
• Pay PFP invoices quickly as contamination reduction milestones are met.
• Confirm contamination reduction results after the goal is reached.

Conducting A Pilot

A pilot program gives the state, contractors, and responsible parties an opportunity to familiarize themselves with PFP and to customize it to unique local needs. For states trying this contracting approach for the first time, launching a PFP pilot can:

• Help the state determine a process that best fits its needs;
• Demonstrate that PFP cleanups result in faster reduction of environmental contamination than traditional T&M cleanups at leaking underground storage tank sites;
• Show that this contracting method can result in cleanup cost savings for underground storage tank cleanups;
• Confirm that PFP cleanups can result in reduced paperwork for underground storage tank cleanups; and
• Promote greater use of innovative technologies.

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How do I select sites for PFP?

There are two ways of selecting sites for the implementation of PFP-either convert existing time-and-materials (T&M) sites to pay for performance (PFP) or use PFP on new cleanup sites just starting up:

• Convert Existing T&M Cleanup Sites To PFP
• Implement PFP At New Cleanup Sites

Convert Existing T&M Sites To PFP

Significant environmental progress can be seen more quickly and documented as well by converting existing T&M cleanups to PFP terms. Fast results can quickly bolster confidence in this new contracting approach. Converting on-going T&M cleanups to PFP can be especially useful in helping the state achieve annual "cleanups completed" goals.

On-going T&M cleanups can become uncontrollable expenditures and can jeopardize the solvency of a state fund as reimbursement claims continue with little to no environmental results. The longer a cleanup takes to reach its goals the more likely it is that the plume(s) will spread, jeopardizing peoples' safety and health and costing even more to clean up later.

Typically, there are site characteristics and monitoring data available. There may also be additional information that was generated in the course of designing and operating the current treatment system.

To begin converting on-going cleanups to PFP terms, consider these rules-of-thumb when reviewing an inventory of unclosed UST cleanups. Find sites that:

• Will take more than six months to reach their cleanup goal; or,
• Show no significant decline in contamination levels for two quarters; or,
• Will fail to meet cleanup goals within spending caps or time limits at the current rate of spending.

If any one of the above conditions is true for a site, it may be possible to prepare and offer the current site contractor a PFP deal to continue work at the site. If the offer is rejected, review the current contract and determine whether terminating the contractors' involvement at the site and assigning the work to another contractor is possible.

Oklahoma is an example of a successful PFP program that began by converting ongoing cleanup sites. Oklahoma has successfully used PFP to spur further contamination reduction at existing cleanup sites that had failed to reach goals even after extensive treatment. Oklahoma began PFP by identifying ongoing cleanups where, despite significant site expenditures, contamination levels had stopped declining. Then state staff met with the responsible party and the cleanup contractor regarding this problem. Sites where neither the contractor nor the responsible party was able to show a way to reach the cleanup goals within a reasonable time were converted from T&M to PFP terms. In some instances the existing cleanup contractor was replaced; in others, the existing contractor was kept but paid on PFP terms. At some sites the existing treatment system was used; at others, new systems were installed.

The environmental effect of converting T&M cleanups to PFP terms has been dramatic. When these "flat lined" sites were converted from T&M to PFP (MS POWERPOINT) (542K, You may need MS PowerPoint Viewer to read the file ) contract terms, contamination levels spiked downward quickly and continued to decline over time. This pattern of sudden reductions, followed by a moderate to slight rebound, then trending downward is typical of results from converting T&M sites to PFP. Oklahoma found that it had paid out approximately $4.5 million in excessive costs at 35 T&M sites before converting the sites to PFP terms using air sparging and soil vapor extraction treatment technologies. Had these cleanups been working on PFP terms from their outset rather than on T&M terms, the state says these costs would have been avoided. For additional information on Oklahoma's adoption of a PFP cleanup program, please refer to LUSTLine, No. 36, "After Some PFP Growing Pains Oklahomans Realize PFP Benefits (PDF)" (3 pp, 52K, About PDF), by Richard McKay, Oklahoma Corporate Commission.

Implement PFP At New Cleanup Sites

New cleanup sites may offer simpler opportunities to start up a PFP program if funding is available. It is best to rule out especially difficult sites such as those where the source is both unknown and uncontrolled - establishing contamination reduction goals for these sites would be nearly impossible. New cleanup sites with strong site characterizations are good candidate sites for piloting PFP contracting. These site characterizations should be recent enough that site characteristics can be presumed to be fundamentally unchanged.

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Will staff roles change as PFP is implemented?

The role of the state project manager may shift under a PFP contract, especially in terms of contamination reduction monitoring. In addition to preparing and reviewing risk assessment and site characterizations for new PFP cleanups, project managers must also review site reports and confer with the cleanup contractor if contamination reduction stalls. Project managers must confirm monitoring results and approve the contamination reduction milestone reports.

The role of the state fund staff may also change under PFP contracts. The state fund staff must earmark the money for signed PFP contracts to ensure availability of payments. The state fund staff (or whoever is approving payment for the cleanup) will have less paperwork to review, and the review time will quicken. The need for oversight of time and materials billing (multiple invoices) by contractors is eliminated, as well as staff time needed to sort, file, review, cross check, and resolve disputes about the way in which the contractor is managing the business aspects of a cleanup.

 

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