The Program Eligibility Check SOP

Purpose

To confirm, before any incentive is named in writing to a customer, that the job clears every eligibility dimension the program actually tests, and to capture the documentation the claim will need while the technician is still standing in front of the equipment. A claim that fails on eligibility is not a paperwork problem, it is a promise made against a job that never qualified. A claim that fails on documentation is usually a job that qualified perfectly and was written up from memory a week later.

Scope

Applies to every quote, estimate or work order where an incentive, rebate or credit is named to the customer in writing, on any program: utility, manufacturer, state or local energy office, or a federal tax provision. Applies whether the shop or the customer is the applicant of record.

Does not apply to midstream or upstream programs where the incentive is applied in distributor pricing and never reaches a customer application, because there is no claim to file. It also does not cover deciding whether a supplier rebate or loyalty program is worth enrolling in at all, which is a purchasing decision covered elsewhere.

Roles and responsibilities

One named person owns each row. A claim with no named owner at the coordinator row is the single most common way a program deadline passes unnoticed.

Procedure

1. Maintain the program registry, and re-verify it each season

Keep one record per program the shop participates in. Re-read the program's own posted terms at the start of each season and any time you hear of a change, and stamp the record with the read date. Each record holds:

• Administrator name and the exact program name.
• Reimbursement model: customer is applicant, shop is participating contractor of record, or instant discount at point of sale. This determines who gets paid and who a clawback lands on.
• Credential requirements on the shop: participating-contractor registration, license, insurance certificate on file, training completion. Note the expiry date of each.
• Pre-approval required before work begins: yes or no. Record this as an explicit Boolean, per program, not as a note.
• What date the deadline runs from: install date, invoice date, permit sign-off, or in-service date. Programs differ, and reading the wrong basis is how a shop misses a window it thought it had weeks left on.
• The documentation classes the program demands, listed by class rather than by file name.
• Funding basis: open enrollment, budgeted for a period, or first-come until committed.

An outdated registry record is worse than no record, because the estimator will trust it. If the read date is more than one season old, treat the record as unverified and re-read before quoting.

2. Run the check before the quote is issued, not after

The trigger is the moment an incentive is about to appear in writing. Running the check after the customer has seen a number is not a check, it is a search for confirmation, and it will find it.

3. Test all five eligibility dimensions

Programs test more than the equipment. Work all five, and record a pass, fail or unknown for each.

• Property. Type (single family, multi-family, rental, commercial), and whether the service address matches the utility account the incentive would be paid against. Rentals and multi-family units frequently sit on a different track with different requirements, or are excluded.
• Customer. Is the person signing the contract the account holder of record? Have they participated in this program within any stated lookback window? Is there an income-qualified track that would serve them better than the standard track, and does routing them there change the documentation set?
• Equipment. Does the proposed equipment appear on the program's qualifying list as of your read date, by the exact model designation? Capture the full model and serial numbers of both the installed and removed equipment, because several programs care about what came out.
• Installer. Is the shop's participating credential current, and is the technician performing the work covered by whatever certification the program requires? Check the expiry, not just the existence.
• Process. Pre-approval, permit, inspection sign-off, third-party verification, commissioning report with measured values. Each of these is a scope item that has to be priced and scheduled, not discovered at submission.

Any dimension marked unknown blocks the incentive block on the quote until it resolves. Quote the job without the incentive block and add it by revision once the unknown clears.

4. Stop at the pre-approval gate

If the registry record says pre-approval is required, no work begins until the written approval is in hand, and the approval's own expiry date goes on the job record and drives the schedule. Starting work first is not a recoverable error on most programs: the application is refused on its face because work preceded approval, and no appeal fixes a date.

5. Capture documentation at the job, not afterward

The technician does not leave the site until the capture list is complete. A typical list runs to photographs of the removed equipment data plate, the installed equipment data plate, the installed equipment in place, and the meter or account identifier where the program requires it, plus the commissioning values if a performance report is required.

If the data plate you need sits behind a cover on energized electrical equipment, the photo waits. Open the disconnect, apply your lock and tag, then verify the conductors are dead with a meter you have proved on a known live source immediately before and immediately after the test, which is the electrically safe work condition process in NFPA 70E-2021, 120.5. OSHA's requirement that circuits be de-energized and locked or tagged before employees work on or near exposed parts sits at 29 CFR 1910.333(b)(2) for general industry, with the construction counterpart for lockout and tagging of circuits at 29 CFR 1926.417. Nobody pulls a cover on live gear to get a rebate photograph.

6. Record the check, attach it to the job

The completed check record attaches to the job file with the estimator's name, the date, and the read date of the terms it was run against. This is what makes a later denial diagnosable: you can see what was true when the promise was made.

7. Submit inside the shop's own window and track it

The coordinator submits the complete package within 5 business days of the program's stated deadline-basis event, which is commissioning for some programs and completion or inspection close for others, so read the basis off the registry field rather than assuming, records the confirmation or reference number, and tracks the file until it pays or is denied. Tune the 5 days to the program you file with most, but publish the number internally so a missed window is visible as a missed commitment rather than as an ordinary delay.

8. Retain the claim file

Keep the full claim file, including the eligibility check, the submitted package and the outcome. The IRS's general rule is to keep records supporting an item of income, deduction or credit on a return until the period of limitations for that return expires, which is generally 3 years from the date the return was filed, with longer periods in specific situations such as a substantial understatement of income; IRS Publication 583 covers business recordkeeping. Program audit and clawback windows are set separately by the administrator and are stated in the participation agreement, so record that period in the registry too and retain to whichever is longer.

Worked example: a completed check record

Job: equipment replacement, single-family residence. Program: local utility efficiency program, terms read 4 days before the quote.

Four dimensions passed and one failed. The failure is the customer dimension, and it is a common one: the program pays against a utility account, and the person signing the contract is not the account holder.

The estimator's options were three. Route the claim through the tenant as applicant, with the owner's written consent, which the program's terms allowed on the rental track but which adds a consent document and extends the timeline. Check whether the program's income-qualified or rental-property track applies to this property, which carried a different documentation set. Or issue the quote with no incentive block at all and let the owner pursue it independently after the work.

The shop took the third option for the quote and the first option for the claim: the job was priced and sold with no incentive named in writing, and the coordinator worked the tenant-consent route afterward as an unpromised extra. When the consent document came back unsigned three weeks later, nothing about the sale, the price or the customer relationship was affected, because no incentive had ever been part of the deal.

Contrast the version where step 3 was skipped. The estimator checks the equipment against the qualifying list, sees a match, names an incentive in the quote, and the failure surfaces at submission. Now the owner has signed a contract in reliance on money that was never available to them, and the shop is explaining a rental-account rule it should have found before the quote went out.

The reconstruction cost, measured

One shop timed both paths across a season. Capturing the full documentation set at the job added about 0.3 field hours per install. Reconstructing it afterward from invoices, memory and the customer's photographs averaged about 2.0 office hours per file and still required a return visit on 1 in 5 files to photograph something nobody had captured.

Across 30 claims, that is 9.0 field hours spent at the job versus 60 office hours spent afterward plus 6 return visits. Do not compress that into a single multiple: field hours, office hours and return trips are three different costs staffed from three different places, and the honest comparison is the one stated in full.

References

• NFPA 70E, Standard for Electrical Safety in the Workplace, 120.5, process for establishing an electrically safe work condition
• 29 CFR 1910.333(b)(2), general industry lockout and tagging before work on or near exposed energized parts; 29 CFR 1926.417, construction lockout and tagging of circuits
• IRS Publication 583, Starting a Business and Keeping Records, on the period of limitations for retaining supporting records
• Program administrator's participation agreement and current posted terms, which are the authoritative source for eligibility, deadline basis and audit or clawback windows
• See related: How to Price a Job That May or May Not Carry an Incentive; The Rebate or Loyalty Program: Worth-It Decision Tree