Coverage Evaluation and Damage Assessment
Coverage first, then dollars
Evaluate coverage before valuing damage, and keep the two decisions separate in the file. The insured bears the burden of showing a loss within the insuring agreement; the insurer bears the burden of proving an exclusion applies; the insured then bears the burden of proving an exception to that exclusion. Work the sequence: policy in force on the loss date (check the exact term and endorsements), insured or additional insured status, cause of loss, exclusions, conditions, then limits and deductibles. Concurrent causation questions - wind versus flood, long-term seepage versus a sudden pipe break - usually turn on anti-concurrent-causation wording and on cause-and-origin evidence.
Valuing the loss
Build a documented scope: quantities, unit prices, labor, materials, sales tax, overhead and profit where warranted, and code-required upgrades (ordinance or law). Depreciation must be explained, not asserted. Distinguish damaged from undamaged property, recoverable from non-recoverable depreciation, and track salvage and subrogation recoveries that reduce the net loss.
Traps: denying a claim because the amount is disputed - that is a payment disagreement, not a coverage denial; applying the wrong policy year; using ACV on an RCV policy without explaining the holdback; missing an endorsement that adds coverage; failing to cite the specific policy language in a coverage letter.
Rule of thumb: pay what is undisputed while the rest is investigated. Example: a $40,000 fire loss with a $5,000 coverage question about a detached shed. Issue $35,000 (less deductible) now, explain the $5,000 in writing with the policy language relied on, and supplement or deny later.