COMMERCIAL INSURANCE · FRISCO, TX
Utility MSA Checklist: Why Your COI Was Rejected and How to Fix It NOW!
The job is yours, but the ISNetworld® compliance officer says “No.” Here is the exact checklist to clear the insurance hurdle and get your crew on site.
TL;DR FOR BUSY PEOPLE
You probably used a standard “box-checker” agent who sent a basic ACORD 25 form. Utility giants like Oncor, CoServ, or Atmos require specific endorsements (CG 20 10 + CG 20 37), a Waiver of Subrogation, and Primary/Non-Contributory language. If you don’t have these specific forms attached, you don’t get paid. Period.
FAST ANSWER
- The #1 Reason for Rejection: Missing “Completed Operations” coverage (CG 20 37) for the Additional Insured.
- The “Texas Trap”: Failing to include a Waiver of Subrogation in favor of the certificate holder.
- The Fix: You cannot just “edit” the COI. You must endorse the actual policy. This costs money, but it costs less than losing the contract.
The “Gatekeeper” Won’t Let You Mobilize
You bid the job. You won the job. You’ve got trucks idling in Frisco and crews ready to work on the expanding North Texas grid. Then, you get the email from ISNetworld®, Veriforce®, or a safety coordinator named “Compliance.”
“COI Rejected. Please revise and resubmit.”
This isn’t just bureaucracy; it’s a financial firewall. Large entities in Texas—whether it’s municipal infrastructure or private utility expansion—transfer 100% of their risk to you. If your insurance paperwork (the Master Service Agreement or MSA) doesn’t perfectly reflect that risk transfer, you are a liability, not an asset.
Stop trying to argue with the compliance officer. They are following a script. You need to speak their language. Here is the translation.
The “Big 3” Rejection Reasons
If your Certificate of Insurance (COI) was kicked back, it is almost certainly one of these three missing endorsements on your general liability insurance policy.
1. Additional Insured: Ongoing vs. Completed Operations
Most cheap policies only give you “Ongoing Operations” coverage (Form CG 20 10). This covers the utility company while you are physically on-site turning wrenches.
The Rejection: The MSA requires coverage for after you leave. If your wiring causes a fire two years later, they want to be covered on your policy. This requires the CG 20 37 (Completed Operations) endorsement. If your agent didn’t include it, you are out of compliance.
2. Primary and Non-Contributory
This is a mouthful, but it means this: If there is a lawsuit, your insurance pays first (Primary), and the utility company’s insurance pays nothing (Non-Contributory). Without this specific language endorsed on your policy, the certificate holder will reject your COI immediately.
3. Waiver of Subrogation
We wrote a deep dive on the Waiver of Subrogation here, but the short version is this: You are waiving your insurance carrier’s right to sue the utility company to get their money back after a claim. In Texas, this is standard operating procedure for any serious contract.
The “Action Over” Exclusion Trap
This is the “Widowmaker” of insurance policies. Many budget insurance carriers will slip an “Action Over” exclusion into your policy to save money on premiums.
Here is the nightmare scenario: One of your employees gets hurt on the job site. They collect Workers’ Compensation, but then they decide to sue the Utility Company (the General Contractor) for negligence. The Utility Company then turns to you to defend them (because of the Indemnity agreement in the MSA).
If you have an “Action Over” exclusion, your insurance company will deny the claim, leaving you to pay for the Utility Company’s legal defense out of your own pocket. This is why we check for Action-Over Exclusions in every audit we perform. If you have this exclusion, most major Texas general contractors will ban you from the site.
The Utility MSA Checklist
Before you sign the contract or submit your COI, run your policy against this checklist. This is what the gatekeepers at ISNetworld® and the Texas Department of Insurance standards generally align with for high-risk work.
| Coverage Line | Standard Requirement |
|---|---|
| General Liability | $1M Per Occurrence / $2M Aggregate |
| Additional Insured | Must include CG 20 10 AND CG 20 37 (or equivalent) |
| Commercial Auto | $1M Combined Single Limit (CSL) |
| Workers Comp | Statutory Limits + Waiver of Subrogation |
| Umbrella / Excess | Usually $1M to $5M depending on project size |
| Endorsements | Primary & Non-Contributory + Waiver of Subrogation on ALL lines |
The Agent’s Office® Advantage
Most agents just sell you a policy and hope it works. We operate differently. We act as your fractional Risk Manager.
When you work with us, we ask for the MSA before we quote. We read the “Insurance Requirements” section (usually Exhibit C or Article 11) and we build the policy to match the contract.
Don’t let a $200 endorsement cost you a $200,000 contract. If you are stuck in “Compliance Purgatory,” send us your MSA and your rejected COI. We can usually diagnose the problem in 10 minutes.
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FAQs about Utility MSA Requirements
What is form CG 20 10 vs CG 20 37?
CG 20 10 covers “ongoing operations” (while you are working). CG 20 37 covers “completed operations” (after you finish). Utility MSAs almost always require BOTH. If you only have one, your COI will be rejected.
Why does my umbrella policy need to “follow form”?
“Follow form” means your Umbrella policy adopts the same terms (like waivers and additional insured status) as your underlying General Liability policy. If it doesn’t “follow form,” there is a gap in coverage that large contractors will not accept.
Can I just handwrite the “Additional Insured” on the COI?
Absolutely not. A COI is just a piece of paper; it conveys no rights. Unless the policy itself is endorsed to add the entity, writing it on the certificate is fraud. We ensure the policy matches the paper.
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George Azide
LOCAL, INDEPENDENT AGENCY
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