TPAs Steer Mitigation. Independents Inherit the Rebuild.

Inspired by Brandon Cooper (@hmmcooper), on TPAs steering assignments away from independents — 2 September 2026. This is an operator brief, not a reprint of his reply and not a reprint of our TPA application playbook.

The assignment is the job. Cooper’s point is not “mold is cash.” That part is old. The point is who gets called while the floor is still wet. Adjusters now sit behind TPAs. TPAs are not licensed the way an adjuster is licensed. They route work. Nationals with back-end deals get mitigation. Independents show up when the building is dry and the rebuild estimate is already a fight.

Mitigation is the days that set Category, Class, equipment, and the photo set. Rebuild is the months that argue unit cost. If you only inherit the second, you inherited the worst clock from the crew-week brief and none of the first-loss relationship.

What steering looks like on a commercial file

  • The FM calls the carrier because the lease or the lender said to.
  • The TPA dispatches “their” vendor. That vendor is often a national with a program rate and a SLA on paper.
  • You hear about the loss when a tenant wants a rebuild bid, or when the national wants a local to finish what they scoped thin.
  • The moisture map, the demo list, and the first photos already exist — in someone else’s system. Your estimate is now a supplement to their story.

That is not a sales problem. That is a door problem. The panel playbook tells you how to apply and when to walk. This page is what to do so the TPA is overflow, not the receptionist.

Keep first-loss without living on the panel

  1. Own the call sheet. An ERA with a named activator and an NTE means the FM does not have to wait for a TPA ticket to extract water.
  2. Say it in the ERA: emergency mitigation is owner-directed. The carrier and TPA may be notified. They do not pick the first truck if the building already signed you.
  3. Document as if you will lose the rebuild. If a national still gets reconstruction, your moisture map and photo set are what the FM uses to keep you on the next loss. The record stays.
  4. Do not take rebuild-only from a steered mitigation unless you re-open Category, Class, and demo with your own readings. Their thin scope is now your liability.
  5. Cap program revenue. 25–40% mix. If the TPA is the only way work arrives, they already steered your company, not just the file.
  6. Cash and specialty still skip the desk. Mold with weak coverage, document rooms, medical, electronics — the FM chooses you because the panel vendor does not live in those rooms. See the five rooms.

What you tell the FM

If the first person on site works for the TPA’s list, you will get a drying story written to a program rate. If we are on the ERA, we dry on your authorization and hand you a file the carrier can pay. You can still use their panel vendor for overflow. You should not use them as the only person who has ever walked your riser.

Questions

Should we refuse every TPA dispatch?
No. Refuse the ones that give you rebuild after someone else billed the wet days, unless you can re-scope from readings you took. Overflow is fine. Inheritance is how margin dies. Run it through job costing.

Is “just rank for mold” the fix?
It is a cash lane. It is not a commercial account. FMs do not build a vendor list from a mold keyword. They sign an ERA. Use mold as retail. Use the walk and the packet for the building.

Are TPAs illegal for steering?
This page is operations, not a lawsuit. Cooper is right that the incentive is the assignment. Your counter is a signed door, not a thread.

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The Vault has the ERA kit and the TPA fast-track. First-loss lives in the contract. The panel fills the gaps. One email. No sales call.

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