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CONSTRUCTION UNAPPROVED CHANGE ORDER RISK — THE FINANCIAL COST OF PROCEEDING WITHOUT APPROVAL.

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The construction industry norm is to proceed with directed work and sort out the change order later. In practice, “later” produces three outcomes: the change order gets disputed after the leverage window closes, the WIP is distorted by cost with no assigned revenue, and the pattern trains the GC to direct scope without creating documentation. All three outcomes reduce project margin. All three are preventable with a documentation discipline that takes five minutes per directed scope item and does not require stopping work.

The contractors who collect on their change orders are not the ones who fight harder at closeout. They are the ones who documented every directed scope item the day it was directed.

BY JOSH LUEBKERPublished: May 2026Updated: May 2026
THE FINANCIAL RISKS OF PROCEEDING WITHOUT APPROVAL

THREE SPECIFIC RISKS MOST CONTRACTORS DO NOT ACCOUNT FOR.

RISK 01 — MOST COMMON

The Work Gets Done and the Change Order Never Gets Approved

The most common outcome of proceeding with unapproved scope is that the work gets executed, the change order gets submitted after the fact, and the GC disputes it — claiming the scope was part of the base contract, that it was executed without authorization, or that the submitted amount is not supported by the documentation. The contractor has performed the work. The leverage to compel approval is gone. The change order becomes a negotiation from a position of weakness. In some cases it becomes a formal dispute. In others it gets written off. The cost was real. The recovery was partial or zero.

RISK 02

Unapproved Change Orders Distort WIP and Job Profitability

When unapproved change order work is coded to the base scope, the job cost for the base contract looks over budget. The change order cost has no revenue assigned to it. The WIP schedule shows the job as less profitable than it actually is — or shows a loss that would not exist if the change order were approved and billed. This WIP distortion affects surety underwriting, banking conversations, and the owner's strategic decisions about the project. An accurate WIP requires change order costs separated into dedicated cost codes, with the corresponding change order revenue tracked separately as a pending receivable.

RISK 03

Pattern of Unapproved Change Orders Creates a Relationship Problem

A contractor who consistently proceeds with directed work without securing written approval — even informally by email — trains the GC to direct scope changes verbally without creating documentation. The GC gets scope additions without formal commitment. The contractor incurs cost without contractual protection. Over time this dynamic produces a project closeout with $80,000–$200,000 in undocumented scope additions that the GC declines to pay because there is no paper trail. The relationship problem is not the GC — it is the contractor's documentation discipline.

HOW TO PROCEED SAFELY WITH DIRECTED SCOPE

THE NOTICE AND DOCUMENTATION PROCESS THAT PROTECTS YOU WITHOUT STOPPING WORK.

Written notice before proceeding: Same-day email to the GC PM: “We have been directed to perform [specific scope]. We will proceed under protest pending change order execution. Please confirm direction in writing.” Three sentences. This creates a paper trail without stopping work.
Dedicated change order cost code from day one: All directed scope goes to the change order cost code immediately. Not sorted out at month-end. Not coded to base scope because the change order code did not exist yet.
Change order submitted within 48 hours of direction: Not at month-end. Not after the work is complete. Within 48 hours of the verbal direction, a written change order with scope description and cost estimate is in the GC PM's inbox.
Follow-up at 14 days, escalation at 30: Unapproved at 14 days gets a written follow-up requesting status. Unapproved at 30 days gets a formal letter citing the contract provision for change order response time and reserving all rights.

The leverage window: Leverage exists before work starts. It is significant while work is in progress. It diminishes at completion. It is nearly zero 30 days after completion. Every day between direction and written notice is a day of lost leverage. The documentation discipline is not bureaucracy — it is the financial protection system for work that has already been deployed.

COMMON QUESTIONS

FREQUENTLY ASKED.

Send the email yourself. “As directed this morning, we will proceed with [scope]. Please confirm direction in writing at your earliest opportunity. We will submit a change order within 48 hours.” You have created a paper trail. The GC received written notice. The change order clock has started. The absence of a response to your email does not constitute approval, but it establishes that direction was given and that you notified the GC you were proceeding under protest.
Include all direct costs: labor hours at fully burdened rate, material quantities at current prices, equipment at daily operating cost, and any subcontract costs. Include overhead at the project overhead rate. Include markup at the bid markup rate. Do not under-estimate to make the change order “easier to approve.” An under-estimated change order that gets approved locks in reduced recovery. An accurately estimated change order that gets negotiated slightly lower still produces better recovery than one that was under-estimated from the start.
Yes. The weekly change order review is part of every CFOS engagement. Every directed scope item from the prior week is reviewed: has a written notice been sent, has a change order been submitted, what is the approval status. Unapproved items at 14 days get written follow-up. The change order log is part of every monthly cost-to-complete.
Josh Luebker
Josh Luebker
Fractional CFO · The Construction CFO

Former commercial construction project manager and master electrician. Managed 150+ projects totaling $300M+. Now fractional CFO for commercial subcontractors doing $1M–$12M. About Josh →  |  LinkedIn →

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