Before Insurance Appraisal:
Know the Dispute.
Prepare the Record.

Your insurer’s estimate and your contractor’s estimate may describe the same building but reach very different conclusions. Before focusing on the gap between the totals, identify what is actually driving it.

Are the estimates using different quantities or repair methods? Is damage missing from one estimate? Or is the insurer saying that part of the loss is outside the policy’s coverage? Those questions help frame a more useful discussion about whether appraisal is the right next step.

This guide provides a starting point for that discussion. The policy language and the facts of the claim control the analysis.

Start With the Difference Between Value and Coverage

Appraisal provisions commonly address disagreements about property value or the amount of a loss. They should not be assumed to resolve every disagreement about whether the policy covers a claim. The scope of a particular appraisal depends on its policy language and applicable law.

Make a short list of the disputed items. For each one, record the insurer’s stated position, your supporting documents, and the question you need answered. Keep a disagreement about repair pricing separate from a letter asserting an exclusion, even if both affect the same damaged roof.

Ask About the Appraiser Before Making the Selection

Read the actual qualifications in the appraisal clause. Do not assume that someone who helped prepare the claim automatically satisfies the policy’s requirements for an appraiser.

Useful questions to bring to a coverage consultation include:

• What does this policy require of an appraiser?
• What prior work or relationships should be disclosed?
• How will fees be calculated, and is the arrangement documented?
• What is the process for selecting an umpire if one is needed?
• Who will receive correspondence and maintain the appraisal record?

Clarifying these matters early can reveal issues that deserve attention before the process advances. A familiar professional and an appropriate appraiser are not necessarily the same thing.

A Court Decision Shows Why Timing Deserves Attention

In Biscayne Beach Club Condominium Association v. Westchester Surplus Lines Insurance Company, the Eleventh Circuit affirmed a decision against an insurer that waited until after an award to object to an appraiser’s alleged partiality, despite learning of the issue earlier. The August 6, 2024 opinion turned on waiver; the court did not reach the insurer’s other arguments. Read the opinion [PDF]

The practical takeaway is to bring a known concern to counsel promptly and preserve the correspondence. The decision is not a promise that every award will survive a challenge or that every late objection has the same result.

Build a File Someone Else Can Follow

Use this checklist to organize materials for an initial review. Check items as you gather them; nothing is uploaded or sent to the firm.

0 of 6 items gathered

Keep the Award and Payment Questions Separate

If an award is issued, keep the signed document with the claim file and review it alongside the insurer’s response. Ask counsel which issues the award resolved and whether any coverage questions, deductions, or other disputes remain. Avoid treating an award figure as a guaranteed net payment.

Continue organizing the file through this stage. An accurate record of what was decided, what was paid, and what remains disputed makes the next conversation more productive.

Questions to Bring to a Coverage Consultation