Method

Every engagement runs the same gated workflow. No gate is skipped for urgency; a late start narrows scope instead. The durable asset is the reviewable dataset, not a summary memo.

The gates

  1. Conflict and capacity check. Client, brands, affiliates, and referral partner confirmed; configuration count estimated; deadline checked against supplier outreach, measurement, review, and certification time.
  2. Contract and authority. Services agreement and data-handling terms signed. Who owns producer/exemption determinations — client or counsel — is recorded in writing. No supplier contact or portal access without permission.
  3. Scope screen. Per state: legal entity, candidate producer, channels, revenue and tonnage inputs with the required geographic basis, covered/excluded assumptions, prior filings and invoices, assignment documents. No “not applicable” without evidence and a named reviewer.
  4. Source inventory. SKU exports, state-level units, specs, drawings, declarations, prior reports, co-packer and 3PL packaging, change history, samples. Every source file hashed or uniquely identified; originals never overwritten.
  5. Normalize and resolve gaps. SKUs grouped into identical packaging configurations, split on any mid-year change. Supplier specs preferred; structured supplier request for missing attributes; measurement only where documents cannot be obtained or need validation.
  6. State mapping. Each component mapped to each state's current category with the exact rule/category version and rationale recorded. Ambiguous composites, coatings, labels, tiny components, exclusions, and producer identity escalated — never silently decided.
  7. Calculation and QA. Two reconciliations (mass and commercial), then an independent recalculation sampling top components by fee and mass, all overrides, all low/medium-confidence items, and every exemption, credit, bonus, and malus.
  8. Client approval and filing. Sign-off pack with entities, states, totals, schedule status, assumptions, exclusions, and variance. Explicit written approval required. Receipts and uploads archived.
  9. Close and maintain. Source archive, dataset, filing package, and change log delivered. Quarterly change requests scheduled; temporary copies deleted per retention policy.

Evidence hierarchy

Strongest first. The bottom two levels require review and never silently become facts:

  1. Current supplier specification or signed declaration, tied to the exact part/version
  2. Technical drawing, certificate, or bill of materials
  3. Client ERP/PLM record with owner and effective date
  4. Calibrated physical measurement with documented sampling
  5. Purchase-order or invoice inference
  6. Visual / resin-code inference (review required)
  7. Undocumented assumption (review required)

Components are flagged green (direct evidence), amber (measured or inferred, review required), or red (missing, conflicting, or unresolved). No filing with red items unless the client and appropriate adviser approve a documented method.

Estimate labels

Every fee result carries exactly one label:

All outputs show jurisdiction, data year, program year, schedule publication and retrieval dates, assumptions, low-confidence components, and “not a quote from the state or PRO.” Rates are never edited in place — a change creates a new version with source, dates, status, changed rows, affected calculations, and reviewer.

Capacity policy

First three pilots capped at 75 unique configurations each; no more than two overlapping full-data builds until cycle time is measured; normal intake cutoff at least 10 weeks before filing. In deadline weeks, delivery and QA take priority over outbound.