On a large job, instead of every sub bringing its own liability and workers’ comp, one party buys a program that covers everyone who enrolls. The owner runs an OCIP; the general contractor runs a CCIP. If you’re enrolled, you take your cost for those coverages out of your bid and ask your insurer to make your own policies excess over the wrap-up for on-site work. You still carry your own auto, equipment and off-site coverage. The part contractors miss: your own general liability may get an endorsement excluding that project, completed work included, and the wrap-up’s completed operations coverage eventually ends. Read the program’s insurance manual before you price the job.
OCIP vs. CCIP
IRMI defines an owner-controlled insurance program (OCIP) as a centralized program arranged and controlled by a project owner to cover eligible contractors and subcontractors working on a specific project or group of projects. A contractor-controlled program (CCIP) works the same way, but the contractor is the sponsor: an IRMI article describes that sponsor as usually a construction manager at risk, a general contractor or a prime contractor, the party in direct contract with the trade contractors.
Per IRMI, cost-focused programs usually include workers’ compensation and general liability, consistency-focused ones often wrap only general liability in primary and excess layers, and some add professional or pollution liability. On the public OCIPs I’ve read, each enrolled contractor gets its own workers’ comp policy, everyone shares one general liability policy and one set of limits, and the program administrator issues the certificate.
What the wrap-up usually leaves to you
A wrap-up insures work at the project site. The public OCIP manuals I’ve read spell out the gaps:
- Off-site work. Your shop, yard and off-site fabrication are outside the program unless, as on the Wisconsin DOT program, an off-site location dedicated solely to the project is endorsed on. You keep your own workers’ comp, general liability and excess for it.
- Vehicles. Both public OCIPs I read say flatly that they provide no automobile coverage. Enrolled contractors carry their own commercial auto on and off the site.
- Tools and equipment. Owned, leased, rented and borrowed equipment, tools and scaffolding stay yours to insure, for example under a contractor’s equipment floater.
- Professional liability. The New Jersey program lists contractors professional liability among its general liability and excess exclusions, and requires design-builders to carry their own.
- Excluded parties. Both public programs exclude truckers, haulers, vendors and suppliers who only deliver, hazardous materials firms, and subs who do no work on the site. They insure all their own work.
IRMI adds that contractors generally remain responsible for required deductibles and retentions. Both programs also want a certificate for the coverage you keep, with additional insured status and a waiver of subrogation.
Enrollment and taking insurance out of your bid
Enrollment is required but not automatic. On the Wisconsin DOT highway OCIP I read, contractors had to submit enrollment forms before mobilizing, weren’t allowed on site until enrollment was complete, and the coverage applied only to work after their enrollment date.
Enrolled contractors have to remove the cost of the coverage the sponsor provides from their bid and from change orders, and the contractor is responsible for making sure subs of every tier do the same. The New Jersey manual spells it out: leave out your on-site workers’ comp, employer’s liability and general liability primary and excess cost, and have your insurer make your own policies excess and contingent over the wrap-up for on-site work. Excluded subs price their insurance in as usual.
The wrap-up exclusion on your own GL
Since the wrap-up is insuring your work on that project, the program expects your own insurer to be told so it can add an endorsement and avoid covering the same job twice. The ISO form is CG 21 54, Exclusion: Designated Operations Covered by a Consolidated (Wrap-Up) Insurance Program. It applies to the project locations listed in its schedule and excludes both your ongoing operations and your completed operations there.
The completed operations part is what matters later. Because CG 21 54 excludes your completed work on that project, your own general liability isn’t designed to answer a claim about it after the job closes; the wrap-up’s completed operations coverage is. IRMI notes that a different form, CG 21 53, can exclude only your ongoing operations on a wrap-up job and keep completed operations in place, because most wrap-up programs provide only limited completed operations coverage. Whether your insurer will is an underwriting question.
How long completed operations lasts
It depends on the program. A 2005 IRMI article on CCIPs describes completed operations coverage as typically running 3 years beyond the construction period. Some public OCIPs go longer: the Wisconsin DOT and New Jersey school programs each carry a ten-year products and completed operations extension under a single limit that does not reinstate each year.
State rules vary
Some states write conditions for wrap-ups into statute. Examples:
- North Carolina state public works. G.S. 58-31-65 lets the Office of the State Fire Marshal use a wrap-up on a public works project or group of projects over $50 million, with at least three years of completed operations coverage, coverage and safety requirements stated in the bid specs, contractors free to buy more insurance, and any deductible or self-insured retention capped at $1 million.
- California state public works. Government Code 4420.8 lets a state agency use a wrap-up only on public works projects over $125 million, with similar conditions: at least three years of completed operations coverage, coverage and safety requirements stated in the bid specs, no ban on buying more coverage, and no surety insurance.
- California private residential. For projects that began construction after January 1, 2009, Civil Code 2782.95 requires the owner, builder or general contractor obtaining the wrap-up to state in the contract documents the amount, or how it’s calculated, of any premium credit or compensation required from a sub, plus, to the extent known, the policy limits, scope, term and a good-faith estimate of remaining limits.
- California workers’ comp. Insurance Code 11751.82 requires a wrap-up insurer to report each contractor’s and sub’s workers’ comp losses and payroll to its rating organization and provide copies of the report within 10 days of a request.
Common questions
What’s the difference between an OCIP and a CCIP?
Who sponsors it. The project owner buys and controls an OCIP; a general contractor, construction manager at risk or prime contractor buys and controls a CCIP.
Does a wrap-up cover my trucks?
Generally no. The public programs I’ve read leave automobile liability out entirely and require each contractor to carry its own commercial auto.
Do I still need my own general liability if I’m enrolled?
Yes. You need it for off-site work, your other jobs and anything the program excludes, and the public programs I’ve read ask for proof of it before you mobilize.
What happens after the wrap-up’s completed operations coverage ends?
CG 21 54 excludes your completed work on that project, so your own policy isn’t designed to pick it up. That’s why it pays to know the program’s completed operations term and to ask whether your insurer will exclude only ongoing operations instead (CG 21 53).
Do I have to take insurance costs out of my bid?
If you’re enrolled, yes, for the coverages the program provides, and from change orders too. Excluded subs, such as haulers and suppliers, price their own insurance in as usual.
Sources
- IRMI: owner-controlled insurance program (OCIP) definition
- IRMI: controlled insurance program (CIP) definition
- IRMI: designated operations exclusion endorsement definition (CG 21 53, CG 21 54)
- IRMI (Richard Resnick, January 2005): Have You Thought About a Contractor-Controlled Insurance Program?
- Rough Notes (Donald S. Malecki, November 2008): Risk Management—A necessary evil (CG 21 54)
- Rough Notes (Donald S. Malecki, April 2002): Wrap-Up Programs—A Pandora's Box of Complexities
- Wisconsin DOT: USH 41 Corridor Project OCIP Insurance Manual (2-12-09)
- New Jersey Schools Development Authority: OCIP V Insurance Manual (12/1/2024)
- North Carolina G.S. 58-31-65: Owner-controlled or wrap-up insurance authorized (as amended by S.L. 2024-1)
- California Government Code 4420.8: state agency owner-controlled or wrap-up insurance programs
- California Civil Code 2782.95: private residential wrap-up disclosures
- California Insurance Code 11751.82: wrap-up workers’ comp loss and payroll reporting
General information about owner- and contractor-controlled (wrap-up) insurance programs as of October 2026, not legal advice; each program’s insurance manual and policies, your own policy’s endorsements and state law control. Coverage depends on underwriting and the terms, conditions and exclusions of the policy actually issued.