A contractor must prove that a government change order caused the costs for which it is claiming. Cases have stipulated that the contractor need not prove the costs with "absolute certainty or mathematical exactitude" but a "reasonable basis for computation, even though the result is approximate" is acceptable. Still, the contractor has the burden of establishing the basic facts of their claim when an upward adjustment is sought while the government has the burden for a downward adjustment.

Directly Related Costs Method. When a change order has been performed and actual costs incurred, the preferred method for establishing the amount due is actual cost data for the changed work. Ideally, contractors should establish separate work orders for the change and be able to segregate costs incurred as a result of the change. In practice, contractors’ accounting records frequently do not segregate costs for the changes, especially when costs are cumulative and overlapping. When this is the case, the contractor should be prepared to show the basis of its estimates by a description of the method used, evidence of its validity and substantiation of its calculations. Expert advise may be advantageous.

The Total Cost Method. The total cost method measures the difference between the contractor’s bid price on the original contract and the actual cost of performing the contract as changed. The government has voiced significant objections to this method because it can allow for recovery of costs having nothing to do with the changes. For example, the original contract price might be distorted because the contractor under bid the contract or the adjustment may be excessive due to the contractor’s inefficiencies. A case (WRB Corporation VS US) has established four criteria that must be met to use the total cost method:

1. The nature of the losses make it impossible or highly impracticable to determine with a degree of accuracy. The total cost method is not to be used if there are available other methods of proof such as credible expert opinion on the actual cost impact of the change, the contractor has a basis to know what costs are being incurred along with the accounting tools to segregate the costs or when there is sufficient data available to allow a reasonable estimation.

2. The original bid is realistic. If it was too low, the contractor obtains a windfall profit. A contractor can demonstrate the bid was reasonable if it was similar to other bids received by the government, close to the government’s pre-award estimate or there is expert testimony the estimating technique was reasonable and accurate.

3. Actual costs for the changed work is reasonable

4. The contractor is not responsible for added expense. Both Nos. 3 and 4 may be satisfied by demonstrating the work was accomplished in a normal, efficient manner and there were not unrelated events contributing to the cost incurred.

"Jury Verdict". Like the total cost approach, the jury method of measuring EAs is used only when more exact methods of calculation of actual costs cannot be made. The Board or arbitrator might, on an imprecise basis, decide the amount to be paid typically using averages or percentages of computed amounts and then use discount percentages or other offsets to arrive at a "fair" number. Cases have held (1) there must be proof of injury (2) no more reliable methods for computing damages exist and (3) there is sufficient evidence for a court to make a fair approximation. The jury method is not to be used when there is a failure of proof by the contractor that prevents a reasonable degree of accuracy. Absence of cost estimation data on the original bid has been held to void the jury verdict method resulting in no adjustment for the contractor.

Modified Total Cost Method.This is the same as the total cost method except adjustments are made to the original contract price or to actual costs to overcome a contention they are understated or overstated. An underbid, for example, would be adjusted upwards and the total costs incurred would be reduced to adjust for costs not attributable to the change in question.

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