The success of an energy efficiency program should be measured in terms of the actual energy savings, and not against "stipulated" or estimated energy savings. Although M&V guidelines and protocols have standardized methods for verifying energy savings accruing from the implementation of an energy efficiency project, M&V is largely viewed as a cost center rather than a value proposition. The jury may still be out on the real value of M&V because it is often perceived as very expensive and too technical. This paper will review measured energy savings data from the Texas LoanSTAR Program and analyze available data and program requirements of Federal and state performance contracting programs that require some level of M&V to verify energy savings. The intent is to determine the role of M&V in different programs and what implications it has on the success or failure of the programs. The paper concludes with suggestions to use M&V as a risk management tool wherein both the service provider and the customer have a vested interest to perform appropriate level of M&V to reduce uncertainty in energy savings in a cost effective manner.