Not a laziness tactic.  Given that most of my calls are 60-90 minutes, the bulk of time with clients is spent having sex.  We may get under sheets if the person likes chatting and relaxing in between shots, but we are usually not inclined.

when I was at her location.  Shocked when it happened.  It usually never happens, mostly because its a hygiene thing.  When I hosted, always.

Most of the time it's on top but on a couple cold windy nights we got under the covers and generated a great deal of heat...

It doesn't matter if you're between the sheets or on top of them, but DON'T lie on top of the bedspread/comforter because they can be filthy.  Here's what HuffPo says:

"Remove the Comforter

Sheets and pillowcases: easy to wash. Bedspreads? Not so much. So some hotels just... don't. Even between guests. According to Reneta McCarthy, a former housekeeping manager for a major American hotel chain, it is possible that a hotel bedspread might only be changed four times a year. And you're not even safe with a duvet that has a removable cover: McCarthy says that if there is a top sheet between the duvet and the bed, the cover might not be washed between guests. So before you get into bed, take off the dirty bedspread!"

So unless you want to rub your naked bod on dozens of people's dried splooge, blood, feces and snot, ditch that bedspread.

but if it's their room, on top.

There are sometimes exceptions, like when doing an overnight

any of the providers I have seen got under the sheets-above the sheets 100% of the time.

of the sheets. I can only recall being between the sheets on an overnighter - and that was only when we were sleeping.

Love to be above the sheets! Covers just seem to get in the way to me. Lol

Not only do I not like being under the sheets, I prefer standing for BJs and doggie with her on a sofa, also prefer cowgirl on a sofa, also tough to flip into different positions with the sheets on top of us.....I notice some providers tend to try to avoid the sofa thing and get me to the bed

If anyone's seen that show, you may have seen when Anthony brings in a UV light and shines it on the bed spread, walls, and floors, the whole place glows with DNA. (lol - eww!)

At least the sheets are changed after each guest checks out - hopefully. So I would vote for under the sheets.