Just bare ground is fine. The heat bakes through so you don't get that slimey, wormey, bug-filled muck that you normally get from something on the ground. You get dead grass either way, but it won't be disgusting when you lift the panels up--it will be dry and baked. It will heat the ground around it, and that ground will go on heating the water after the sun passes, passing it back to the panel. Done this a couple of times.
Bookmarks