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Welcome to our newsletter! You will find important updates and industry related news, along with upcoming speaking events and educational opportunities. Thank you for your interest in CCMI.

Deborah Wilder
CCMI President 


DOL Protocol for Approving Self-Funded Benefits

With the new updates to the federal Davis Bacon regulations, employers who want to claim fringe benefit credit for self-funded benefits must first obtain approval from the U.S. Department of Labor (DOL). Once approval is obtained, it is valid for all projects moving forward. For example: If a company does not make a contribution for vacation and holiday to a third party plan and instead keeps that calculation “on the books” to be paid at a later date, the DOL requires proof of the following:

  • Written policy which details the holidays to be paid;
  • Written policy as to how vacation is accrued;
  • Vacation must accrue on an ongoing basis and cannot be forfeited;
  • A record of accrued vacation has to be kept as part of the company records. Many companies merely list accrued vacation on the employee’s pay stub;
  • Vacation cannot be capped; and
  • Vacation and holiday must be amortized:
  • Total number of hours accrued per year X RRP (the employee’s regular rate of pay when that holiday or vacation is paid) ÷ 2080 hours = per hour rate for fringe benefits credit

Additionally, the DOL will ask for a copy of the company’s federal Sick Pay policy. While this policy only applies to direct Davis Bacon contracts, a company needs to establish, at minimum, sick pay for any employees who work on direct Davis Bacon projects. (contract is between the US Dept of XXX and the prime contractor as opposed to federal funding being funneled through a state or local agency). This policy covers not just those individuals who are performing trade work on the project, but also any other administrative employee who spend 20% or more of their time (8 hours out of a 40 hour workweek) providing supportive services relating to the project. This would be individuals performing payroll, CPRs or contract administration among others.


Upcoming Training:

WCOE California June 17-18 Napa, California Deborah will be leading a workshop on updates to California and Federal Prevailing Wage Compliance on Tuesday morning 2024 Annual Conference — WCOE California

CSDA Annual Meeting September 9-11 Deborah will be conducting a workshop on California Prevailing Wage Checklistwww.csda.net to register

If you need more training, Deborah Wilder is the presenter on the LCPtracker Academy Prevailing wage workshops. Go to www.LCPtracker.com and select the education tab.

Want to schedule your own prevailing wage workshop?

We will customize a workshop or webinar for you and your Agency/Account. Contact us at: info@ccmilcp.com 

What Every Contractor Should Know About Prevailing Wages, 3rd Edition.
Available through www.ccmilcp.com $45 inclusive of tax and shipping.
FROM THE INBOX....You asked, we answered!


Why does the California Department of Industrial Relations (DIR) NOT adopt all parts of a collective bargaining agreement into the Scope of Work?



Recently a contractor, who was union signatory, was confused over various trade classifications being required by the DIR. His Collective Bargaining Agreement (CBA) allowed the Laborers to perform far more than what the DIR had adopted in its published scope of work. The CBA also allowed for the Laborers to perform “incidental work” that might otherwise be claimed by another trade such as touch up painting or plumbing work, but the DIR's Laborer scope of work did not include "incidental work".

The DIR has taken the position that they may adopt some or all of a particular scope of work fromm a CBA. If they do not adopt a particular task as being within the scope of work, that is because the DIR did not find that task to be “prevailing” for that trade. So, while a Laborer can lay pipe, in most instances they may not “connect” the piping. That work would belong to a Plumber/Pipefitter. 


If more than one trade is listed by the DIR as claiming the work, then the contractor can classify and pay the worker in either trade classification.

Feel free to send your questions to info@ccmilcp.com
CCMI is not just another firm....

We are not merely a "consulting" firm, but rather a team of individuals who understand the needs of the Public Entity and contractors to "get the project done." Our staff includes retired contractors, auditors, attorneys and industry veterans.
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