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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 


Davis Bacon Regulations- Part 2 of 2

Over 800 pages of regulations with many nuances. Here is our continuing update:

Wage Increases: DOL has determined that for wage determinations which are based on surveys and not union collective bargaining agreements, that the DOL may choose to increase those survey rates (up to 3%) as often as every three years without taking any additional survey. If DOL chooses to do this, they will update the wage rates in www.sam.gov. If the rates have not been updated, then the published rates at www.sam.gov will apply. There will not be any automatic increases on projects which have already been awarded - no matter the length of the project.

Conformances and Contracting Officers: The DOL has expanded the definition of “contracting officer” to include agencies and grant recipients who are not federal employees. The lack of a designated “contracting officer” created many conformances to be rejected or at least delayed until the issue of contracting officer was resolved. HUD for many years had its own conformance form for just this very reason. DOL likes uniformity and anticipated this change will allow SF1444 forms to be used for all conformances.

Fringe Benefits: Not many changes here. Contractors whose contributions are not already being calculated on a per hour basis are still required to amortize or annualize their monthly/quarterly contributions to a per hour rate. Typically this calculation is the monthly premium x 12 (months in a year) ÷ 2080 (work hours in a year). For pension contributions whether made to a union trust or to another ERISA approved plan will continue to be allowed. Individual pension plans, such as the Contractor’s Plan, will need to seek DOL approval for their plans. For contractors who provide vacation and holiday pay directly to workers and do not make the contribution to a third party plan, those benefits will still be allowed so long as there is 1) an enforceable written policy for the benefit; 2) the benefit is nonforfeitable (vacation pay is not forfeited if not used or if the employee leaves employment; and 3) those benefits are amortized/annualized. (Total number of holiday/vacation hours (accrued by the employee for the year) x RRP (the employee’s regular hourly rate of pay that will be received when the vacation or holiday is taken) ÷ 2080 hours (work hours in a year)).

While there are some additional smaller nuances in the new Davis Bacon regulations, CCMI believes we have hit the high points. Watch for CCMI’s updates to our books: What Every Contractor Should Know about Prevailing Wages and the Davis Bacon Handbook for Public Agencies, anticipated at the end of the year.


Upcoming Training:


October 3 - 4. LCPtracker SPARK Event Sacramento California. Deborah will be teaching a two hour deep dive into California Prevailing Wage compliance. To register, contact www.LCPtracker.com Look under Education, then Events.

October 5-7. NAHRO National Conference New Orleans. Deborah will be speaking on a panel with Ida Booker and Jade Banks on the new Davis Bacon Regulation. www.NAHRO.org

October 16. Humboldt Builder’s Exchange 6 hour deep dive course of California and federal prevailing wage requirements.


Remember 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!


I am working on a PLA project which includes work classifications that are not listed on the DIR or Davis Bacon wage determination, such as helper. I am being told that I cannot use the lower help rate. Why is that?



Many times wage rates on a project labor agreement (PLA) project are higher than the state or federal wage determination and then those higher rates will apply. However, if the PLA has wage classifications which are not contained in the state or federal wage rates or are helper classifications (which are less than the state or federal determination), you may not use and pay those lower rates. You must pay the higher state or federal rates which apply. Remember if there are sometimes limited allowance for helpers, many times there are footnotes or other restrictions, such as having a journeyman working before a helper is allowed on the project. In most instances helpers are not allowed unless specifically provide in the State and Federal wage determination.

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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