Section 8.10 Guidance & Best Practice

Grant Administration: Section 8.10 Guidance & Best Practice

Installation Work
Construction, alteration, or repair work of more than $2,000 that is financed in whole or in part with CDBG or other federal funds, regardless of the CDBG amount will trigger Davis-Bacon wage rates for the project. Installation work does not require payment of Davis-Bacon wage rates if it involves only incidental construction work. The applicability also may depend on the location of the incidental work. Attachment 8-17: Construction versus Installation provides additional clarification regarding construction versus installation to help determine whether Davis-Bacon wage rates must be paid for the work performed.

Reference Guide
It is recommended that the grant administrator shares a copy of the Davis Bacon Labor Standards: Contractor’s Guide with the contractor (Attachment 8-2). This reference manual can be provided either at the pre-bidding conference (optional) or the pre-construction conference.

Labor Standards Documentation
While the following steps are not required, CDFA recommends them as best practices to facilitate labor standards compliance. If used, this documentation should be when conducting the Pre-Construction Conference.

• Have the contractor complete Attachment 8-18: Wage/Benefit Certification Form, listing each anticipated job classification and salary/wage rate anticipated to work on the project. This form also provides opportunity to document that a fringe benefit plan is bona fide DOL-approved benefit plan.
• Have contractor also provide a current employee roster, listing all persons currently employed prior to the start of the project. (See Attachment 8-19 Roster of Assigned Employees.) The contractor should update this roster as work progresses and employment hires are made.

This roster then can be used to cross check against future job opportunities for the project to determine completeness and accuracy of weekly payroll reports and if Section 3 hiring goals are being achieved. The roster is also helpful determining random selection of employees for interviews and assisting in paying back wages to workers if an employer fails to do so.

Interview Resource
When conducting interviews, administrators may choose to complete the Project Wage Rate Sheet found in HUD Form 4720. Attachment 8-20: Project Wage Rate Sheet (HUD Form 4720) provides a link to that form.This form will facilitate interview questions with workers and completion of the required Record of Employee Interview.