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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.

Sincerely,
Deborah Wilder
CCMI President 

WHAT'S NEW?    


SO MUCH GOING ON…


Revisions to California’s DIR Website


The California Department of Industrial Relations (DIR) has revised its website.

Contractors and agencies need to know that their registration and projects were not

carried over into the new system.

 

Agencies need to get a new user name and then input the PW Project number for each project so contractors can submit eCPR for those projects. The DIR has training videos to help Agencies understand the new changes.

 

Contractors- your registration is not showing up in this new system. Go onto the website

and select a new user name. You should be able to repopulate most of the information if

you have your ten-digit registration number from before. Also changes to uploading

eCPRs. The DIR has training videos you can access on their support page.

 

Do not forget that your registration renewal is due July 1 of this year.



Inflation Reduction Act- Final Regulations


Final regulations relating to prevailing wage requirements were published June 25, 2024. Here are a few highlights:


  • Federal Davis Bacon rates apply to the construction, alteration or repair of a qualifying facility. This includes;
  • ·Construction of the facility
  • Any part of the 10 year period after the facility is placed into service.


  • Prevailing wages are set based on the first day construction, alteration or repair of the facility applies.
  •  If construction starts June 1, 2024, then the wage determination which applies on that date will be enforceable for both the construction and the following 10 year period after the facility is placed into service
  • If there is no initial construction, but just maintenance and repair, then the first date that work starts will the determine the wage determination.
  • Wage determinations can be found at www.sam.gov


  • Not only does the Davis Bacon Act apply, but also the Copeland Anti Kickback Act and rules governing apprenticeship from the U.S. Department of Labor.



  • The Apprenticeship Requirement is 10%, 12.5% and 15% depending on when construction started on the project.
  • A project either needs to meet this requirement of apprenticeship employment; or
  • Request an apprentice from a DOL approved apprenticeship committee, obtain proof of delivery of the request; provide 5 days for the committee to refer an apprentice, and agree to any special requirements of the apprenticeship committee. If no apprentice is dispatched, then the contractor receives a waiver for that apprenticeship trade for 1 year.
  • Note: If you have apprentices you are currently using from a DOL approved program, you can reassign those apprentices to any of your IRA projects across the country and that apprentice still counts as a bona fide apprentice for that project even if they do not come from a local apprenticeship program.


  • There is no apprenticeship requirements for maintenance or repair to a facility, once construction is complete and the facility is placed in service.


These regulations go into effect August 26, 2024.

 

If you want to read the final regulations (90 pages) where you can see more information about compliance and tax credits, you can find it here:

 https://www.federalregister.gov/documents/2024/06/25/2024-13331/increased-amounts-of-credit-or-deduction-for-satisfying-certain-prevailing-wage-and-registered


UPCOMING SEMINARS AND SPEAKING OPPORTUNITIES


Upcoming Training:


Prevailing Wage and the Inflation Reduction Act. July 16, 2024 11:00 a.m. (1hour) Cost $79. Register by clicking this link.


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 

NEW BOOK UPDATE
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!

QUESTION:

Why am I asked for Collective Bargaining Agreements, Apprenticeship Standards Agreements and extra documentation when I am working on a federal funded prevailing wage project?


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ANSWER: 


Please note that federal prevailing wage compliance may have different requirements than any State prevailing wage requirements. Labor compliance is so much more than just certified payrolls (CPRs). In addition to CPRs, it is not unusual to be asked for some type of proof that fringe benefits have been paid (and properly amortized). If you are union signatory, your collective bargaining agreement (CBA) may have additional funds, terms or contributions that can be verified by reviewing the CPR compared to the CBA. Please remember that not everything in the CBA has been adopted by the U.S. DOL or a particular State Department of Labor. 

 

Apprenticeship Standards Agreements are necessary to confirm apprenticeship rates, fringe benefits, advancement level and journeyman to apprentice ratios. Apprenticeship certificates can be met in one of two ways depending on which state your project is located. In either case verification that the apprentice is enrolled in a bona fide program is required.

 

Also, an employee’s authorization for “other deductions” is required unless the deduction is one which is included in a CBA. This could be a garnishment, a court order or an independent agreement with the company.

 

The auditing agency or the US government typically asks for this documentation during an audit; so many labor compliance companies just collect them as part of the overall labor compliance process instead of trying to track those down after the project is finished.


Feel free to send your questions to info@ccmilcp.com
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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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