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 


Let's Get This Right: Even though I have written about this topic before, there still seems to be a lot of confusion over California's mandatory labor compliance for public agencies. So, in an abundance of caution, let's take another look at these requirements:

Filing a PWC-100: An Agency must file a PWC-100 within 30 days of contract award, BUT NOT LATER THAN the first day worked on the project (some exceptions for emergency work- see the October newsletter for details). The DIR can fine the agency $100 for each day you are late in filing the PWC-100. This applies to all projects over $15,000 for maintenance and over $25,000 for demolition or construction.

Contractor Registration: This seems to be a big problem for many agencies. ALL entities (sole proprietors, partners, corporations, etc.) who are performing prevailing wage work on your project MUST be registered as a public works contractor. This includes: the contractor, subcontractor, sub tiered subcontractors, including: surveyors, inspections, material testing companies, concrete delivery companies, temporary service providers who employ and dispatch workers to the jobsite...essentially everyone who must pay prevailing wage to themselves or their employees. The fine is $100 a day for every day an Agency allows an unregistered contractor to work on the project. That fine also applies to the unregistered contractor and to the prime contractor. Registration applies to any contract where the total value of that contract equals or exceeds $15,000 for maintenance or $25,000 for demolition or construction.

Prevailing Wage Threshold is Still $1,000: Even though a PWC-100 form and contractor registration is not required on projects under $15,000 for maintenance and under $25,000 for demolition or construction, remember that prevailing wages are still triggered at $1,000. An on-call maintenance contract with a NTE price of $5,000 still requires the payment of prevailing wages..

A Note to Contractors: CCMI suspects the Department of Industrial Relations will more quickly fine a contractor who has an unregistered subcontractor on the project, than an agency. So, it is important that you check the contractor registration status of all subcontractors and impress upon those subcontractors that any sub-tier subcontractor MUST be registered as a public works contractor BEFORE they set foot on the project.


CSDA Prevailing Wage Update for Public Agencies: January 9th webinar. Contact www.csda.net for more information and to register.

CSDA Prevailing Wage 3 Pack Workshop: April 16th in Sacramento, Prevailing Wage Basics for Agencies; David Bacon Funded Projects; and, Auditing Your Own Agency Project for Prevailing Wage Compliance. Contact   www.csda.net for more information and to register.

Want to schedule your own prevailing wage workshop? We will customize a workshop or webinar for you and your Agency/Company. Contact us at: info@ccmilcp.com 

You asked, we answered!

What do I do if a subcontractor on my project did not file a DAS-140 or DAS-142?

While DAS-140 and DAS-142 forms are required for all contractors and subcontractors employing an apprenticeable trade on projects over $30,000, many times a lower tiered subcontractor will not do this. The good news is there is a way for a prime contractor to avoid any penalty for non-compliance. There is a safe harbor exemption that will apply if you can meet these requirements :
1) Contract clauses: You included the mandatory safe harbor language in your contract;
2) You collected the certified payroll and reviewed it while the project was ongoing;  
3) You told the contractor to file the DAS-140 and DAS-142 (maybe more than once)
If you can document these steps, a prime contractor will not be assessed apprenticeship penalties. The DIR will go after the offending subcontractor only. The Awarding Agency has no authority to access penalties due to an apprenticeship violation. The Agency's only recourse is to report the violation to the DIR.

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.