4-Pre-Bid Orientation Prime Contractor Responsibilities Compliance Requirements for DBRACDBG Projects.pdf
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- Solicitation number
- 2026-01-RFB
- Issued by
- Salt Lake County, Salt Lake City, Utah
About this file
This is a Pre-Bid Orientation document issued by Salt Lake County Housing and Community Development outlining prime contractor responsibilities and compliance requirements for Davis-Bacon and Related Acts (DBRA) and Community Development Block Grant (CDBG) funded projects. The document applies to the Electronic Rolling Security Gate and Fencing Installation project at Volunteers of America, Utah Youth Resource Center in Salt Lake City, which requires furnishing and installation of a complete electronic rolling security gate system, access control pedestal, and perimeter fencing for the staff parking lot. A mandatory site visit is scheduled for March 17, 2026, and attendance is required for bid responsiveness. The contract will be awarded to the lowest cost responsive and responsible bidder and shall commence only after completion of all required CDBG pre-construction compliance and orientation requirements and contract execution. The contract term extends until final completion and formal acceptance of work, unless terminated earlier.
All pricing must be firm and fixed for the contract duration. The project is entirely CDBG-funded and subject to mandatory Davis-Bacon prevailing wage compliance for all contractors and subcontractors. Prime contractors are responsible for all on-site workers, including those hired through subcontractors or staffing agencies, and must ensure full SAM.gov registration (not merely a UEI number) for all subcontractors before work begins. Mandatory in-person pre-construction compliance meetings must be held at the County with the prime contractor and all known subcontractors, with additional meetings required for any subcontractors added after the initial meeting. Weekly certified payroll reports must be submitted electronically and must match worker interviews conducted by the compliance analyst. Payment will be withheld until the compliance analyst confirms compliance, and non-compliance can result in DOL investigations and project delays. All payroll and subcontractor documentation must be retained for three years after project completion, and contractors must provide the Davis-Bacon Worker Pocket Guide to all workers on-site.
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Pre-Bid Orientation: Prime Contractor Responsibilities & Compliance Requirements for DBRA/CDBG Projects
1. Responsibility for All Workers on Site
• The prime contractor is responsible for all workers at the job site, including those hired through subcontractors or staffing agencies.
• Ensure that all workers meet the required compliance standards, and that proper documentation is maintained.
2. Compliance with Davis-Bacon Wage Requirements
• Davis-Bacon wage rates must be followed for all workers on the site, including direct hires, subcontractors, and staffing agency workers.
o No exceptions to the wage rates. Non-compliance will result in payment delays or withholding.
3. Pre-Construction Compliance Meeting and Subcontractor Participation (In Person at the County)
• Pre-construction compliance meetings are mandatory and will be held in person at the County.
• Required attendance includes:
o The prime contractor, and o All known subcontractors (or specialty trades) that will be working on-site.
• No subcontractor may begin work on-site unless they have attended the required pre-construction compliance meeting and received the compliance expectations directly.
• If a new subcontractor is added after the pre-construction meeting:
o The prime contractor must notify the County and the grantee, and o A separate in-person pre-construction compliance meeting must be scheduled at the County before the new subcontractor (or their workers) can begin work on-site.
• This requirement is in place to ensure all parties understand Davis-Bacon requirements upfront and to prevent wage issues, including wage restitution caused by misunderstanding worker classifications or pay rates.
4. Subcontractor Disclosure, Tracking, and SAM.gov Requirement (Ongoing Requirement)
• Notify the compliance analyst and grantee when adding or changing subcontractors.
• Keep an updated list of subcontractors and trades working on-site, including who they work for.
• Full SAM.gov registration is required for all subcontractors. A UEI number alone is not full registration.
• Subcontractors may not begin work on-site until the County verifies full SAM.gov registration and receives the exclusions documentation for the compliance file.
5. Certified Payroll Reporting
• Submit one certified payroll report each week, ensuring it includes all workers (even those from subcontractors or agencies).
• Submit electronically using the Davis-Bacon and Related Act Certified Payroll Submission Form:
Certified Payroll Submission Form.
• The certified payroll report must match the worker interviews conducted by the compliance analyst.
• Keep records for three years after the project ends.
5. Reports for Section 3 and BABA Act Compliance
• Complete any necessary reports for HUD’s Section 3 (promoting employment for low-income individuals) and BABA (Build America, Buy America) compliance.
• Submit these reports accurately and on time.
6. Payment After Completion of Work
• Payment will be processed only after compliance is confirmed by the compliance analyst.
o If you're not in compliance, you will not be paid.
o Multiple discrepancies between the certified payroll and worker interviews will lead to the DOL investigation, and payment will be withheld until compliance is confirmed.
https://app.smartsheet.com/b/form/8c245711a7754234b43d7112a70f508f
7. Consequences of Non-Compliance
• If the agency pays without confirming compliance:
o The agency will not be reimbursed by SLCo due to non-compliance.
o This can result in project delays, penalties, and further scrutiny.
8. Contractor’s Responsibility to Review Key Documents
• It is the prime contractor's responsibility to thoroughly read the following important documents for proper understanding and compliance:
o Davis-Bacon and Labor Standards: Agency/Contractor Guide:
Davis-Bacon and Labor Standards Guide o Chapter 16: Labor Standards for CDBG Projects:
CDBG Chapter 16 Labor Standards
9. Davis-Bacon Worker Pocket Guide
• Provide a copy of the Davis-Bacon Worker Pocket Guide to all workers on the project site to ensure they understand their rights under the Davis-Bacon Act.
o Download the guide here:
Davis-Bacon Worker Pocket Guide
10. Record Retention
• Keep all payroll records for at least three years after the project is completed.
This includes:
o Payroll records for every worker on the project.
o Documentation regarding subcontractors and worker classifications.
Key Takeaways for Contractors:
• Prime contractor is responsible for all workers on the site, including subcontractors and staffing agency workers.
• Davis-Bacon wage requirements apply to all workers on the site. Worker classifications and pay rates must be correct to avoid wage restitution and payment delays.
• Pre-construction compliance meetings are mandatory, in person, and held at the County. Prime contractors must attend and must bring all known subcontractors or trades that will be working on-site.
https://files.hudexchange.info/resources/documents/Davis-Bacon-and-Labor-Standards-Agency-and-Contractor-Guide.pdf https://www.hud.gov/sites/documents/CDBGCHAPTER16.PDF https://www.hud.gov/sites/dfiles/Labor/documents/Davis-Bacon_Worker_Pocket_Guide.pdf
• If a new subcontractor is added later, a separate in-person pre-construction compliance meeting must be scheduled at the County before the subcontractor (or their workers) can begin work on-site.
• Full SAM.gov registration is required for the prime contractor and all subcontractors. A UEI number alone is not full registration. Work will not start until registration is verified and exclusions documentation is received for the compliance file.
• Submit one weekly certified payroll report through the required electronic system.
Certified payroll must match work dates and worker interviews.
• Complete Section 3 and BABA Act compliance reports when applicable.
• You will not be paid until compliance is confirmed. Failure to meet compliance requirements can lead to payment delays, investigations, and non-payment.
• Provide the Davis-Bacon Worker Pocket Guide to all workers and review all required compliance documents.
• Maintain all records for three years after project completion, including payroll and subcontractor documentation.
By following these steps and staying on top of compliance, contractors will support a smooth process for payment and avoid preventable issues on DBRA/CDBG projects.
Note:
For any questions regarding Davis-Bacon Act (DBA) compliance, please direct your inquiries to Madeline Martinez, the Contract and Compliance Analyst for Salt Lake County Housing and Community Development (HCD). You can reach her via email at mademartinez@saltlakecounty.gov
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