Posts in Davis-Bacon Act
The Service Contract Act and Davis-Bacon Act Plan Expense Conundrum

The SCA and DBA both provide that direct contractor payments of plan expenses are not deemed to be bona fide fringe benefit contributions. But that truism doesn’t tell the complete story. Plan expenses paid for by the plan do not invalidate otherwise bona fide contributions made by the employer to the plan under the prevailing wage laws.

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We Need New Davis-Bacon Act Conformance Procedures

Where there is only a single "skilled craft" set forth on the subject WD, DOL is willing to make those union wages and benefits the bench mark for all other skilled positions under the DBA, whether union or nonunion. By this sleight of hand, DOL can bootstrap union wages and benefit rates to all the nonunion positions. This conformance procedure is an abuse that can be reformed by the Trump Administration with the stroke of a pen.

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