It is unlikely that labor compliance is top of mind to most government contractors. In fact, contractors may not even realize that their contracts incorporate prevailing wage requirements. Yet compliance is complicated and the consequence of failing to comply are significant.
Employers with contracts incorporating prevailing wage clauses must provide the correct combination of wages, benefits, vacation and holidays to employees. When the SCA and DBA regulations were created, Congress couldn’t have predicted the workforce of the 21st century. Employees no longer clock in and out of the same project site, on the same contract every day. These requirements no longer dovetail with the way employees work and companies provide benefits.
However, the regulations remain. The consequences of non-compliance can be harsh, from issuing employee back payments, to contractor suspension, or worse, debarment.
Find out more about how Baker Tilly helps contractors:
Before the auditors arrive, contractors should perform a self-assessment of their overall compliance, including compliance with the Service Contract Labor Standards (otherwise known as the Service Contract Act), the Davis Bacon Act, and Collective Bargaining Agreements. The roles and responsibilities of the contracting officer, the Department of Labor, and the contractor are often misunderstood, complicating compliance. Prior to an audit, Baker Tilly’s government contracts practice can help:
Employers must carefully categorize employees to identify those who are covered by prevailing wages. Not every employee on a covered contract is covered by prevailing wage requirements. And unfortunately, identifying covered employees is only step one of the process. Contractors must “map” their internal job positions to the prevailing wage labor categories, a task more difficult than it should be. Baker Tilly’s government contracts practice assists contractors with:
Sometimes, despite best attempts to comply, contractors may find themselves historically non-compliant. Leveraging our experience with the Department of Labor, Baker Tilly government contracts practice can:
Before starting an audit, we help contractors identify the internal and external resources necessary. These resources will work with the auditors and respond to information requests. Audits can last anywhere from several weeks to months (or even years), which can create significant strain on contractor resources.
During the audit, we address contentious issues by first gathering the facts. Understanding our client’s circumstances allows us to help manage the dialogue and successfully resolve difficult issues. In this regard we:
Because prevailing wages impact all parts of the contract life cycle, effective prevailing wage compliance cannot be assigned to one individual or department. An effective system of internal controls will involve accounting, finance, human resources, contracts, legal, and even the bid and proposal department. We help clients:
Employers with SCA contracts must ensure they provide the appropriate wages, benefits, vacation and holidays to employees. However, they must do so in a very specific manner that does not align to common business practices. Baker Tilly’s SCA Robotic Process Automation (RPA) service simplifies (and may improve) employer compliance where:
We combined RPA technical capabilities with extensive SCA knowledge to design and deploy an SCA RPA solution that offers: