|On the Mark!|
On the Mark! is a special publication series for staff responsible for labor standards administration and enforcement. Its purpose is to share streamlining tips and other useful innovations that enhance job performance and results. Any suggestions or comments you may have for On the Mark! are welcome.
What's new about electronic Davis-Bacon payrolls?
Did you know that electronic signature and submission of Davis-Bacon certified payrolls are acceptable?
The Department of Labor (DOL) has advised that the proper use of an electronic signature is acceptable for the purposes of the Copeland Act and its implementing regulations regarding Davis-Bacon payroll certification. That means that Davis-Bacon payroll reports may be certified and submitted electronically, i.e., via the internet. Please be careful to distinguish that electronic signature/submission does not mean pdf files of signed payrolls attached to an email, or faxed copies of signed payrolls. These methods are comparable to photocopies and are not acceptable submissions.
There are several vendors that offer products claiming to manage electronic payroll certification/submission/compliance/retention, etc., for the purpose of meeting Davis-Bacon/Copeland Act requirements. Several contracting agencies report using these products and find them to be acceptable for these purposes.
It doesn't appear that HUD will utilize electronic payroll certification/submission for its "in-house" Davis-Bacon covered projects (e.g., FHA multifamily development, Section 202 and 811 projects) in the near future. However, HUD client agencies, grantees and other program participants are welcome to engage electronic payroll services from vendors that offer products meeting Davis-Bacon and Copeland Act requirements.
Please contact the HUD Labor Standards and Enforcement staff for your area if you have any questions about labor standards requirements in HUD programs. A list of the Labor Standards and Enforcement field staff, the jurisdictions they serve, and contact information can be found at our website by following this link: www.hud.gov/program_offices/davis_bacon_and_labor_standards/laborrelstf.