On April 6, 2010, President Obama recorded a Memorandum in the Federal Register. Directed to the Heads of Executive Departments and Agencies, the stated goal of the Memorandum is to improve transparency while also reducing waste, fraud and abuse in Federal contracting. You can read the Memorandum in its entity by clicking this link: Federal Register, Combating Noncompliance with Recovery Act Reporting Requirements

While these anti-fraud, anti-waste memorandums are not uncommon from Government – which regularly recommits itself to these worthy goals – it serves as notice to all recipients of Federal monies, including Davis-Bacon Contractors and their subs, that the Federal Government may be planning stricter enforcement of reporting. While the specific impact of this memorandum remains unclear, given the large sums of money included in the ARRA legislation, and the pending election, it would not be unreasonable to assume that Prime Contractors working on Federal Prevailing Wage jobs may find their paperwork coming under closer scrutiny by their awarding body. Remember, it is the employer’s responsibility to insure that they are both familiar, and in compliance with, all Prevailing Wage requirements – ranging from proper employee documentation (e.g. fully completed and validated I-9’s) to accurate and correct certified payroll reporting forms.