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Clarifying Conformance: A Davis-Bacon Guide for Contracting Agencies

Updated: Jul 17, 2025


📘 What Is Conformance?

Conformance means adding a missing job classification to a Davis-Bacon wage determination when a federally funded construction project includes work that isn't classified under the labor classifications in the effective wage decision.


It ensures workers are paid properly for the jobs they’re actually doing.


🧩 When Do You Need Conformance?

A conformance request for an additional classification, wage rate, and fringe benefits is appropriate only when all of the following are true:

  1. The work to be performed isn't already covered by a classification in the wage determination.

  2. The requested classification is commonly used in the local construction industry.

  3. The proposed wage rate (including any bona fide fringe benefits) bears a reasonable relationship to existing rates in the wage determination.


📝 How It Works


🔎 Prior to Construction

Once the contract is awarded — but before work begins:

  • Meet with contractors to explain Davis-Bacon and conformance requirements.

  • Review scopes of work to identify any roles not listed in the wage determination.

  • Ensure contractors understand the SF-1444 form and how to initiate a request.

  • Establish clear procedures for posting wage rates and communicating compliance expectations.


Catching classification gaps early helps prevent wage disputes and project delays.


👷 During Construction

While the project is underway:

  • Review certified payrolls to identify unlisted or improperly classified roles.

  • Conduct site interviews to confirm job duties align with listed classifications.

  • Assist contractors with submitting SF-1444 for any missing classifications.

  • Monitor USDOL submissions and follow up as needed.

  • Maintain organized records of all conformance activity.


📤 Submitting SF-1444

SF-1444 – Request for Authorization of Additional Classification and Rate is the required form for initiating a conformance request.


Submission flow:

  • Subcontractor ➡️ Prime Contractor

  • Prime Contractor ➡️ Contracting Agency

  • Contracting Agency ➡️ USDOL at DBAconformance@dol.gov


The request should include:

  • Proposed job title and description of duties

  • Suggested wage and fringe benefit rate

  • Current wage determination

  • Agreement from:

  • The contractor or subcontractor

  • Workers or their representatives

  • The contracting agency


If any party disagrees, they may attach a written explanation. USDOL will issue a final determination.


💬 What If There’s Disagreement?

If the contractor, agency, or labor representatives can’t reach agreement, the U.S. Department of Labor will review the request and make a final decision.


If you have questions about Davis-Bacon conformance, please contact our compliance team:


You can also reach either of them by phone at 985-900-2320.


Learn more about ARTOVIA’s Davis-Bacon Compliance services and expertise on our

 
 
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