With full operations resuming across federal agencies, the restart period presents unique compliance considerations for government contractors subject to the Service Contract Act (SCA) and Davis-Bacon Act (DBA)
Key Impacts on SCA & DBA Contractors:
- Paused or Disrupted Work Schedules: Any lapse in work must be reconciled against wage determinations, fringe obligations, and hours recorded.
- Delayed Payments & Cash Flow Pressure: The shutdown may have delayed invoice approvals that put strain on meeting wage payment obligations and fringe benefits contributions.
- Compliance Gaps: Adjustments in staffing, idle labor time and modified schedules may trigger the need for another compliance review to make sure all contract obligations are met
- Recordkeeping Risks: Interrupted administrative workflows could impact consistent timekeeping, benefits tracking, or wage documentation.
What Contractors Should Be Doing Now:
- Perform a Post-Shutdown Compliance Internal Audit. Coordinate with your teams to verify employee hours worked, wages paid/outstanding, and fringe benefit contributions for each employee on the impacted wage determination.
- Re-Engage with Contracting Officers. Coordinate with the CO to confirm changes to deliverables and any updated labor guidance.
- Document All Modifications That Occurred During Shutdown. Any changes to staffing, work schedules and contract timelines due to the shutdown should be documented and reviewed to confirm consistency with the payroll and fringe benefit payments. The more detailed the documentation, the easier it will be to comply with DOL audit requests.
At The Boon Group, we specialize in helping government contractors navigate SCA and DBA complexities—including during periods of disruption. If your team needs support with compliance reviews, fringe benefit strategy, or preparing for a potential DOL audit, we’re here to help you move forward with confidence.
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