Dear Colleagues:

Sorry for the delay in posting the results of my survey.  Some of the Cities
that responded referred me to their CDBG office and the bottom line is that
the City is on the hook for certifying the payroll for prevailing wage on
federally-funded projects.

The City of Imperial Beach has been certifying payroll with a contractor on
weekly basis, with the contractor providing payroll timesheets showing his
employees being paid at prevailing wages.  When the field audit was
conducted with several employees of the subject contractor, the employees
stated that they were not being paid prevailing wages.

Our City's question was "how far should the City go in certifying prevailing
wage payroll"?  The other question was "how much can you withhold from the
contractor's payments".

The Cities responding stated that their due diligence included obtaining
copies of cancelled checks to make sure that the contractor's payroll
records were not just made up.  Member Cities also stated that they were
retaining the difference between the required prevailing wage and the actual
wages paid to employees.  The burden of proof was on the
contractor/employer.

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