Federal construction contractors operating under FAR Part 36 carry compliance obligations that begin at solicitation response and continue every week through final payment. The Davis-Bacon and Related Acts require payment of locally prevailing wages to all laborers and mechanics on federally funded construction projects, and the Department of Labor enforces these requirements through weekly certified payroll review and periodic investigative audits. Beyond payroll compliance, FAR 52.236-2 gives contractors a defined window to submit differing site condition claims — a window that closes permanently if field documentation is not captured in real time. A virtual assistant dedicated to federal construction compliance manages these obligations systematically across all active projects.
Davis-Bacon Wage Determination Monitoring
Wage determinations for federal construction contracts are issued by the Department of Labor under the Davis-Bacon Act and incorporated into the contract via FAR 52.222-6. Determinations specify minimum wage rates by trade classification and geographic area, and they can be modified by DOL during a project if the contract includes option periods or exceeds one year. A virtual assistant monitors the SAM.gov wage determination portal for modifications to the wage determinations applicable to active projects, notifies the project manager and payroll administrator when modifications are issued, and maintains a wage determination log by project documenting the effective rates for each trade classification throughout the project lifecycle.
Weekly Certified Payroll Preparation and Submission
The Davis-Bacon Act requires prime contractors and all subcontractors to submit certified payroll reports weekly using DOL Form WH-347 or an equivalent format, demonstrating that each worker was paid at least the applicable prevailing wage for their classification during that pay period. These reports must be submitted to the contracting officer and retained for three years after project completion. A virtual assistant collects weekly payroll data from the construction firm's payroll system, reconciles hours by trade classification against the applicable wage determination, prepares WH-347 forms for each subcontractor and for the prime, and submits the certified payroll package to the contracting officer by the required deadline. Cumulative late submissions or wage underpayments can trigger DOL investigations and contract withholding under FAR 52.222-6.
Subcontractor Certified Payroll Compliance Tracking
Prime contractors are responsible for ensuring their subcontractors also comply with Davis-Bacon certified payroll requirements. A virtual assistant maintains a subcontractor compliance calendar, sends weekly reminders to each subcontractor's payroll contact, collects and reviews subcontractor WH-347 submissions for completeness, and escalates deficiencies to the project manager before they accumulate into systemic compliance problems. DOL's Wage and Hour Division can hold prime contractors liable for subcontractor Davis-Bacon violations, so proactive subcontractor monitoring is an essential prime contractor risk management function.
Differing Site Condition Documentation and Claim Preparation
FAR 52.236-2 entitles contractors to equitable adjustments for differing site conditions — physical conditions at the site that differ materially from those indicated in the contract or from conditions that are normally encountered. The clause requires prompt written notice to the contracting officer before the condition is disturbed, which means field documentation must happen immediately when an unusual condition is encountered. A virtual assistant trains field supervisors on the notification requirement, maintains a differing site condition log, prepares the initial written notice for contracting officer submission within 24 hours of discovery, and coordinates the preservation of photographs, geotechnical data, and contemporaneous field notes that support an eventual equitable adjustment claim.
REA and Contract Modification Coordination
Requests for Equitable Adjustment on federal construction contracts require cost and pricing data organized in the format required by FAR Part 15 for modifications above the simplified acquisition threshold. A virtual assistant maintains the project's change order log, tracks each pending REA through the contracting officer's review and negotiation process, prepares backup cost documentation packages including labor, material, equipment, and subcontractor cost breakdowns, and monitors constructive acceleration claims when contracting officers reject REAs and require continued performance.
Field Documentation as the Foundation of Compliance
Federal construction compliance ultimately rests on contemporaneous field documentation — wage records, site condition reports, and change event logs created in real time rather than reconstructed from memory. A virtual assistant establishes the documentation workflows and submission cadences that make compliance a predictable operational function rather than a reactive scramble when DOL auditors or contracting officers request records.
Government construction contractors seeking to systematize their compliance operations can find experienced virtual assistants at Stealth Agents.
Sources
- FAR Part 36, "Construction and Architect-Engineer Contracts," acquisition.gov
- Department of Labor, "Davis-Bacon and Related Acts," dol.gov/agencies/whd/government-contracts/construction
- FAR 52.236-2, "Differing Site Conditions," acquisition.gov