Prevailing Wage/Davis Bacon - dealing with awarding agencies?

[AndrewZ]

I'm with a TPA firm. I know at least one of our clients had to submit the restated plan document we prepared providing for prevailing wage contributions to the agencies awarding the contract. Our other prevailing wage clients are new and haven't previously done plan contributions, so may not be familiar with the process with the agencies. I'm trying to get a feel for what they should expect.

Is it typical that each agency reviews the plan document before a contractor is allowed to pay fringe benefits as pensions contributions? If so, would something like excluding HCEs (e.g. children of owners) present a problem?

Related to this issue -- if an agency hasn't reviewed the document or isn't aware that HCEs are excluded under its terms, and then an HCE doesn't receive a prevailing wage contribution under the terms of the plan, is it possible an agency might take issue with that (if they don't understand that it's common due to nondiscrimination issues, or they simply require uniformity)?

Thanks.