Is the $2,000 Davis-Bacon Act threshold based on the entire amount of the contract, including equipment costs, or only on the labor costs?
The $2,000 DBA threshold applies to the total cost of a contract; it is not based on contract labor costs alone. • Is there a difference between a “project” and a “contract”? For example, if a community action agency (CAA) uses Recovery Act funding on weatherization of a house and has a contract for $2,000 for insulation for the house and a different contract for $1,900 with another company for weather stripping in the same house, do the Davis-Bacon requirements apply to both contracts since they are the same house, or just to the insulation because it is over $2,000? The “project” consists of all the homes to be weatherized as part of a single grant to the Subrecipient. Therefore, the subrecipient—the community action agency—is likely to have many homes to weatherize within its grant that will require many contracts. Unless the overall grant to the subrecipient is for an amount less than $2,000, the individual homes to be weatherized will always be covered by Davis-Bacon Act requireme