Is it appropriate for States, in certain instances, to conduct some on-site reviews at the local agency and contractor levels to ensure contract compliance?
Yes, it is appropriate for the State to conduct on-site reviews at the local agency and contractor levels. As set forth in the Davis-Bacon Act Requirements clause and the Recipient Functions clause that will be added to existing weatherization grants that already have been awarded to State/Recipients, Recipients are responsible for ensuring compliance with DBA requirements by Community Action Agencies, local agencies, contractors and their lower-tier subcontractors. On-site reviews are useful in ensuring compliance.
