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    In a competitive environment, individual labor rates are N/A as only price is evaluated, not individual cost elements. Therefore, the first time the Government would review labor rates would be upon receipt of certified payrolls for Davis Bacon employees. If any employee is paid more than the required minimum, It doesn't seem realistic to ask the contractor to lower the rate of pay on a FFP contract. Also, is it a requirment to pay only the DB rates and any negotiated rates (single or sole source) above DB rates, rational for higher rates must be documented in the contract file? Is it not expected that more experienced painters, for example, would be paid the same as lesser experienced painters?


    This response is based on the information provided.  We suggest you discuss with your contracting and finance team, program manager and/or legal department as appropriate.


    You are correct.

    Those wage determination rates are minimums that are to be paid if contracting with the Federal Government.  They certainly are not ceilings.  We believe there is a typo in the last sentence of your question.  It is certainly expected that a more senior/more experienced craftsman would be paid more than a newly hired craftsman.  Putting it in perspective, next year when a new person is hired into your office at the low end of your GS pay grade, do you expect it is fair for the taxpayer that all in the office get that minimum pay?


    These rates are minimums, not maximums.  If they were maximums, people would quit and find a job paying what they were making or better rather than take a pay cut.  We would always be struggling to hire companies with competent workers if all we are willing to pay are minimum wages.


    You do not need to justify in the file paying a company's prevailing labor rates.


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