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“Sweep”Audits for Contractor Compliance

August 7, 2010 Written by: Written by Mike Rogers, Chief Compliance Officer

An issue garnering attention among government contractors is “sweep audits”.  Teams of 3 to 5 investigators are visiting worksites and examining everyone on the project.   Prime contractors need to understand that they are responsible for whether their subcontractors – and any subs their subcontractors are using – are in compliance with applicable laws such as the Davis-Bacon Act.

A fourth-tier subcontractor brought in to install cabinets, may not even be aware that they are covered by the Davis-Bacon Act while working on an ARRA-funded project. It’s imperative that prime contractors ensure that all subcontractors on an ARRA-funded project, or any project to which the Davis-Bacon Act applies, understand their obligations under the law.

The audits are random and unannounced, so government contractors must keep impeccable records at all times.  With the increased number of investigators on staff at the DOL, it’s almost a given than any contractor working on an ARRA-funded project will be audited.