Davis-Bacon, Federal Labor Laws, & HUD Section 3 Pre-Construction Conference

Transcription

1 Davis-Bacon, Federal Labor Laws, & HUD Section 3 Pre-Construction Conference Contents Record of Pre-Construction Conference... 2 Federal Labor Laws Applicable to this Project:... 3 Labor Law Responsibilities & Obligations of Interested Parties... 3 I. Owner/Developer and/or its Governing Body responsibilities:... 3 II. General Contractor (Prime) labor standards, responsibilities, and obligations:... 3 III. Designated Labor Standards Officer (LSO) responsibilities and obligations:... 5 IV. Department Labor Standards Specialist (LSS) responsibilities and obligations:.. 7 V. Disbursement Restrictions Related to Labor Standards:... 7 Economic Opportunities for Low-Income Persons: HUD Section 3 of The Housing and Urban Development Act of Section 3 Responsibilities & Obligations of Interested Parties... 8 I. Awardee (Subrecipient), Contractors, and Subcontractors... 8 II. Section 3 Coordinator... 9 III. Department Section 3 Specialist (STS) responsibilities and obligations:... 9 IV. Disbursement Restrictions Related to Economic Opportunity Standards:... 9 Section 3 Local Economic Opportunity Obligation Notice... 9 Section 3 Clause... 9 Pre-Construction Conference Sign-In Sheet Program Services Division Record of Pre-Construction Conference November 2016

2 TEXAS DEPARTMENT OF HOUSING AND COMMUNITY AFFAIRS Program Services Division - Davis-Bacon Labor Laws & HUD Section 3 Record of Pre-Construction Conference Owner/Developer: Source(s) and Contract(s) #: Property Name, Address: Project County: Conference Location: Conference : Owner/Developer Contact Person: Address: Telephone: Architect/Engineer: Address: Telephone: General Contractor (Prime): Address: Telephone: Master Subcontractor: Address: Telephone: Texas Department of Housing and Community Affairs (TDHCA) P. O. Box / 221 E. 11th Street / Austin, TX Telephone: / Fax: A preconstruction conference was held at the above date and place signed by attendees named. Fax: Fax: Fax: Fax: TDHCA Programs Services Division Page 2 of 10

3 Federal Labor Laws Applicable to this Project: Davis-Bacon Act (DBA) requires that each contract over $2,000, to which the Federal Government is a party, for construction shall contain a provision for the minimum prevailing wages to be paid to all laborers and mechanics employed at the site of work and includes fringe benefits payments for specific trades. DBA requires weekly payments to workers. Contract Work Hours and Safety Standards Act - CWHSSA establishes requirements for payment of over-time and penalties for violations. Penalties are referred to as liquidated damages. Liquidated damages liability equals $25 per day per worker per event (day), and requires that over-time pay restitution be paid to worker who is underpaid. CWHSSA also establishes safety standards compliance Copeland (Anti-Kickback) Act - establishes laws to prohibit the payment of kickbacks to work on federally assisted projects, enforces weekly payment and sets forth rules concerning allowable and disallowed employee deductions. Copeland Act also provides basis for contract termination and criminal prosecution pursuant to 18 U.S.C. 874 Federal Labor Standards Act - FLSA establishes laws for minimum wages paid to workers and laws associated with the employment of minor. FLSA prohibits wage discrimination based on gender and governs the rules for independent contractors. FLSA enforces over-time payment mandates at 1.5 the basic wage rate for nonexempt employees that exceed 40 hours in a workweek. The Department of Labor governs enforcement jurisdiction of FLSA rules. Labor Law Responsibilities & Obligations of Interested Parties I. Owner/Developer and/or its Governing Body responsibilities: II. 1. Require all Project parties to comply with applicable Program rules, regulations, and guidelines. 2. Appoint a HLabor Standards Officer (LSO) (Exhibit 14 Preconstruction Guide)H. The project owner may hire this person directly, making the LSO directly responsible to the owner. In order to avoid a conflict of interest, this individual must not receive their salary or employment through the Project Construction Company. The LSO safeguards the interests of the owner and the workers against any possible oversight or abuse by the construction company. 3. Retain all payroll records pertinent to this contract for a period of three years after construction completion and make available upon demand of State and Federal authorized individuals. 4. Adhere to all provisions of the Loan Documents. 5. Comply with all local, state, and federal laws, rules, and regulations and agencies as referenced in the Land Use Restriction Agreement (LURA) and Loan Funding Agreement by and between the Development Owner and the Department. 6. Comply with federal construction regulations: a. Section 3 Local Plan b. Fair Housing construction mandates c. Equal Opportunity Employment and hiring women and historically underutilized businesses (HUBs) General Contractor (Prime) labor standards, responsibilities, and obligations: 1. Incorporate Federal Labor Standards Provisions- HUD 4010 (TDHCA Website, Exhibit 1)) to all executed Construction Contracts, including contracts with the General Contractor, subcontractors, and lower-tier subcontractors. 2. Pay rate for project employees must equal or exceed the prevailing wage rates listed in the applicable U.S. Department of Labor (DOL) General Wage Determination (GWD) for the County where the project is located. Prime must also pay over-time to workers at time-and-a-half the basic rate when work exceeds 40 hours in a workweek. (This includes self employed independent contractors.) Note: the Department of Housing and Community Affairs (the Department ) locks-in the project applicable DOL-GWD at loan closing and/or prior to construction. 3. Additional Classification: If Prime contractor needs a classification not listed on the applicable project GWD, Prime must ensure contractor proposed worker hourly wage complies with DOL-WHD Memorandum No. 213 new requirements, complete the HUD Report of Additional Classification and Wage (4230a) (Exhibit 7), send to the Project designated Labor Standards Officer (LSO) who, in turn, will review documents for TDHCA Programs Services Division Page 3 of 10

4 completeness and accuracy and forward to the Department Labor Standards Specialist (LSS) for processing and final approval determination by the DOL. Support documentation attached to HUD form that is submitted to LSO for proposed classifications and wage rates and fringe benefit, if applicable, must include one or both of the following: a. Letter from contractor confirming proposed wage for classification is consistent with applicable GWD and local rates ; i. Group occupations on the GWD by categories: (1) general laborer, (2) skilled craft or trade, (3) power equipment operator, (4) truck driver ii. Find the median wage for each category for even-numbers of pay rates, use the higher of the middle two wages. iii. For an occupation in an unrepresented category, use median for skilled trades. b. Copy of hire letter or form signed by employee accepting Contractor proposed wage, if employee is identified at the time of request Note: DOL must approve all project worker classifications. 4. Obtain and maintain all subcontractor-certified payrolls; ensure accuracy and compliance with labor laws including attachment of required support documentation; and make available upon demand by authorized State and Federal authorities. Department and federal mandates consist of the following: a. U.S. Department of Labor (DOL) WH -347 Payroll form (REV Dec 2008) The Department requires all contractors and subs to use WH-347 to document and report employee data and prevailing wage mandates during the work week (also available on TDHCA Website, Exhibit 2). Contractor may use own certified payroll if approved by LSS as containing same information as WH-347 (Contractor payroll form). b. Statement Required by Regulations, Parts 3 and 5, Statement of Compliance (attachment to WH-347 Payroll) must contain an original signature by the owner, partner, officer or individual authorized by owner in writing. If an Owner authorizes an individual that does not have a stake in the company to sign on his/her behalf, Owner must attach authorization statement to initial payroll submitted to LSO, identifying individual s name, title, and statement confirming that owner does not relinquish federal labor responsibilities. Note: This form does not require notarization. The Development Owner signing the certified payroll statement is subject to the penalties provided by 18 USC 1001, including possible imprisonment for 5 years, or a $10,000 fine, or both. c. Submit payrolls each week: original 347-WH payrolls within seven (7) days following the end of the work week to the Labor Standards Officer (LSO). A pay period is seven consecutive days; Ensure that you collect payrolls every week The Copeland Act makes failure to collect weekly payrolls a serious violation, requiring the Department to impose sanctions and penalties tied to Retainage release. d. Prime Contractor bears ultimate responsibility for weekly review of payrolls, for completeness (all fields (dates, hours, rates, amounts etc.), and correct calculation of each worker s wages. e. Number payrolls consecutively, identify the first payroll as #1-initial and the last as # final ; f. Employee Social Security number last 4-digits must appear on the WH -347 Payroll. Do NOT document the employee s full social security number on the certified payroll. A separate Worker Information Sheet must be provided by all contractors and attached to the first certified payroll submitted by all contractors working on the project. The Worker Information Sheet must contain all employee name(s), full social security number, address and telephone number (optional). Any time a new employee is added, the contractor is responsible for providing the employee information required. Note: Project Owner must make this information available to authorized representatives monitoring for labor standards compliance; g. List all workers on payroll and, if they work in multiple classifications, list the employee under each classification worked and include wage rate; h. Allow on weekly paychecks only those deductions required by law or voluntarily authorized by the worker in accordance with the Copeland Act. Employee must sign a voluntary deduction statement or certification specifying type of deduction, amount deducted, and frequency of deduction. Attach certification to initial certified payroll where deduction appears. Note: voluntary deductions must not reduce hourly wage below the required FLSA $7.25/hr mandate; i. No work payroll, submitted with consecutive numbering, must document a temporary break. If Prime discovers an extended break in subcontractor work, Prime should send a note to LSO stating the approximate date the subcontractor will return to work on the project to avoid submitting multiple no work payrolls; j. Piece work or contract labor must appear on form 347-WH (certified payroll) to document that, on an hourly basis, employee pay equals or exceeds either the required classification prevailing wage rate or the FLSA $7.25/hr minimum wage rate plus required over-time, when applicable. Remember, piece workers are entitled to OT if their work exceeds 40 hours per week. TDHCA Programs Services Division Page 4 of 10

5 III. k. Foreman or supervisor who works on-site performing construction activity in excess of 20% during a work week must document hours worked, hourly wage, and earn 1.5 times the basic rate if he/she works in excess of 40 hours. Note: Salaried employees loose exemption status if performing construction work on a federally assisted project; l. Owner of a company who performs work on the project must list him/herself on the payroll and must show the hours worked each day and total hours. An owner working alone cannot certify his/her payroll. The hours worked by the solo owner must be certified on the Prime payroll. Note: If ownership evidence is not provided, Owner must document hourly wage. 5. Apprentices and/or Trainees working on the project must register in a bona fide program approved by the U.S. Department of Labor Employment &Training Administration Office of Apprenticeship (ETA) and must not exceed the ratio of apprentices to journeymen. Prime must attach the apprentice or trainee ETA certificate to the initial certified payroll (DOL certification sample, Exhibit 3); Note: A State Licensing School apprentice identification does not qualify as an approved ETA apprentice certificate. 6. Forbid all contractors to use helper classification on the payroll unless helper classification appears on GWD. Note: If the helper uses tools of the trade, he/she must receive the classification wage rate; 7. All contractors must pay employees weekly, as required by the DBA and Copeland Act; 8. Pay all union trade workers according to Union pay rate eligibility; 9. Assess liquidated damages (penalties), required by Contract Work Hours and Safety Standards Act (CWHSSA), to Contractors who fail to pay workers the proper overtime rate. Liquidated damages liability equals $25 per day per worker per violation. Additionally, Prime must pay workers wage restitution (difference between hourly amount paid and amount due) due to underpayment of required prevailing wage rate and/or overtime at 1.5 times the basic pay rate; 10. Display the DOL Employee Rights under the Davis-Bacon Act poster, GWD prevailing wage rates and DOL approved additional classifications and wages alongside GWD, and make these accessible to all workers on the project construction site. (DOL poster, Exhibit 4) 11. Inform all contractors that failure to comply with required labor standards can result in the withholding of federal funds for restitution pay owed to worker(s) and/or assessed liquidated damages. Prime must also inform all contractors that the administrator may terminate a contract in accordance with the Copeland Act, and may subject the violator to criminal prosecution pursuant to 18 U.S.C. 874; and 12. Retain labor records for a period of three years after project construction completion. Designated Labor Standards Officer (LSO) responsibilities and obligations: 1. Ensure all executed Construction Contracts for the Project incorporate and comply with applicable Federal Labor Standards, Provisions (HUD 4010) and regulations; 2. The LSO [representing project owner] must obtain the Notice to Proceed (NTP) from the Department Labor Standards Specialist (LSS [TDHCA representative]) prior to any project construction activity. The Notice to Proceed authorizes project construction to start and documents the Department of Labor s (DOL) applicable County prevailing wage determination (GWD). The LSS will process the NTP upon confirmation of TDHCA loan closing and receipt of required Building Permit including verification of payment of applicable fees (NTP sample, Exhibit 5); 3. Verify eligibility to receive federal funds for the General Contractor and all project subcontractors prior to any construction contract award (Excluded Parties List, Exhibit 6); a. Retain verification documents obtained from the HUD website H in the Owner/Developer s labor standards file; b. Clear for eligibility on System for Award Management (SAM) each contractor company and their principals; 4. Submit to Department LSS for approval those additional classification requests received from Prime contractor proposing wages for laborers or trades not listed on the GWD. LSO must ensure compliance with DOL-WHD Memorandum No. 213 mandates and listed on the HUD s Request for Additional Classification and Rate (HUD 4230a -TDHCA Website, Exhibit 7) Before sending the Report to the Department s LSS, the LSO must: a. Include Prime contractor s support documentation (refer general contractor section #2); b. Upon receipt of the Department of Labor (DOL) determination, provide to Prime Contractor the Final Classification & Wage Determination, and ensure its posting at job site where accessible to all workers alongside the approved GWD and DOL labor poster(s); TDHCA Programs Services Division Page 5 of 10

6 5. Conduct Employee Interviews of a broad sampling of workers on a regular basis using the Record of Employee Interview HUD 11 (TDHCA Website, Exhibit 8a). a. Require Davis-Bacon-covered workers to sign the Consent to Voluntarily Disclose Confidential Wage- Earner Information (Exhibit 8b), which informs the worker that the owner/contractor appointed and employs the LSO. The form assures the worker that any information disclosed during the interview is confidential and reported disclosure violations of Davis-Bacon and Related Laws will be investigated and acted upon in accordance with labor law mandates. Verify compliance of weekly payrolls with applicable labor requirements by comparing employee interview results with applicable certified payroll. Note: LSO must review payrolls weekly for completeness (all fields (dates, hours, rates, amounts etc.), and verify correct calculation of each worker s wage. The Copeland Act makes failure to collect weekly payrolls a serious violation, requiring the Department to impose sanctions and penalties tied to Retainage release. b. Document interview results for each contractor payroll either in Remarks section of Record of Employee Interview form or with a Review tool (see Samples in Exhibit 9 Certified Payroll Review Sheet). c. Follow up with contractor(s) promptly about any discrepancies observed during job site visit. The following examples constitute discrepancies: i. Inconsistency in hourly wage reported by employee versus wage recorded on certified payroll; ii. Misclassification of worker or classification incorrectly reported (i.e. employee performs trade work but appears as laborer on payroll); iii. LSO observes employee performing more than one classification and certified payroll only reflects one classification; iv. Certified payroll does not match the observed number of workers d. Require contractors to submit revised certified payroll and Statement of Compliance containing owner or authorized person signature, if necessary for affected payroll to correct error(s) or match LSO findings. Note: Do NOT return original payroll received to contractor. e. Retain copies of interviews in Owner/Developer labor standards file 6. File weekly certified payrolls (with Statement of Compliance signed by owner or authorized individual) in the Owner/Developer labor standards file; Note: An owner of a company must provide written statement if he/she appoints an individual to sign the Statement of Compliance on his/her behalf see SAMPLE authorization form in Exhibit Notify contractors in writing of underpayment restitution, including overtime, they owe to workers and liquidated damages assessed for CWHSSA violations (TDHCA Sample Letter Exhibit 10). LSO must adhere to the following labor standards for CWHSSA liquidated damages assessed and/or collected: a. Contractor has thirty (30) days to appeal an assessed finding and liquidated damages. b. Complete and submit Liquidated Remittance form (TDHCA form 6.03, Exhibit 11); c. Complete and submit Liquidated Summary form (TDHCA form 6.04, Exhibit 12) ; d. Make contractor check payable to Texas Department of Housing and Community Affairs for the amount of liquidated damages (TDHCA remits contractor s check to the U.S. Treasury via HUD); e. Submit copy of receipt signed by employee confirming overtime restitution payment; or f. Submit copy of employee cancelled check front and back; and g. Submit list of unfound workers and copy of bank statement confirming escrow of restitution amount owed, if applicable. Note: unfound worker restitution amount must remain in escrow for three years. 8. Address and correct promptly all violations of labor standards; 9. Make available original payroll records to authorized individuals during on-site audits. 10. TDHCA conducts monitoring reviews of all its contracts. If a monitor finds incomplete or inaccurate payrolls, they will record and report the errors. Consequences will apply. Not only should contractors submit payroll records weekly to the LSO, but contractors and LSO must bear responsibility for completeness and accuracy. Either the LSO or General Contractor must ensure that whoever submits payrolls completes all fields (dates, hours, rates, amounts etc.) and correctly calculates all amounts. 11. Report any Fraud, Waste or Abuse to: a. TDHCA Labor Standards Specialist and b. TDHCA Fraud, Waste and Abuse i. By Phone: Toll Free: ; or ii. By Mail: The Network ATTN: Texas Department of Housing and Community Affairs 333 Research Court, Norcross, GA 30092; or TDHCA Programs Services Division Page 6 of 10

7 iii. By Fax: ( Faxes need to be addressed to The Network, Attn: The Texas Department of Housing and Community Affairs; or iv. By HReportline@tnwinc.com H; and/ or c. Contact the U.S. Department of Labor s Wage and Hour Division (and inform TDHCA Labor Standards Specialist) at: or TTY: d. Note: An LSO employed by a project owner who has vested interest in a construction company affiliate working at the project must act independently of employee relationship in all matters related to fraud, waste and abuse. 12. Make Labor standards records available for review by Department staff and authorized individuals. 13. Upon completion of project construction submit the Final Wage Compliance Report (Exhibit 13) to the Department LSS. 14. Retain labor records for three years after project construction completion. The person who will monitor this project for compliance with the labor requirements and serve as Liaison to the Department is: IV. Name of designated Labor Standards Officer: Department Labor Standards Specialist (LSS) responsibilities and obligations: 1. Prior to the disbursement of federal funds, obtain: Appointment of Labor Standards Officer (LSO) (Exhibit 14), notifying the Department who will take responsibility for labor standards administration and enforcement. Conduct the preconstruction conference prior to disbursement of federal funds or waive if Owner/Developer demonstrates working history and familiarity with state and federal labor requirements; 2. Issue Notice to Proceed Ten Day Call (calendar days), to authorize the start of Project construction activity and to lock in the DOL GWD applicable throughout project construction. a. NTP identified by General Decision No. b. Valid for County: c. Effective date: Locked in upon release of NTP 3. Withhold Notice to Proceed-Ten Day Call (ten calendar days) until Building Permit from local jurisdiction authorizes project construction and Loan Closing Specialist or Program Specialist confirms Department loan closed. Note: Owner/ Developer must pay any fees noted on Building Permit and send evidence to LSS with copy of Building Permit; 4. Send required support documentation to DOL-WHD (Department of Labor Wage and Hour Division) only after LSO provides complete Additional Classification and Wage Rate Reports; 5. Wire transfer funds to HUD-OLR only after LSO submits accurate liquidated damages and required support documentation; 6. Approve release of Project Retainage only after LSO submits accurately completed Final Wage Compliance Report, including support documentation; Note: LSS will also verify with TDHCA Program Monitor to ensure any assessed findings of noncompliance are resolved prior to approving Report. 7. Provide Technical Assistance related to labor standards compliance mandates. V. Disbursement Restrictions Related to Labor Standards: 1. Acquisition (only) Disbursement - Department LSS must confirm receipt of the Appointment of Labor Standards Officer (Exhibit 14) prior to Draw #1. Note: The release of a NTP is also required prior to the start of project construction even if federal funds are only used for acquisition. 2. Initial Construction Draw Department LSS must confirm compliance with the Notice to Proceed Ten Day Call thresholds. If the LSO does not receive a Notice to Proceed-Ten Day Call from TDHCA (issued by the LSS) prior to the start of Project construction work (demolition, reconstruction, new construction, or rehabilitation), that lack of notice may render those construction costs ineligible for reimbursement. 3. Retainage Release - TDHCA must confirm receipt and approve Final Wage Compliance Report. TDHCA Programs Services Division Page 7 of 10

8 Economic Opportunities for Low-Income Persons: HUD Section 3 of The Housing and Urban Development Act of 1968 (12 USC 1701u) applies to this Project HUD Section 3, codified as 24 CFR Part 135 Economic Opportunities for Low- and Very Low-Income Persons recognizes that the normal expenditure of certain HUD funds typically results in new jobs, contracts, and other economic opportunities; and when these opportunities are created, low- and very low-income persons residing in the community in which the funds are spent (regardless of race and gender), and the businesses that substantially employ them, shall receive priority consideration. Section 3 is one of HUD s tools for ensuring that the expenditure of federal funds in economically distressed communities has a multiplier effect by targeting local low- and very low-income persons and qualified businesses for jobs, training, and contracting opportunities. Nothing in this rule requires employment of a Section 3 resident or business that lacks minimum job qualifications. Nor does this rule override standard procurement guidelines described in OMB guidance. Find Section 3 details here: HTDHCA, Employment Opportunities For Low-Income People: HUD Section 3 H [ Section 3 Responsibilities & Obligations of Interested Parties I. Awardee (Subrecipient), Contractors, and Subcontractors 1. Meet recipient responsibilities summarized on Local Economic Opportunity Obligation Notice (based on 24 CFR ). Find it on the Section 3 Forms Page ( 2. To the greatest extent feasible, preferentially direct efforts at training and employment opportunities generated from the expenditure of Section 3 covered assistance to Section 3 residents in the priority order described in 24 CFR See text of the rule: 3. Incorporate Section 3 Clause 24 CFR into all solicitations and executed Construction-related Contracts, including those with the General Contractor, subcontractors, and lower-tier subcontractors. This clause appears on the TDHCA Section 3 web page. 4. Verify Section 3 resident and business eligibility and document verification with Section 3 Resident and Business Certification Forms, available on TDHCA web site. Section 3 Forms Page ( 5. Complete Section 3 Summary Report (form HUD 60002), include data from all lower-tier contractors, and submit the report to TDHCA attached in the Contract System. Report appears in draw request workbook. 6. No awardee of Section 3-covered funds may contract with any individual or organization known to be in violation of 24 CFR 135, according to the Excluded Parties List System ( 7. Failure to meet Section 3 goals for hiring or contracting does not relieve the Awardee of responsibility to comply with the rule. The awardee should use the narrative section of form to document good faith efforts (fruitful or not) to create economic opportunities for low-income persons. Efforts to earn QAP Selection points (for a Tax Credit application submitted in conjunction with a HUD-funded project) can demonstrate good faith actions to support local economic development programs. Awardees who coordinate their development plans and collaborate with local jurisdictions and agencies may help to ensure long-term community economic opportunities. Earnest documented efforts may suffice to meet Section 3 obligations, in the absence of jobs created directly by construction activity. TDHCA Programs Services Division Page 8 of 10

9 II. Section 3 Coordinator 1. Coordinate Section 3 compliance activities on behalf of awardee. 2. Complete forms, plan, reports, and transmit them to TDHCA. 3. Verify Section 3 resident and business eligibility and maintain all Section 3 documentation. III. IV. Name of Section 3 Coordinator: Department Section 3 Specialist (STS) responsibilities and obligations: 1. Prior to the disbursement of federal funds, inform Owner/Developer of their Section 3 Obligations for Local Economic Opportunities and obtain their certification to adhere to these. 2. Compile required Section 3 summary reports for transmission to HUD; 3. Approve release of Project Retainage only after Section 3 Coordinator submits accurately completed Section 3 Report Provide Technical Assistance related to HUD Section 3 mandates. Disbursement Restrictions Related to Economic Opportunity Standards: 1. Final Section 3-covered Disbursement and release of Retainage - TDHCA must confirm receipt and approve Final Report prior to release of Retainage. Section 3 Local Economic Opportunity Obligation Notice Find this notice on the TDHCA web site. Accessible via navigation bar Local Economic Opportunity Obligation Notice (PDF) at Hhttp:// Section 3 Clause Use this clause to notify contractors and potential contractors about their Section 3 liabilities. Find a link to the Section 3 Clause (24 CFR Code of Federal Regulations) in navigation bar at Hhttp:// TDHCA Programs Services Division Page 9 of 10

10 Pre-Construction Conference Sign-In Sheet I hereby certify that each of the foregoing topics was discussed in the Pre-Construction Conference. I understand that nothing presented in this document or discussed in the Pre-Construction Conference represents a modification to any existing contract or agreement or to any state, federal, or local requirement. Meeting Attendee Development Owner Signature of Conference Labor Standards Officer Signature Architect/Engineer Signature General Contractor Signature Master Subcontractor Signature TDHCA Labor Standards Specialist Other Other Other Other Other TDHCA Programs Services Division Page 10 of 10