ABC Metro Washington Spring 2016

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Building Washington 15
does not affect those state prevailing
wage covered contracts where these
exemptions exist.
Several SUB plans received the
DOL exemption from annualization
requirement in the past. SUB plans
that did not have a specific ruling from
DOL granting the plan exemption
never were exempt from annualization
for federal contracts. Credit for
contributions will be calculated by
dividing total contributions to the
SUB plan by all hours worked on both
DBA/DBRA projects and on private/
commercial projects. The result of the
calculation is the amount of credit per
hour worked that a contractor can take
credit toward meeting its prevailing
wage obligation under DBA/DBRA.
For example, if a contractor makes
contributions to a SUB plan of
$200 in a particular month and the
employee worked 50 hours on a DBA
covered contract and 150 hours on a
commercial contract, the contractor
will only be able to take credit for
$1.00 per hour. This compares to the
$4.00 of credit per hour contractors
who had the SUB plan exemption
could take prior to the DOL change.
SUB plans may still be a viable option
for companies with employees who
need to draw upon unemployment
benefits during planned layoffs.
This DOL change does not alter the
requirement that a SUB plan benefit
must be tied to the receipt of state
unemployment benefits in order for
the SUB benefit to be exempt from
FICA and FUTA. n
Wondering what your options
are? The Contractors Plan
understands the unique
challenges that DBA/DBRA
and Service Contract Act
contractors face when
creating and managing bona
fide employee benefits plans. The Contractors
Plan specializes in prevailing wage compliance
and provides a flexible, easy-to-use solution that
reduces contractors’ workload while offering
great benefit options for their employees. For
further updates and developments regarding SUB
plans and other prevailing wage benefits issues,
contact Karen deMontigny at 800-690-7793 or
More information can be found
at