HUD's Increased Use Of Split-Wage Decisions Is Troubling

By Christopher Ruhman (May 7, 2018, 2:48 PM EDT) -- Departing from prior public policy, the U.S. Department of Housing and Urban Development Headquarters-Office of Davis-Bacon and Labor Standards, or ODBLS, has recently begun the concerning practice of applying split-wage rate decisions to multifamily projects of four stories or less. This is a significant and very troubling departure from prior policy and decisions. Historically, ODBLS assigned these apartment properties the single "residential" wage determination. Apartment amenities such as parking, club houses, streets etc. were generally considered incidental in function to the overall character of the project. Accordingly, ODBLS rarely assigned a separate wage determination to such projects....

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