CDBG Entitlement FAQ

In cases where the work is being contributed in-kind, or paid for from another source and CDBG funds are only paying for materials, does Davis-Bacon still apply?

Date Published: May 2015

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Bona-fide volunteers are excluded from Davis-Bacon requirements under CDBG (and other HUD programs). HUD Regulations at 24 CFR Part 70 provide definitions and additional guidance concerning the use of volunteers. Generally, volunteers are defined as individuals who:

  • Perform services for a public or private entity for a civic, charitable, or humanitarian reason, without promise, expectation, or receipt of compensation for services rendered;
  • May be paid expenses, reasonable benefits, or a nominal fee for such services for which the individual volunteered; and
  • Are not otherwise employed at any time in the construction work.
  • Davis-Bacon also does not apply to material suppliers or their employees or to employees, such as truck drivers, who may be delivering materials to a job site.

For any youth performing construction work, you should ensure the work is supervised by a general contractor and that appropriate insurance coverage is provided.

Tags: CDBG Entitlement Program Davis-Bacon