Training funds and the CAC-2 on a Caltrans contract

What Caltrans requires for training funds

In the 2025 Standard Specifications, section 7-1.02K(4) tells you to comply with the training contribution requirements of Labor Code 1777.5(m)(1), and the Department deducts from progress payments the civil penalties that the Chief of the Division of Apprenticeship Standards assesses for violating section 1777.5. Check the edition named in your contract.

The Labor Compliance Manual repeats the duty in section 11-1: pay the amount on the wage determination to an approved training program or to the California Apprenticeship Council (CAC). Section 11-4 narrows it to apprenticeable crafts. The manual's web chapters and the LCPtracker help pages carry no date; each was read on November 4, 2026. The DAS public works FAQ is dated September 2024.

Is your craft apprenticeable?

Section 11-4 of the manual marks an apprenticeable craft with a # before its name on the DIR wage determination. With no # or a double ##, the craft is not apprenticeable, and training contributions can be paid to the employee or an approved training program. The DAS public works FAQ (dated September 2024) agrees: training funds cannot be paid to workers unless the craft is not apprenticeable.

When the council payment is due

Section 11-8 of the manual says contributions to the council are due on the 15th day of the month for work performed during the preceding month, paid by check with a completed Form CAC-2. Work performed in March is due April 15. 8 CCR 230.2(b) states the same deadline. Under subdivision (c), the check shall come with a completed CAC-2 or nine listed items of information; the general guide has the full list.

DIR's Training Fund Search page lists two reasons a recent contribution may not appear: a wrong remit address, or an old CAC-2 form. It says payments made with the current web CAC-2 form appear within 48 hours of receipt, except where the license number is missing, the system fails or a holiday intervenes. Subdivision (c) still allows the information list in place of the form, but the search page does not say whether a payment sent that way posts automatically. Search for your payment after sending it, and keep your check record either way.

What proof the sources describe

Section 11-3 of the manual tells Caltrans staff, if apprentices are employed, to verify that training fund contributions went to an approved apprenticeship program or the CAC. No Caltrans document read for this page names a specific proof for a training payment to a program. Section 15-3 of the manual lists trust fund statements, canceled payroll checks and bank statements among the records staff use to verify certified payroll entries in general.

On construction-administered contracts, section 15-2-1 of the manual tells labor compliance staff to check certified payrolls submitted, within 30 days of receipt, for a list of items that includes, for an apprenticeable craft, that the training payment went to an approved program or the council and was captured on the fringe benefit statement.

How the training amount shows on the fringe benefit statement

All four checklists carry the same training rule, under the lead-in that limits it to apprenticeable crafts. Which one applies depends on your contract and track; see File Transfer versus LCPtracker.

The statement is Caltrans form CEM-2501 (rev. 01/2026). All four checklists say it goes in with the first payroll and again when fringe benefits change. The form has an hourly amount for apprentice or training fees and the plan, fund, or program's name and address. The manual tells reviewers to check that it shows to whom and where benefits were paid, so name the program or the council. Our CEM-2501 guide covers the whole form.

How the training amount appears in LCPtracker

LCPtracker's free Excel template guide describes a Training column for the total employer payment (hourly amount times hours worked). It says training is "almost always required" and almost never allowed to be paid to the employee, and that "in rare cases the value may be zero." For crafts DIR identifies as apprenticeable, chapter 10 of Caltrans's 2023 manual says the contractor cannot meet the obligation by paying the amount directly to the worker.

LCPtracker's validation settings page describes check VAL_4, which compares the Training amount with the published training rate. For California state-funded projects it recommends Notice and Enforce, under which the contractor cannot certify while the message stands. If you see it, compare your figure with your determination's training line. Other failures: upload errors.

Under $30,000 or a sole proprietor: the manual still expects a payment

Section 11-2 of the manual lists four examples of contractors exempt from the apprentice requirements. For two, a general contractor's contract under $30,000 and a contractor with a sole proprietor license who does all the work unassisted, the manual adds that the contractor must still pay the training fund fee and submit proof of the monthly payments. The other two carry no such line.

Labor Code 1777.5(o) reads: "This section does not apply to contracts of general contractors or to contracts of specialty contractors not bidding for work through a general or prime contractor when the contracts of general contractors or those specialty contractors involve less than thirty thousand dollars ($30,000)." For a subcontractor, the manual reads the $30,000 as the value of the entire contract, not the subcontract.

The statute's text and the manual differ here. Subdivision (m)(1), the council contribution duty, is part of section 1777.5, and (o) says "This section does not apply" to those contracts. Section 8-4-4 of the manual says instead that (o) does not apply to contracts under $30,000 and that the section's other requirements about apprentices on public works projects still apply. No source read for this page reconciles the two.

Where the sources disagree

On a contract under $30,000, the sources read for this page differ on whether and to whom the training amount is paid. Only section 11-2 of the manual and the DAS FAQ speak to exempt contracts, and 11-2 names no payee.

Section 8-4-4 of chapter 8, a checklist point for the pre-job meeting, says the contractor must contribute training funds to the Joint Apprenticeship Committee or to the California Apprenticeship Council. Chapter 20 of the 2023 manual, in its audit guidance on deductions, says training funds are not paid to the worker but to the local training trust fund of an approved apprenticeship program or to the council on Form CAC 2. Both are general statements, not written about exempt contracts; this page applies them to exempt contracts by inference. Section 11-2 asks for proof of the monthly payments but does not say to whom.

The DAS public works FAQ (dated September 2024) says you are still obligated on a prime contract under $30,000, because training funds are part of the prevailing wage package, but that on an exempt project the training fund is paid to the employee. Its own exemption list says section 1777.5 does not apply to general contractors whose contract is under $30,000, so it rests the continuing duty on the prevailing wage package, not on section 1777.5. The manual and the FAQ both treat the amount as not waived, and on the payee they may point different ways. To resolve it, ask the resident engineer or district labor compliance officer, in writing, which payee and proof your contract expects, and keep the answer.

Federal-aid contracts have a second training item

The federal-aid checklists also have a separate item for the required number of trainees or apprentices. If your contract sets a trainee or apprentice goal, section 8-4-4(a) of the 2023 manual says to submit a training plan to the resident engineer before work starts. That is the contract's training program, not the hourly fee.

If Caltrans questions your training payment

1. Check the rate. Compare your determination's training line with your CEM-2501 and payroll.
2. Check a council payment. Search your license number in the Training Fund Search, which shows the previous 48 months.
3. Collect program proof. Gather your record of payment to the program's trust fund.
4. Ask what proof Caltrans wants. Ask the resident engineer. If the question arrives in a delinquent payroll notice, start with our delinquent payroll notice page.

Help with the payroll documents

WellStanding prepares your Caltrans payroll documents from the payroll export you already run, and a person reviews them. You review and sign; the certification is always yours and we never sign for you.

Questions