San Diego Housing Commission certified payroll: what one proposed 2024 contract set out

What this page is based on

The San Diego Housing Commission (SDHC) labor compliance web page refused all automated reading on November 4, 2026, so nothing here describes what it says today. This page rests on one document, Attachment E to Contract No. PM-25-02. It sits inside "Attachment 1: Proposed Contract" in the docket for the Commission Board's September 13, 2024 agenda (report HCR24-073). It covers physical needs assessment services.

The copy read is a proposal. Its agreement date and term are blank, its signature lines are empty, and its cover is headed "More than $250,000 and Other than Construction or Development". The board report asks the Board to approve the award, and the copy does not show the outcome. The report recommends a one-year term from September 16, 2024 to September 15, 2025, and the contract allows extensions of up to 90 days, so this contract is unlikely to govern work today. This page cannot confirm a signed version has the same Attachment E.

Your own signed contract controls, and a construction contract or a later one may carry different terms. In the copy read, Section 21 of the General Conditions (Attachment B) checks the box for state prevailing wage terms and leaves the box for federal terms blank, so this page states no federal terms. The board report conflicts with itself on funding. Its Environmental Review section says federal funds are a portion of the funding, conditioned on the City of San Diego's final NEPA review and approval, while its Fiscal Considerations section lists local funds only. Read Section 21 in your own contract instead. For jobs with both layers, see Davis-Bacon plus California prevailing wage.

Weekly payroll to the Commission

Under Payroll Reporting Requirements, the proposed text has the contractor and each subcontractor submit certified payroll to the Commission every week, by one of two routes.

DIR's public works forms page (dated August 2016) says the A-1-131 will not satisfy the eCPR initial reporting requirement, and that the form or its elements will be required if the Labor Commissioner investigates. See the Form A-1-131 guide. The attachment says nothing more about eComply Solutions, so ask the Commission how to get access.

Each payroll record must contain or be verified by a written declaration under penalty of perjury, under Labor Code 1776(a). The paper route here calls for original wet signatures, and the attachment does not say whether a scan or electronic signature is accepted, so ask first. See who signs certified payroll.

Monthly filing with DIR

Item 2 under Payroll Reporting Requirements calls for electronic certified payroll reports through DIR's online portal every month. That is a second filing. DIR's public works FAQ (dated September 2024) says submissions to a union, a prime contractor, an awarding body or a labor compliance program do not fulfill the requirement to submit to the Labor Commissioner.

The state rule is Labor Code 1771.4(a)(3). Each contractor and subcontractor furnishes records directly to the Labor Commissioner, electronically, at least once every 30 days while work is performed and within 30 days after the last day. The late penalty is $100 a day, up to $5,000 per project, and it is not levied until 14 days after the due date. See the DIR eCPR guide for the portal.

When the DIR step may not apply

Two DIR sources point in different directions, so read both. DIR's exemption page (dated July 2016, "until further notice") says "Only" projects monitored and enforced by an approved labor compliance program, or covered by a qualifying project labor agreement, may be exempted from submitting certified payroll to DIR. It names four legacy programs (Caltrans, the City of Los Angeles, LAUSD and the County of Sacramento), not the Commission.

DIR's FAQ (dated September 2024) also describes a small project exemption: $25,000 or less for new construction, alteration, installation, demolition or repair, and $15,000 or less for maintenance, measured on the whole contract between the awarding body and the prime. The statute is worded differently. Labor Code 1725.5(f) lifts registration at the same amounts, for construction, alteration, demolition, installation, or repair work, or maintenance work. Labor Code 1771.4(a)(4) excuses an unregistered contractor on such a project from furnishing records directly to the Labor Commissioner, though it must keep them for at least three years. Lettered duty I of the attachment cites section 1725.5(f) as an exception to DIR registration only, and the attachment does not address any exemption from the monthly DIR filing, so if your job is that small, ask the Commission in writing whether it still expects it.

Forms due before work starts

The attachment calls for the contractor and each subcontractor to submit these seven items to the Commission before commencing work.

1. Authorized Signatory
2. Checklist of Labor Law Requirements
3. Request for Dispatch of an Apprentice (Form DAS 142), as applicable
4. Public Works Contract Award Information (Form DAS 140), as applicable
5. Fringe Benefit Statement
6. List of Trades and/or Crafts
7. Project Contact Sheet

The attachment says the Commission's website posts these forms, a page that could not be read, so this page cannot describe items 1, 2, 5, 6 and 7.

The DAS 140 (Rev. 1/04) says it goes to the apprenticeship committees, not to the Division of Apprenticeship Standards, and 8 CCR 230 sets a 10 day window from execution of the contract, no later than the first day workers are on the job. The DAS 142 (6/24) is the dispatch request. See DAS 140 and DAS 142, explained.

Proof of payment and the completion affidavit

Items 3 to 5 under Payroll Reporting Requirements also list proof of actual payment of wages to all employees and proof of actual payment of fringe benefits to all employees, both without qualification, and proof of the use of apprentices "as and when required by law". The attachment gives no form or schedule for them.

Lettered duty G adds a closing step: when the work is complete, you sign and notarize an affidavit of compliance, in a form the Commission provides, certifying compliance with Labor Code sections 1720 to 1861.

The $1,000 line and withholding

A note at the top of the attachment applies California prevailing wage to any public work project over $1,000, counting every purchase or work order within one project, however small. The line matches Labor Code 1771, which excludes projects of $1,000 or less.

Lettered duty H says that if the Commission finds a violation of Labor Code sections 1720 to 1861, including delinquent or inadequate payroll records, it shall withhold any payments due to you. It cites Labor Code 1771.6, which requires an awarding body that enforces under section 1726 or 1771.5 to give written notice describing the violation and the amount withheld, and to tell you how to seek review. If a notice arrives, see notice of withholding of contract payments.

Check your own contract

1. Read Section 21 of the General Conditions (Attachment B). See which prevailing wage boxes are checked. In the copy read, Section 106 of the agreement says the Prevailing Wage Attachment is incorporated only in accordance with Section 21, and Section 21 says that if both boxes are checked the contractor alone must work out which terms apply.
2. Compare your Attachment E with the routes and forms above.
3. Ask the Commission in writing about each gap. The attachment gives no weekly due day, no rule on whether subcontractors submit directly or through the prime, no other accepted format, and no labor compliance contact, and it names no consequence for a late weekly report. Duty H covers withholding for Labor Code violations, including delinquent records.
4. Confirm the DIR project ID with the awarding body before the first monthly filing. See how to find the DIR project ID.

WellStanding prepares the WH-347 and, where it applies, the eCPR from the payroll export you already run, and a person reviews every filing. You review and sign, and nothing is filed until you have signed; we never sign for you.

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