SF-1444: how to request an additional classification on a Davis-Bacon job

When a missing classification becomes your problem

Each weekly Statement of Compliance says every worker was paid at least the wage and fringe rates for the classification of work actually performed (29 CFR 5.5(a)(3)(ii)(C)). If the work fits no line, there is no rate to certify against. The 2023 final rule describes a conformance as adding the missing classification and rate to the wage determination for one contract only.

The three tests, and when you do not need a request

All three criteria in 29 CFR 5.5(a)(1)(iii)(A) must be met before conformance is appropriate.

The FAR 52.222-6 clause adds a fourth criterion for helpers: the helper classification must prevail in the area where the work is performed (paragraph (c)(1)(iv)).

Conformance cannot be used to split, subdivide, or avoid a listed classification (5.5(a)(1)(iii)(B)). First look for a listed rate: a wage determination may list one for a classification that conformance requests regularly cover, and work in it must be paid at least that rate (current 5.5(a)(1)(ii)). If you merely doubt whether a listed classification covers the work, the 2023 preamble says the contracting agency should submit a conformance request or seek guidance from the Wage and Hour Division under 29 CFR 5.13, which takes requests by email to dgceinquiries@dol.gov, by mail to the Administrator, or by other means the Administrator directs.

Who sends it, and where it goes

You do not send the SF-1444 to DOL yourself. The form's instruction line has the contractor submit it to the Contracting Officer. On a contract awarded by a federal agency, FAR 22.406-3 sets the steps, because the FAR applies to federal acquisitions. On federally assisted work, such as HUD-assisted or federal-aid highway jobs, 29 CFR 5.5(a)(1)(iii)(A) puts the same duty in the contract clause, and the agency that awards or administers the contract sets the route. The FAR steps are:

1. You submit it to the contracting officer, who under FAR 22.406-3(a) must require it for any classification not on the wage determination, and who checks the three tests under paragraph (b).
2. The officer reports to the Administrator of the Wage and Hour Division with a copy of the form: paragraph (c)(1) if all agree, (c)(2) as a referral, with everyone's views and a recommendation, if they disagree or the tests are not met.
3. The Administrator acts within 30 days of receipt, or says within that period that more time is needed, and the officer forwards DOL's action to you (paragraph (d)).

The 2023 final rule moved the 29 CFR 5.5 clause to (a)(1)(iii) and has the officer email the report to DBAconformance@dol.gov, but most of it applies only to contracts entered into after October 23, 2023. An older contract carries (a)(1)(ii), which as of August 23, 2023 named no email address and had the report sent to the Administrator at Washington, DC 20210.

Federal-agency contracts carry a conflict. FAR 52.222-6 is still dated AUG 2018 in eCFR as of November 3, 2026, and its paragraph (c)(2) sends the report to the Administrator, Washington, DC 20210, with no email address. DOL's own text is mixed on which clause governs a FAR contract entered into after October 23, 2023. Section 5.5(e) makes the 5.5 clauses "(or their equivalent under the Federal Acquisition Regulation)" part of every covered prime contract. The 2023 preamble says that for a FAR contract entered into after the rule took effect but before the FAR is amended, 5.5(e) incorporates the FAR clauses mandatory when the contract was entered into, but it also says that in the same period agencies must use the 5.5(a) and (b) clauses "to the maximum extent possible under applicable law." Ask the contracting officer in writing which route your contract uses.

On federal-aid highway work, the conformance clause is in Section III, paragraph 1.c of Form FHWA-1273, and the June 25, 2026 revision has the email route. The revision in your contract may be earlier, so check the date printed on your copy and ask the agency which clause text applies. Since June 10, 2026, attaching the form is optional for the agency, but it must still ensure compliance with the provisions the form cites. See our 2026 FHWA-1273 guide.

Where it goes first depends on who administers the money. On HUD-assisted work, LR-22-01 (April 4, 2022) has local agencies submit SF-1444 requests directly to DOL without going through HUD (see our housing authority guide). HUD's handbook paragraph 3-17 names whd-cbaconformance_incoming@dol.gov for these requests, and the pages carrying it are marked changed on 05/01/2023, before the October 23, 2023 rule took effect. For contracts entered into after that date, 29 CFR 5.5(a)(1)(iii)(C) and (D) name DBAconformance@dol.gov. Ask your agency who forwards the request to DOL and which address it uses.

When to file

29 CFR 5.5(a)(1)(iii) and FAR 22.406-3 set a 30-day clock for DOL but name no filing deadline for you. Two agency sources give timing for their own work, and yours may differ.

• NDDOT work. The June 2026 handbook says requests "should be made prior to commencement of work on the contract," which sets an expected filing point.
• HUD work. Handbook paragraph 3-17 says to request after contract award, and only after the wage decision's "lock-in" date, which sets the earliest filing point.

Filing after workers have started does not change the first-day rule below.

Which copy of the form to use

GSA's forms page lists the current revision as October 2023, and the PDF it links is the copy checked for this page. The sources conflict: FAR 53.222(f), current in eCFR as of November 3, 2026, still names Rev. 4/2013. The PDF itself states "Previous Edition Is Not Usable," so Rev. 10/2023 is the one to use. Look for "REV. 10/2023" at the bottom of the copy you download.

Filling it in, block by block

The form has the contractor complete items 3 through 16 and submit it in quadruplicate to the contracting officer, so ask the officer what format they want.

What to pay and record until DOL answers

The approved rate applies to every worker in the classification from the first day anyone worked in it (29 CFR 5.5(a)(1)(iii)(E), or (a)(1)(ii)(D) as of August 23, 2023; FAR 52.222-6(c)(4); FAR 22.406-3(d)(2)). If you paid less for earlier weeks, the gap is owed. Neither text says what to pay in the meantime, and DOL's own conformance pages could not be read for this page. Ask the contracting officer in writing and keep the answer.

• Keep the hours apart. Paying each classification's rate for time worked in it requires payroll records that accurately show that time (5.5(a)(1)(i)), so track hours by worker, day and classification from day one. See our WH-347 guide for the signed form.

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