What precautions should an entity take if it is leveraging utility funds with ARRA funds?

Utility funds should not be comingled with ARRA funds. They are not Federal funds and are not subject to any DBA provision. €¢ The CAA has Crisis Intervention Program (CIP) money, which it receives through the Low Income Home Energy Assistance Program (LIHEAP) and which is not subject to the DBA.

The CIP money is used for heat emergencies; for example, if a home's furnace was broken and the family is without heat, the CAA would use CIP money to immediately install a new high efficiency furnace. If the CAA hires a contractor to do a CIP job on a house that is scheduled to be weatherized under the Weatherization Assistance Program (WAP), will the CIP work subject to the DBA? If, as in the example, the CIP work was completed prior to any ARRA-funded weatherization work, the CIP work would not be subject to the prevailing wage requirements of the Davis-Bacon Act.

In this answer, the work crews doing the CIP work and the WAP ARRA-funded work are not working at the same time and the CIP ... more.

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