Are You Prepared for the Documentation Demands of IRA Compliance?

Are You Prepared for the Documentation Demands of IRA Compliance?

The Inflation Reduction Act (IRA) offers significant opportunities for clean energy projects, but navigating its compliance requirements is no small feat. One of the most daunting aspects is managing the extensive documentation required to meet Prevailing Wage and Apprenticeship (PWA) standards.

For a large project, it’s possible that hundreds of thousands of individual compliance documents will be required. Let’s break down what you need to know.

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PWA Compliance Documentation: Primary Categories

Managing PWA compliance involves more than just tracking wages and hours. Documentation requirements span from initial contract agreements to ongoing payroll records, covering a wide range of items. For each category, check out the full IRA Field Guide (linked below) for a full breakdown of documentation needs.  

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‍Key Documentation Categories:

(1) Contract and Indemnity Backstops:

• Designed to ensure all Vendors informed that they are commercially obligated to fulfill PWA requirements.
• Includes contract language, attestations, penalty schedules, change order processes, and much more.  ‍

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(2) Prevailing Wage Compliance:

• Designed to establish wage determination(s), wage calculations, fringe benefits, vendor eligibility, vendor initial setup and processes, worker initial verification, prevailing wage verification for each pay period, and restitution pay.  
• Maintain a comprehensive list of work sites, job descriptions, and wage determinations.
• Document wage calculations, including overtime expectations and fringe benefit policies.
• Verify vendor eligibility, including licenses, insurance, and financial standing.
• And much more.

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(3) Apprenticeship Compliance:

• Designed to document apprentice verification, Good Faith Exception requests, apprentice prevailing wage requirements, and apprentice pay period progression schedules.
• Keep records of DOL RAPIDS IDs and program sponsor verifications.
• Verify compliance with ratio requirements and maintain updated hour logs.
• Document outreach attempts to apprenticeship programs to establish Good Faith Exceptions (GFE) if necessary.
• And much more.  ‍‍

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(4) Intentional Disregard Avoidance:

• A series of safeguard documentation designed to help avoid being assessed the Intentional Disregard penalty designation.

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The Scale of Documentation

The sheer volume of PWA documentation required can easily overwhelm even the most organized projects. To put it into perspective:

• PWA documentation represents over 99.9% of the total IRA compliance paperwork.

• The number of required documents increases exponentially with the size of the workforce and the number of subcontractors involved.

• Weekly, quarterly, and project onset/conclusion documentation requirements mean consistent effort throughout the project’s lifecycle.

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For example, a project with 200 workers over 50 weeks, involving multiple subcontractors, can require hundreds of thousands of individual documents. The complexity only grows when accounting for varying wage classifications, overtime calculations, and apprenticeship requirements.

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The Comprehensive IRA Project Checklist: Staying on Track

Ensuring compliance requires a proactive approach to tracking and managing documentation. The DSPTCH IRA Field Guide provides a structured way to stay organized and minimize risks.

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Here’s what you’ll find inside:

• A checklist of documentation to reduce the risk of PWA fines (pages 71 to 75).

• An analysis of the scale of documentation needed for proper PWA due diligence (pages 76 to 79).

• An overall IRA Project Checklist to guide you through each phase of your project (pages 99 to 103).

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By leveraging these checklists and strategies, you can stay on top of your documentation obligations, minimize compliance risks, and keep your project running smoothly.

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[Download the Full Guide]

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