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Copeland Anti-Kickback Act


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Q.  The BPPM required clauses language states that Davis Bacon and Copeland Anti-Kickback Act provisions only apply to construction contracts over $2,000. However, the new Circular 4220.1F (Appendix D page 2 of 8) indicates that Copeland Anti-Kickback Act provisions apply to all construction contracts, regardless of threshold.

A.  The answer is that the new FTA Circular 4220.1F should be followed.  Note: This Q/A was posted the month of: 02-2009.