The FAA Reauthorization Act of 2018 instituted a requirement for recipients to report covered prompt payment complaints to the FAA Office of Civil Rights. The FAA had temporarily set up a survey tool as a means for recipients to report complaints, but have now launched a new prompt payment complaint reporting module directly in the FAA Civil Rights Connect System. Recipients can now report the details and outcomes of covered complaints by navigating to the “Prompt Payment Complaints” section of the dashboard or from within the airport file in the system. The new module is live now and can be used immediately.
This new reporting method replaces the previous survey-style questionnaire, which has been discontinued. If you do not have a user account in the FAA Civil Rights Connect System, you can create one from the home screen by selecting “User Lookup, Password Reset, and Create Account.”
As a reminder, Federal regulations (49 CFR Part 26, §26.29) require airport grant recipients to ensure prime contractors pay subcontractors – both DBE and non-DBE – for satisfactorily completed work no later than 30 days after the contractor receives payment for the work performed by the subcontractor. Airport grant recipients must also implement appropriate mechanisms to actively monitor projects and ensure all subcontractors are being paid promptly, including the release of any retainage being held from subcontractors. U.S. DOT’s Official Questions and Answers (Q&A’s) on the Disadvantaged Business Enterprise Program Regulation provides guidance on prompt payment monitoring. This document is located at https://www.transportation.gov/civil-rights/disadvantaged-business-enterprise/dbe-guidance.