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Subcontracting Compliance

In order to be compliant with CDOT specifications and Federal regulations, Prime Contractors must be aware of key subcontracting requirements that apply to all Construction Contracts.

FHWA 1273

The FHWA 1273 are required contract provisions for every contract using Federal funds. The 1273 includes all of the Civil Rights requirements that are contractually required when working on a Federal-aid job. It is the Prime Contractor's responsibility to ensure that the 1273 is incorporated into every subcontract.

Registration in B2GNow

Per Section 108.01 of CDOT's Standard Specifications, all contracting firms must Register in the B2GNow system before being approved to work on a CDOT contract as a prime contractor, subcontractor, trucker, or supplier. CDOT must provide the information requested annually to FHWA, it helps CDOT gain a better understanding of the contracting community, and ensures the correct vendor account is transferred to LCPTracker for certified payroll reporting. Only one registration is required per firm, though firms may have multiple users associated with the firm’s account. 

To Register or verify that your firms is Registered, log into B2GNow and click Contractor's Registration/Prequalification in the menu on the left. 

Permission to Sublet

CDOT requires all Prime Contractors to submit a Form 205, Permission to Sublet, for all subcontractors and suppliers on the job. This form ensures that CDOT is aware of every contractor working on a particular job, and adds subcontractors and suppliers to the B2GNow system, which is the system of record for Prompt Payment.

Prompt Payment

Per federal regulation and Section 109.06 of CDOT's Standard Specifications, CDOT requires that contractors pay their lower-tier subcontractors promptly upon receiving payment from CDOT or their subprime contractor. This regulation is designed to help address cash flow issues for small businesses by keeping progress payments moving down to lower-tier subs in a timely fashion.

DBE Participation

Monitoring DBE participation is a critical element of ensuring contract compliance. Per federal regulation and CDOT's DBE Standard Special Provision, Prime Contractors are responsible for subcontracting a percentage of the work to certified DBEs who are able to perform a Commercially Useful Function (CUF) on the job, or to demonstrate a Good Faith Effort (GFE) to meet that percentage in the event there is a shortfall in DBE participation.


B2GNow is a national system used to monitor DBE participation and prompt payment compliance. CDOT's instance of B2G can be found by clicking the link below. Should you need help navigating B2G, click Contact Support in the top right corner of the home page.

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