Christopher Ruhman, Senior Counsel in the firm’s Houston office, authored an expert analysis in the inaugural edition of Law360’s Construction section entitled “HUD’s Increased Use Of Split-Wage Decisions Is Troubling”, published May 7, 2018.  The article describes how HUD’s Office of Davis-Bacon and Labor Standards (ODBLS) has recently begun applying split-wage rate decisions to multifamily projects of four stories or less. Historically, ODBLS assigned these apartment properties the single “residential” wage determination. Apartment amenities such as parking, club houses, streets, etc. were generally considered incidental in function to the overall character of the project. Accordingly, ODBLS rarely assigned a separate wage determination to such projects.