Making CUF Work in the Digital Age: A Real-World Guide

CUF requirement
  • April 8, 2024

Today’s projects don’t look like they used to. Contracts aren’t just about concrete, cranes, and job trailers anymore—they’re also about data dashboards, digital collaboration, and managing workflows across time zones. With all these changes, one thing remains the same: everyone on a project is expected to do the work they were hired to do.

That’s where Commercially Useful Function, or CUF, comes in.

CUF is a requirement that ensures subcontractors and suppliers on a project are doing more than just lending their names to meet contract goals. Whether you’re a public agency, a general contractor, or a certified small business, understanding how CUF works—and how to prove it—is essential in today’s digital-first construction and procurement environment.

What CUF Really Means (And Why It Matters)

A company is performing a Commercially Useful Function when it's actively and directly responsible for a clear portion of the work on a contract. This means:

  • They’re executing a distinct element of the job with their own crew and tools.

  • They’re managing their scope, paying for labor and materials, and supervising the work.

  • They aren’t acting as a middleman or pass-through just to help someone check a box.

CUF is especially important in public-sector work, where government funding—from agencies like GSA, HUD, or DOD—comes with strict requirements to prevent fraud and ensure fairness. Agencies want to see real participation, not paper participation.

Projects funded by federal or state money, especially those tied to DBE, MBE, WBE, or SBE goals, will often face CUF audits. And in cases involving prevailing wages or Davis-Bacon requirements, enforcement is even tighter.

The takeaway? CUF is not optional. It’s the difference between real partnership and compliance risk.

The Challenge: CUF in a Tech-Driven, Remote-Friendly World

In the past, CUF was easier to confirm. You’d drive by a job site and see the supplier’s trucks or talk to a foreman about who was laying pipe or pouring concrete.

But in the digital age, CUF is tougher to monitor. With remote teams, cloud-based tools, and multi-layered contracting structures, verifying who’s doing what takes more than a clipboard and a jobsite visit.

Some common hurdles today’s project teams face:

  • Subcontractors working virtually and off-site

  • Multiple tiers of vendors, making it harder to track real contribution

  • Software and IP (not materials) being the “product” being delivered

  • Rapid tech changes, which make it harder for small firms to keep up without support

  • Work being spread across several companies, leading to diluted accountability

This is why digital CUF tools and smarter contract tracking are becoming essential—not just for compliance, but for building better projects with partners who pull their weight.

How Pegbo Makes CUF Visible, Verifiable, and Practical

Now, here’s where Pegbo comes in. CUF doesn’t have to be confusing or complicated—and Pegbo is built to make it practical, transparent, and trackable for everyone involved.

👷‍♀️ What Pegbo Does for CUF:

Shows Who’s Doing the Work—In Real Time

Pegbo dashboards track who is assigned to which task, how much of the project budget they control, and where they’re showing up. No more guessing if someone is just “on the roster.”

🕒 Tracks Labor and Time On-Site

Our time tracking and workforce logs help confirm that small business subcontractors have boots on the ground—not just business cards on the contract.

📸 Logs Proof of Work

Daily logs and uploadable photos show real performance, not just attendance. This helps document contributions for CUF audits and reports.

🛠️ Verifies Equipment Usage

Is the subcontractor using their own equipment? Pegbo tracks this too, supporting CUF standards that require firms to bring their own tools—not just lend their name.

💸 Follows the Money

With Pegbo’s invoice and payment tracking, you can show that payments are going to the subcontractor doing the actual work—not being filtered through a middleman.

📁 Keeps Certifications and Scope of Work in Sync

Pegbo makes it easy to keep scopes, certifications, and contract terms current, ensuring suppliers stay aligned with what they’re contracted to do.

🚨 Flags CUF Risks Before They Become Problems

Our real-time utilization tools alert you when subcontractor activity drops or when something doesn’t match what’s expected—so you can fix it early and stay in compliance.

Real-World Solutions: What CUF Looks Like in Action

Let’s say you’ve got a project funded by a state transportation agency with 25% subcontractor participation goals. You’ve onboarded a certified SBE subcontractor to manage your project’s GIS mapping work.

With Pegbo, you can:

  • Confirm that the SBE team is logging work hours on mapping tasks

  • Track whether they’re using their own proprietary software or relying on yours

  • Attach deliverables to their scope of work

  • Validate that their invoices match the work completed

  • Provide a clear record if the agency requests a CUF audit

This isn’t just about staying compliant—it’s about building confidence and transparency with partners, funders, and clients.

CUF Is a Standard Worth Holding Onto

CUF isn’t red tape—it’s a way of making sure the work is shared fairly, the right people get credit, and contracts lead to real business opportunities.

When done right, CUF does more than meet a goal—it opens doors for capable suppliers to show what they can do, strengthens project results, and creates a better foundation of trust across the board.

In today’s digital world, making CUF work means adapting how we manage projects. With platforms like Pegbo, we can do just that—bringing clarity, accountability, and support to every contract, every supplier, and every job site (even the virtual ones).

Whether you're a general contractor trying to stay ahead of compliance or a small business ready to contribute more than just credentials, Pegbo gives you the tools to prove the work, protect the contract, and build with confidence.

 

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