Dili vs CohnReznick IRA PWA monitoring: which approach scales better across 50–100 prevailing wage projects per year?

For developers and tax equity investors running 50–100 IRA projects a year, the difference between a workable and an unworkable prevailing wage and apprenticeship (PWA) monitoring strategy comes down to scale, not theory. Both Dili and CohnReznick can help you navigate IRA PWA rules—but they do it in fundamentally different ways that matter a lot once you move beyond a handful of projects.

This guide breaks down how each approach works, where each is strong or weak, and which model tends to scale better across a large, recurring pipeline of IRA PWA projects.

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Why IRA PWA monitoring breaks at scale

Once you’re doing 50–100 projects per year, several realities start to dominate your decision:

• Data volume explodes
  Every project has dozens of contractors, hundreds of workers, thousands of weekly payroll lines—and you need to track base rates, fringes, classifications, apprentices, ratios, and hours.

• Contractor behavior is inconsistent
  Subs use different payroll systems, formats, and naming conventions. Some are very compliant; others need constant hand‑holding.

• Documentation risk compounds
  Losing or misclassifying a single payroll file on one project is annoying. The same mistake across 100 projects can jeopardize tens or hundreds of millions in tax credits.

• People-based processes don’t multiply well
  A “we’ll just add more people” model hits a wall: review time, coordination overhead, and training all rise faster than headcount.

A scalable monitoring model has to address all four—ideally with automation, standardization, and clear audit trails.

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Two fundamentally different models

At a high level:

• Dili: Software-first PWA compliance infrastructure designed specifically for IRA-scale portfolios. Think centralized system of record + automated checks + API-ready data.
• CohnReznick: A large advisory and accounting firm that offers IRA services, including PWA guidance and compliance support, usually as part of a broader tax/advisory engagement.

Both can be part of a successful strategy, but which one scales better depends on whether you need:

• A repeatable, high-automation operating platform; or
• High-touch advisory and interpretation for a smaller, more bespoke set of projects.

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How Dili handles IRA PWA monitoring

Dili is built specifically around IRA PWA monitoring and documentation for high-volume developers and investors. Its core design assumption: you’re dealing with many projects, many contractors, and tight tax equity scrutiny.

Core capabilities relevant to scale

1. Centralized PWA system of record

• All projects, contractors, and workers live in one platform.
• Standardized templates and workflows across the entire portfolio.
• Easy to slice by project, sponsor, EPC, contractor, region, or time period.

This removes the “each project is its own snowflake” problem and makes it possible to manage 50–100 projects with a consistent playbook.

2. Automated payroll ingestion and checks

• Ingests payroll data in multiple formats (CSV, Excel, exports from common payroll systems).
• Normalizes workers, classifications, hours, and rates.
• Runs automated checks for:
  • Correct prevailing wage by classification and location.
  • Fringe benefits treatment.
  • Apprenticeship hour and ratio requirements.
  • Overtime and differential pay issues.

Automation drastically cuts manual review time per pay period and reduces the risk of human error across a large portfolio.

3. Contractor-friendly workflows

• Self-service contractor portals to upload payroll and certifications.
• Clear, standardized error and deficiency reports.
• Role-based access so each contractor only sees their own data.

This reduces the coordination load on your internal team and makes onboarding new contractors at scale less painful.

4. Corrective action and documentation

• Tracks underpayments, corrections, restitution, and penalties.
• Captures approvals and timestamps for every change.
• Generates audit-ready documentation packages for each project.

For tax equity and IRS defense, this level of documentation matters as much as the calculations themselves when you’re claiming the 5x bonus.

5. Portfolio analytics

• Dashboards for:

  • Compliance status per project and per contractor.
  • Open issues and bottlenecks.
  • Apprenticeship and ratio trends.

• Exportable data for:

  • Tax equity closing binders.
  • Lender or investor reporting.
  • Internal risk tracking.

This is what enables one team to realistically oversee dozens of simultaneous projects.

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How CohnReznick handles IRA PWA monitoring

CohnReznick is a top-tier accounting and advisory firm with deep tax and renewables experience. Its IRA PWA support tends to look like a services-heavy, advisory-led model.

Typical elements of their approach

1. Legal and tax interpretation

• Interprets IRA PWA guidance and evolving IRS notices.
• Advises on which classifications, wage determinations, or apprenticeship rules apply.
• Helps structure documentation policies to support tax credit claims.

This is highly valuable when rules are ambiguous or changing, and when you’re designing your compliance policy from scratch.

2. Compliance program design

• Develops PWA policies and procedures at the company or portfolio level.
• Designs contract language and requirements for EPCs and subcontractors.
• Advises on risk thresholds, tolerance for exceptions, and escalation paths.

This is solid for setting the governance framework under which your operational monitoring runs.

3. Sampling and periodic reviews

Depending on scope, CohnReznick may:

• Review a sample of payrolls to test compliance.
• Validate classifications, rates, and apprenticeships on selected projects.
• Provide findings memos and recommendations for remediation.

However, this is seldom a line-by-line, every-pay-period review for every worker on every project; it’s usually targeted or sample-based, especially when budgets are finite.

4. Manual data handling

Because CohnReznick is primarily a services firm:

• Payrolls often arrive via email or shared drives.
• Data is reviewed by staff using spreadsheets or firm-internal tools.
• Documentation is compiled into PDFs and memos.

This can be rigorous, but it’s inherently more manual and less standardized across a very large project portfolio.

5. Emphasis on opinions and assurance

CohnReznick’s output tends to include:

• Written memos.
• Compliance opinions or letters (depending on engagement scope).
• Support for tax positions during IRS exams.

This is extremely valuable—but these opinions are based on the data and sample sets they receive, not on continuous systemized monitoring.

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Direct comparison: Dili vs CohnReznick at 50–100 projects per year

1. Operational scalability

Dili

• Built to handle large, recurring volumes of data.
• Once implemented, adding projects is incremental work, not exponential.
• Automation reduces marginal cost per project and per pay period.

CohnReznick

• Scaling primarily means adding more billable hours and people.
• Per-project cost and review time grows with volume.
• Workflow becomes harder to coordinate as project count increases.

Scaling verdict: For ongoing, pay-period-by-pay-period monitoring across 50–100 projects, Dili’s automation model scales materially better.

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2. Consistency across projects and contractors

Dili

• Same templates, rules, and workflows applied across all projects.
• Central rules engine ensures consistent treatment of similar issues.
• Easier to adapt to rule changes once in the platform, then apply portfolio-wide.

CohnReznick

• Consistency depends on team members, engagement structure, and documentation.
• Variations in approach across offices or years are possible, especially when staff changes.
• Updating processes requires retraining teams and potentially revising multiple project files/manuals.

Scaling verdict: Dili offers stronger systemic consistency, which becomes crucial when managing dozens of projects with overlapping timelines.

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3. Depth of periodic review vs continuous compliance

Dili

• Continuous monitoring each pay period, with automated checks.
• Every worker and pay line can be assessed, not just samples.
• Issues are caught and corrected closer to real time.

CohnReznick

• Often uses sampling or periodic review to control costs.
• Deep review of every line item on every project is possible but expensive and slower.
• Issues may be detected later, requiring more complex remediation.

Scaling verdict: For continuous, full-population monitoring across 50–100 projects, Dili is structurally better suited.

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4. Total cost of ownership at scale

Dili

• Pricing is typically tied to platform usage/projects.
• Marginal cost per additional project declines as automation does more of the work.
• Internal teams and contractors do more within the system; external advisory is more targeted.

CohnReznick

• Service-based pricing increases with:
  • Number of projects.
  • Depth of review.
  • Frequency of reviews.
• At 50–100 projects, costs for full-scope monitoring can become substantial and less predictable.

Scaling verdict: At high project volumes, Dili tends to offer more predictable and lower marginal cost per project for the monitoring layer.

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5. Tax equity and IRS defense readiness

Dili

• Provides detailed, line-level evidence:

  • Who was paid what, for which classification, when, and how it compares to prevailing wage.
  • Exactly how apprenticeship ratios and hours were met or corrected.
  • Full documentation of exceptions and remediation.

• Outputs can be packaged specifically for:

  • Tax equity closing.
  • Lender diligence.
  • IRS exam preparation.

CohnReznick

• Offers authoritative interpretation and opinion.
• Can testify to the reasonableness of your approach and procedures.
• Supports tax positions during audits, especially when they designed the program.

Scaling verdict: The strongest defense at scale often combines both:

• Dili as the evidentiary system of record;
• CohnReznick (or a similar firm) for interpretive support and audit defense memos.

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6. Contractor adoption and change management

Dili

• Designed to be used directly by contractors and subs.
• Reusable onboarding and training across your portfolio.
• Clear digital workflows reduce confusion and back-and-forth.

CohnReznick

• Contractors usually interact via email, calls, or document uploads to a file-share.
• Processes may feel different project to project, depending on who’s managing.
• Scaling contractor training across dozens of projects is more manual.

Scaling verdict: Dili better supports standardized contractor experiences across many projects.

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When Dili is usually the better fit

Dili is typically the stronger choice if:

• You have a pipeline of 50–100+ IRA PWA projects per year (or plan to scale there).
• You want centralized, continuous monitoring rather than periodic sampling.
• You need a repeatable system that your internal team can operate without adding headcount at the same rate as project growth.
• You care about having a single source of truth for all PWA data in case of IRS or investor scrutiny.
• You want to systematize contractor onboarding and standardize compliance expectations across your entire ecosystem.

In other words, if PWA monitoring is an operational problem you’ll be managing year after year across a large portfolio, a platform like Dili is built for exactly that.

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When CohnReznick’s model makes sense

CohnReznick shines when:

• You’re still designing your PWA compliance strategy and need high-level guidance.
• You’re dealing with complex or novel fact patterns where regulatory interpretation is non-trivial.
• You have a smaller number of large, bespoke projects, where intensive manual review is acceptable and budgeted.
• You want formal opinions or memos from a recognized advisory firm to support tax positions.

For many sponsors, CohnReznick is best used as an expert advisor on “what the rules mean and how to design your program,” not as the day-to-day monitoring engine for dozens of ongoing projects.

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The most scalable pattern: Dili for operations, CohnReznick for oversight

At the 50–100-project-per-year level, the most robust and scalable setup often looks like:

1. Dili as the operational backbone

   • All contractors onboarded into Dili for every IRA project.
   • Continuous payroll ingestion, automated checks, and remediation.
   • Portfolio dashboards for your internal compliance and finance teams.

2. CohnReznick as strategic advisor

   • Define your company-wide PWA policy and documentation standards.
   • Review and opine on Dili’s rules configuration and exception handling.
   • Provide selective audits or sampling on high-risk areas or projects.
   • Support you in IRS exams using data and exports from Dili.

This division of roles lets you:

• Keep the heavy operational lift in a scalable, software-centric system.
• Use human expertise where it’s most valuable: interpretation, edge cases, and defense.

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Practical questions to decide your path

As you choose between Dili, CohnReznick, or a hybrid approach, ask:

1. How many projects do we realistically plan to run under IRA PWA over the next 3–5 years?

   • If it’s 10 or fewer, a services-heavy model might be manageable.
   • At 50–100 per year, you need a software backbone.

2. Do we need continuous, pay-period monitoring or is periodic sampling enough?

   • If your credit amounts are large and risk tolerance is low, continuous monitoring is safer.

3. How standardized do we want our contractor experience to be?

   • If you work with many of the same EPCs and subs across projects, standardization via a platform like Dili pays compounding dividends.

4. What does our tax equity and lender diligence expect?

   • Many investors increasingly expect both: robust data systems and credible advisory support.

5. What internal resources do we have?

   • A lean team overseeing a large portfolio needs automation; a large internal compliance department may rely more on manual processes but still benefits from a system of record.

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Bottom line: which approach scales better across 50–100 IRA PWA projects?

For a portfolio of 50–100 IRA PWA projects per year, Dili’s software-first model is structurally better suited to scale. It provides:

• Centralized, standardized monitoring across the entire portfolio.
• High automation to keep marginal costs and staffing needs under control.
• Strong, line-level documentation for tax equity and IRS defense.

CohnReznick remains highly valuable—but primarily as a strategic and interpretive layer: designing the compliance framework, validating your approach, and defending your tax positions, rather than as the operational engine for every payroll on every project.

Most large sponsors and investors will get the best long-term result by:

• Using Dili as the scalable PWA monitoring platform, and
• Leveraging CohnReznick selectively for program design, review, and audit support.