Winning a federally funded construction project is great news for your backlog. It also makes your company responsible for Davis-Bacon prevailing wage compliance for every contractor on the jobsite. Here is the checklist our compliance team runs on every federal project.
Before construction starts
First, confirm the correct wage determination is in your contract and matches your project type: building, residential, heavy, or highway. Second, map every planned scope of work to a craft classification on that determination. If your crews will perform work that no classification covers, file a conformance request with the Department of Labor early. Third, put Davis-Bacon flow down language in every subcontract, because the prime contractor is responsible for subcontractor violations.
During construction
Collect a certified payroll report from every contractor and subcontractor every week, on form WH-347 or an approved equivalent. Review classifications and wage rates before submitting, not after. Post the wage determination and the required Davis-Bacon poster at the jobsite where workers can see them. Track apprentices carefully: they must be individually registered in an approved apprenticeship program, employed within the allowable ratio, and paid the correct percentage of the journeyman rate.
Fringe benefits
Davis-Bacon rates include a fringe benefit component. Your company can pay it in cash, into bona fide benefit plans, or a combination. Whatever the approach, the math needs to be documented and consistent, and annualization rules apply when benefit contributions cover both public and private work.
Records and closeout
Keep payroll records, timecards, fringe documentation, and apprenticeship certificates for at least three years after project completion. At closeout, verify there are no missing payroll weeks from any subcontractor before final payment and retention release.
When to bring in help
If any item on this checklist made you pause, that is the gap an investigator will find. We manage Davis-Bacon compliance for general contractors from preconstruction through closeout. Reach out for a free consultation on your next federal project.