Davis-Bacon Prevailing Wage Compliance Manual

Davis-Bacon Prevailing Wage Compliance Manual

Alliance for Contractors | Comprehensive Compliance System

Build Better. Build Smarter. Build Compliant.

Executive Overview

The Davis-Bacon Act requires contractors and subcontractors on federal construction projects exceeding $2,000 to pay workers prevailing wages and fringe benefits. This comprehensive compliance manual provides the systems, forms, and procedures necessary to maintain full compliance while protecting your business from costly violations and penalties.

Critical Compliance Note: Davis-Bacon violations can result in contract termination, debarment from federal projects for up to three years, and significant financial penalties. This manual provides the framework to eliminate these risks through systematic compliance.

Key Requirements Overview

  • Pay prevailing wages as determined by Department of Labor wage determinations
  • Submit weekly certified payroll reports
  • Maintain detailed payroll records for three years
  • Post wage determinations at job sites
  • Conduct employee interviews when required
  • Ensure subcontractor compliance

🚀 Alliance Integration: Automated Compliance System

Our integrated platform automatically tracks wage determinations, generates certified payrolls, manages compliance documentation, and provides real-time violation alerts. Transform manual compliance into an automated competitive advantage.

Key Features: Real-time wage determination updates, automated payroll certification, compliance dashboard, audit preparation tools, and direct DOL submission capabilities.

Wage Determination Tracking Procedures

Step 1: Obtaining Wage Determinations

Process: Access current wage determinations through SAM.gov or the DOL website before bid submission. Verify the determination applies to your project type, location, and construction classification.

Wage Determination Tracking Form

Project Information Details
Project Name: ________________________________
Project Number: ________________________________
Wage Determination Number: ________________________________
Effective Date: ________________________________
Modification Number (if applicable): ________________________________
Construction Type: â–¡ Building â–¡ Heavy â–¡ Highway â–¡ Residential

Verification Checklist:

â–¡ Wage determination matches project location (county/city)
â–¡ Construction type correctly identified
â–¡ Most current modification obtained
â–¡ All applicable classifications identified
â–¡ Posted at job site in prominent location
â–¡ Copies provided to all subcontractors

Step 2: Monitoring Updates and Modifications

Systematic Monitoring: Check for wage determination modifications weekly. Set up automated alerts through Alliance platform for immediate notification of changes affecting active projects.

Modification Tracking Log

Date Checked Modification Found Effective Date Action Taken Initials
_________ â–¡ Yes â–¡ No _________ ________________ ____
_________ â–¡ Yes â–¡ No _________ ________________ ____
_________ â–¡ Yes â–¡ No _________ ________________ ____

Certified Payroll Reporting

Weekly Submission Requirements

Submit Form WH-347 (or equivalent) weekly for all workers, regardless of hours worked. Submissions must be received within seven days of the payroll week ending.

Certified Payroll Form WH-347 Compliance Checklist

Before Submission - Verify Each Item:

â–¡ All employee information complete (name, address, SSN last 4 digits)
â–¡ Work classifications match wage determination
â–¡ Hours worked accurately recorded (regular vs. overtime)
â–¡ Wage rates meet or exceed prevailing wage requirements
â–¡ Fringe benefits properly calculated and documented
â–¡ Deductions clearly itemized and justified
â–¡ Net pay calculations verified
â–¡ Statement of compliance signed and dated
â–¡ Payroll period clearly identified
â–¡ Project information complete

Certification Statement

"I certify that the above is true and complete to the best of my knowledge and belief, and that the wage rates paid are not less than those required by the Davis-Bacon Act and that the classifications set forth for each laborer or mechanic conform with the work performed."

Signature: Date: ___________

Name/Title:

Documentation Requirements

Supporting Documentation: Maintain time records, pay stubs, fringe benefit records, and apprenticeship documentation for each certified payroll submission.

Payroll Supporting Documentation Checklist

Document Type Required Location/File Verified
Daily time records ✓ _________________ □
Payroll register ✓ _________________ □
Fringe benefit records ✓ _________________ □
Apprenticeship papers If applicable _________________ â–¡
Deduction authorizations If applicable _________________ â–¡

🔧 Alliance Integration: Automated Payroll System

Eliminate manual payroll preparation with our integrated system that automatically applies current wage determinations, calculates prevailing wages and fringe benefits, generates WH-347 forms, and submits certified payrolls directly to contracting agencies.

Time Savings: Reduce payroll preparation time by 75% while ensuring 100% accuracy and compliance.

Employee Interview Process

When Interviews Are Required

Employee interviews may be conducted by Department of Labor investigators, contracting agency representatives, or as part of routine compliance verification. Proper preparation and documentation are essential.

Employee Interview Preparation Checklist

Pre-Interview Preparation:

â–¡ Notify employees of interview process and their rights
â–¡ Gather employee records and supporting documentation
â–¡ Review project wage determinations and classifications
â–¡ Prepare workspace for private interviews
â–¡ Designate company representative to be present
â–¡ Ensure all records are organized and accessible

Employee Rights Notice

Employee Rights: Workers have the right to be interviewed privately, to have a representative present, to review their payroll records, and to file complaints without retaliation. Ensure all employees understand these protections.

Interview Documentation Form

Employee Name: _________________________________
Classification: _________________________________
Interview Date: _________________________________
Interviewer: _________________________________
Company Representative: _________________________________

Key Topics Covered:

â–¡ Work classification and duties performed
â–¡ Hours worked and overtime
â–¡ Wage rates received
â–¡ Fringe benefits provided
â–¡ Deductions from pay
â–¡ Any concerns or discrepancies

Interview Summary:

_________________________________________________
_________________________________________________
_________________________________________________

Follow-up Actions Required:

_________________________________________________
_________________________________________________

Documentation completed by: Date: _______

Compliance Verification System

Daily Compliance Verification

Systematic Approach: Implement daily verification procedures to catch and correct issues before they become violations. Prevention is always more cost-effective than correction.

Daily Compliance Checklist

Job Site Verification (Daily):

â–¡ Wage determination properly posted and current
â–¡ Employee classifications match work being performed
â–¡ Time records being accurately maintained
â–¡ New employees properly classified and documented
â–¡ Subcontractor compliance verified
â–¡ Apprentices properly registered and supervised

Verified by: _________________ Date: _________ Time: _______

Weekly Compliance Audit

Weekly Compliance Audit Form

Compliance Area Status Issues Found Corrective Action
Wage Determinations Current â–¡ Pass â–¡ Fail _______________ _______________
Certified Payrolls Submitted â–¡ Pass â–¡ Fail _______________ _______________
Employee Classifications Correct â–¡ Pass â–¡ Fail _______________ _______________
Wage Rates Compliant â–¡ Pass â–¡ Fail _______________ _______________
Fringe Benefits Proper â–¡ Pass â–¡ Fail _______________ _______________
Record Keeping Current â–¡ Pass â–¡ Fail _______________ _______________
Subcontractor Compliance â–¡ Pass â–¡ Fail _______________ _______________

Overall Compliance Status: â–¡ Compliant â–¡ Issues Identified â–¡ Critical Violations

Audit completed by: Date: ___________

Record Keeping Requirements

Mandatory Record Retention

Maintain all Davis-Bacon related records for three years after project completion. Organize records systematically for easy retrieval during audits or investigations.

Record Keeping Master Checklist

Payroll Records (3 Years):

â–¡ Certified payroll forms (WH-347 or equivalent)
â–¡ Daily time records and time sheets
â–¡ Payroll registers and pay stubs
â–¡ Fringe benefit payment records
â–¡ Deduction authorizations and records
â–¡ Overtime calculations and documentation

Employee Records (3 Years):

â–¡ Employee personal information and addresses
â–¡ Job classifications and rate determinations
â–¡ Apprenticeship agreements and progress records
â–¡ Training and safety documentation
â–¡ Employment verification (I-9 forms)
â–¡ Interview records and statements

Project Records (3 Years):

â–¡ Contract documents and specifications
â–¡ Wage determinations and modifications
â–¡ Subcontractor agreements and certifications
â–¡ Compliance correspondence
â–¡ Inspection and audit reports
â–¡ Violation notices and correction documentation

Digital Record Management

Best Practice: Implement digital document management with automated backup, version control, and secure access. Digital records must be easily searchable and printable for government review.

Digital File Organization Structure

Folder Structure Contents Retention Period
Project_Name/Payroll/Year Weekly certified payrolls 3 years
Project_Name/WageDeterminations Original and modifications 3 years
Project_Name/Employees Individual employee files 3 years
Project_Name/Subcontractors Subcontractor compliance files 3 years
Project_Name/Compliance Audits, inspections, correspondence 3 years

📊 Alliance Integration: Digital Record Management

Our cloud-based system automatically organizes, backs up, and maintains all Davis-Bacon records with advanced search capabilities, automatic retention scheduling, and instant audit report generation.

Features: Automated file organization, secure cloud storage, instant retrieval, compliance reporting, and audit trail documentation.

Violation Correction Processes

Immediate Response Protocol

Critical Timeline: Most violations must be corrected within 30 days of notification. Immediate action is essential to prevent escalation and additional penalties.

Violation Response Action Plan

Step 1: Immediate Assessment (Day 1)

â–¡ Review violation notice in detail
â–¡ Gather all relevant records and documentation
â–¡ Calculate scope and financial impact
â–¡ Notify legal counsel if required
â–¡ Prepare initial response timeline

Step 2: Investigation and Verification (Days 2-5)

â–¡ Verify accuracy of violation claims
â–¡ Interview affected employees
â–¡ Review payroll calculations
â–¡ Identify root cause of violation
â–¡ Document findings and evidence

Step 3: Correction Implementation (Days 6-20)

â–¡ Calculate back wages and fringe benefits owed
â–¡ Process supplemental payroll payments
â–¡ Update payroll systems and procedures
â–¡ Implement corrective measures
â–¡ Train staff on proper procedures

Step 4: Response and Documentation (Days 21-30)

â–¡ Prepare written response to violation notice
â–¡ Submit proof of back wage payments
â–¡ Document corrective measures implemented
â–¡ Provide compliance assurance letters
â–¡ Submit all required documentation

Back Wage Calculation

Back Wage Calculation Worksheet

Employee Name Hours Affected Wage Shortfall Back Wages Due Fringe Benefits Due Total Amount
___________ _______ $_______ $_______ $_______ $_______
___________ _______ $_______ $_______ $_______ $_______
Total Back Wages and Benefits: $_______

Payment Method: â–¡ Separate check â–¡ Next regular payroll â–¡ Cash

Payment Date: _______________

Documentation: â–¡ Payment receipts obtained â–¡ Payroll records updated

Subcontractor Management

Subcontractor Compliance Requirements

Prime contractors are responsible for ensuring subcontractor Davis-Bacon compliance. Implement systematic oversight and verification procedures.

Subcontractor Compliance Agreement

Subcontractor Information:

Company Name: _________________________________
Contact Person: _________________________________
License Number: _________________________________
Work Classification: _________________________________
Contract Value: _________________________________

Compliance Certification:

â–¡ Acknowledges Davis-Bacon Act requirements
â–¡ Agrees to pay prevailing wages and fringe benefits
â–¡ Will submit weekly certified payrolls
â–¡ Will maintain required records for three years
â–¡ Will post wage determinations at work areas
â–¡ Allows prime contractor compliance verification
â–¡ Agrees to correct violations promptly

Subcontractor Signature: Date: _______

Prime Contractor Signature: Date: _______

Subcontractor Monitoring

Weekly Subcontractor Compliance Review

Subcontractor Payroll Received Issues Identified Action Required Status
_____________ â–¡ Yes â–¡ No _____________ _____________ â–¡ OK â–¡ Follow-up
_____________ â–¡ Yes â–¡ No _____________ _____________ â–¡ OK â–¡ Follow-up
_____________ â–¡ Yes â–¡ No _____________ _____________ â–¡ OK â–¡ Follow-up

Review completed by: _________________ Date: _________

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Implementation Timeline

30-Day Compliance Implementation Plan

Week 1: Foundation Setup

â–¡ Set up digital record keeping system
â–¡ Create compliance forms and templates
â–¡ Train key personnel on procedures
â–¡ Review current project wage determinations
â–¡ Audit existing payroll processes

Week 2: System Integration

â–¡ Integrate payroll systems with compliance requirements
â–¡ Set up automated wage determination monitoring
â–¡ Create subcontractor compliance agreements
â–¡ Implement daily verification procedures
â–¡ Test certified payroll generation process

Week 3: Process Refinement

â–¡ Conduct trial runs of all procedures
â–¡ Refine forms and documentation processes
â–¡ Train field supervisors and project managers
â–¡ Create compliance dashboard and reporting
â–¡ Establish violation response protocols

Week 4: Full Implementation

â–¡ Deploy complete compliance system
â–¡ Conduct first full compliance audit
â–¡ Address any remaining gaps or issues
â–¡ Document lessons learned and improvements
â–¡ Schedule ongoing training and updates

🎯 Alliance Integration: Complete Solution

Skip the manual implementation process. Our turnkey platform provides immediate Davis-Bacon compliance with automated wage determinations, integrated payroll processing, compliance monitoring, and expert support.

Get compliant in 48 hours, not 30 days.

Emergency Contact Information

Davis-Bacon Compliance Emergency Contacts

Resource Contact Information Use Case
Department of Labor Wage & Hour Division 1-866-4-USWAGE Violation notices, investigations
Contracting Agency _________________________ Project-specific questions
Legal Counsel _________________________ Serious violations, disputes
Alliance for Contractors Support _________________________ System issues, compliance questions
Company Compliance Officer _________________________ Internal compliance issues

Don't Navigate Davis-Bacon Compliance Alone

Join thousands of contractors who have eliminated Davis-Bacon violations and won more federal contracts with Alliance for Contractors' proven compliance system.

Build Better. Build Smarter. Build Compliant.

This manual provides comprehensive guidance for Davis-Bacon Act compliance. For project-specific questions or complex situations, consult with qualified legal counsel or compliance specialists. Alliance for Contractors provides ongoing support and updates to ensure continued compliance with evolving regulations.

Document Version: 2024.1 | Last Updated: Current Date
Next Review: Quarterly | Owner: Alliance for Contractors Compliance Team