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Certified Payroll Mistakes to Avoid

The errors that come up most on Davis-Bacon jobs, most of them from the report being right on paper but checked against the wrong thing.

1. Checking against a superseded wage determination

Wage determinations get modified over time, and only one modification is active at any given moment. A rate check against last month's printout, or against a version you saved to a spreadsheet a year ago, isn't a real check even if the numbers used to be correct.

Before relying on a rate, confirm on sam.gov or our own free lookup that you're looking at the currently active modification, not a superseded one. Or see it checked automatically in a no-signup demo.

2. Classifying by job title instead of actual work performed

A worker's certified payroll classification has to match what they did that week, not what your internal payroll system calls their role. Someone who spent two days on electrical work and three on general labor needs both classifications reflected, not whichever title is easiest to type.

3. Paying fringe short because the base rate looks generous

Base rate and fringe are two separate requirements that both have to be met. A base rate well above the minimum doesn't make up for a fringe shortfall, the two don't offset each other in the contractor's favor, only the worker's.

4. Forgetting the Statement of Compliance signature

Page two of the WH-347 needs an original signature from the owner, a corporate officer, or an authorized designee, every single week, not just on the first submission for a project.

5. Not tracking split classifications within one week

A worker doing two different types of work in the same week needs both classifications and rates tracked separately for the hours actually worked in each, not averaged into one blended rate.

6. Filing the wrong form for the funding source

Federal money means the WH-347 against SAM.gov rates. Some states (California among them) require their own separate certified payroll format for state-funded work, with their own rates and portal. A dual-funded job needs both, filed correctly for each.

7. Not keeping records long enough

Davis-Bacon contractors are required to keep certified payroll records for three years after project completion. Losing them earlier, even by accident, is itself a compliance problem if a record request ever comes in.

Frequently asked

What's the single most common mistake?+

Checking rates against an outdated wage determination modification. It's an easy mistake because the form still looks complete and correct, the number underneath it is just wrong.

Who has to sign the Statement of Compliance?+

The owner, a corporate officer, or someone they've specifically authorized as a designee. It needs to happen every week, not once per project.

How long do I actually have to keep these records?+

Three years after the project is completed, per Davis-Bacon recordkeeping requirements.

Not sure what a term above means? Check the certified payroll glossary, or start filling a real WH-347 with the rates checked for you.

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