Things subcontractors get wrong about certified payroll
Quick list, because this trips people up constantly:
"The GC handles certified payroll, not me" — nope. If you're a subcontractor on a Davis-Bacon-covered project, the reporting obligation is yours. It reaches you through the subcontract's flow-down clause, and it applies even if that clause got left out of the contract by mistake.
"I can submit whenever, it's not that strict" — it's weekly. Every week the project is active. A late report can hold up that week's payment because contracting officers have to confirm certified payroll is current before approving an invoice.
"One small error isn't a big deal" — one transposed wage rate or mislabeled trade classification is enough to trigger a deficiency notice, and fixing it usually means digging back through several weeks of records to find where it went wrong.
"This is only a federal thing" — most states run their own prevailing wage laws too, sometimes called "little Davis-Bacon" laws, with their own rates and reporting formats. Multi-state work multiplies the compliance load fast.
"A pattern of missed reports is just annoying, not risky" — it can lead to back wage assessments, fines and debarment from future public work. Debarment can follow a company for years.
The actual fix is boring, but it works: pay the prevailing wage, file Form WH-347 (or your state's version) accurately, submit it on time, every time.
Payroll4Construction's own Alex Gray gets into this too, in a quick Q&A on LinkedIn.