Payroll
Certified payroll reporting in California
Every public works contractor and subcontractor must register with the DIR and file its own weekly certified payroll.
Registration and the thresholds
California Labor Code §1771.1 · Department of Industrial Relations
Contractors and subcontractors must register with the DIR before bidding on or performing public works, and must submit certified payroll records through the DIR's eCPR system.
Registration thresholds: projects over $25,000 for construction and over $15,000 for maintenance.
Each contractor and each subcontractor files its own certified payroll records. A prime contractor cannot file on behalf of its subs, and a sub that assumes the prime is handling it is not compliant.
What a certified payroll record contains
Form A-1-131 is the state form; many awarding bodies accept the federal WH-347 equivalent.
- Every worker on the project, by name and identifier
- Work classification, which determines the applicable prevailing wage rate
- Hours worked each day, and total hours for the week
- The rate paid, and whether it meets the prevailing wage determination for that classification
- Overtime, computed to the prevailing wage rules rather than ordinary overtime rules
- Deductions, and fringe benefit contributions or payments in lieu
- A signed statement of compliance
- Filed weekly, for every week in which work was performed
Where contractors actually get caught
Misclassification of work. Paying a labourer's rate for work that falls under a higher-rated classification is the most frequent and most expensive finding.
Fringe benefit calculation. The prevailing wage is a total package. Contributions to bona fide benefit plans can offset it, but the arithmetic has to be right and documented.
Apprentice ratios. Public works projects carry apprenticeship requirements, and apprentice rates only apply to properly registered apprentices in an approved programme.
Penalties accrue per worker per day, so a classification error that runs for a month across a crew becomes a large number quickly.