Can Gusto Do Certified Payroll? (w/Examples) + FAQs

No. Gusto does not natively support certified payroll reporting. The platform lacks the specialized features required to generate Form WH-347, track prevailing wages, or automate Davis-Bacon Act compliance.

The Davis-Bacon Act of 1931 creates this problem. This federal law requires contractors and subcontractors working on government-funded construction projects exceeding $2,000 to submit weekly certified payroll reports that prove workers receive locally prevailing wages and fringe benefits. The consequence is severe: contractors using standard payroll software like Gusto cannot automatically generate the mandatory Form WH-347, leading to manual data entry, compliance errors, delayed payments, and potential debarment from future federal contracts.

According to the U.S. Department of Labor, certified payroll violations resulted in over $1.2 billion in back wages collected between 2009 and 2016. In 2024, a Florida contractor paid $124,000 in back wages and penalties for prevailing wage violations.

What You’ll Learn

🔍 The exact certified payroll features Gusto lacks – and why standard payroll platforms cannot handle Davis-Bacon compliance

⚖️ What makes certified payroll legally different from regular payroll – including weekly reporting, prevailing wage calculations, and Form WH-347 requirements

💡 Three practical workarounds if you currently use Gusto – from manual form completion to third-party integrations with LCPtracker

⚠️ The 5 most expensive mistakes contractors make – worker misclassification, incorrect wage rates, and missing reports that trigger audits

🏗️ Real-world examples with actual numbers – how to calculate fringe benefits, complete WH-347 forms, and handle multi-state projects

Understanding Certified Payroll: What Gusto Cannot Do

Certified payroll represents a specialized compliance requirement that differs fundamentally from the standard payroll processing Gusto provides. The distinction matters because government-funded construction projects operate under strict federal and state labor laws that impose obligations far beyond typical wage reporting.

The Core Components of Certified Payroll

Certified payroll consists of three mandatory elements that work together to enforce prevailing wage compliance.

First, contractors must complete Form WH-347 or an equivalent document that captures specific worker information. This form requires employee names (with identifying numbers, not full Social Security numbers), precise job classifications matching the applicable wage determination, daily and weekly hours worked separated by regular and overtime, base hourly rates, fringe benefit amounts, gross wages, itemized deductions, and net wages paid.

Second, the Statement of Compliance must accompany each weekly report. The contractor or authorized company representative signs this document under penalty of perjury, certifying that all information is accurate, workers received at least the required prevailing wage, fringe benefits were handled properly, and payroll records are complete and available for inspection. This signature carries legal weight. The Department of Labor warns that falsification can lead to criminal prosecution, including fines and imprisonment up to five years.

Third, contractors must maintain detailed records for three years after project completion. These records include not just the certified payroll forms but also employee time cards, wage determinations, proof of fringe benefit contributions, apprenticeship registration documents, and all correspondence with contracting agencies.

How Prevailing Wage Differs From Standard Pay Rates

Prevailing wage creates a two-part compensation structure that Gusto’s standard payroll system cannot automatically calculate or track.

The base wage represents the hourly rate workers must receive for their specific job classification in the project’s geographic area. The U.S. Department of Labor determines these rates through surveys and publishes them as wage determinations that vary by county, occupation, and project type. A carpenter in New York City receives a different prevailing wage than a carpenter in rural Montana, even though both perform identical work.

Fringe benefits add a second layer of required compensation. The wage determination specifies an hourly fringe rate that contractors must provide through qualified benefits or cash payments. If the prevailing wage lists $32.50 as the base wage and $8.25 as the fringe rate, the total prevailing wage obligation equals $40.75 per hour. Contractors can meet this obligation by paying $40.75 entirely in cash, providing $8.25 per hour in qualified benefits (health insurance, retirement contributions, paid time off), or combining both approaches.

The complexity increases when contractors provide benefits worth less than the required fringe rate. Consider an employer who pays $412.50 per month for an employee’s health insurance. If that employee works 160 hours per month, the hourly fringe value equals $2.58 ($412.50 ÷ 160). If the required fringe rate is $8.25, the contractor must pay the remaining $2.67 per hour as taxable wages labeled “cash in lieu of fringe benefits”.

Why Standard Payroll Software Cannot Handle Certified Payroll

Gusto’s architecture optimizes for efficiency in standard payroll scenarios where employees work consistent hours at fixed rates with uniform benefit packages. Certified payroll breaks this model in five critical ways.

Dynamic wage rate application by project and location. Construction workers often move between multiple job sites daily, each potentially governed by different wage determinations. A worker might spend four hours on a federal highway project requiring one prevailing wage, then move to a state-funded building project requiring a different rate, and finish the day on private commercial work at the company’s standard pay rate. Gusto lacks the job costing and rate-switching functionality to track and apply multiple wage rates within a single payroll period.

Job classification precision tied to actual work performed. The Davis-Bacon Act requires classification based on the work the employee performs, not the job title on their W-2. An employee classified as a general laborer who operates heavy equipment on a particular day must be paid the equipment operator’s prevailing wage for those hours. Gusto does not track work performed at this granular level or automatically adjust wages based on changing classifications throughout the day.

Fringe benefit annualization and hourly equivalency calculations. Certified payroll requires converting all benefit costs into hourly rates that contractors report weekly. This calculation changes when employees work different hours or receive benefits that fluctuate in value. An employee working 40 hours one week and 50 hours the next receives different per-hour fringe credits even if the monthly benefit cost remains constant. Gusto’s benefits administration tracks enrollment and deductions but does not perform the annualized-to-hourly conversions certified payroll demands.

Weekly submission deadlines that do not align with typical pay periods. The Davis-Bacon Act mandates weekly reporting even when contractors pay employees bi-weekly or semi-monthly. Gusto processes payroll according to the employer’s chosen schedule (weekly, bi-weekly, semi-monthly, monthly), but certified payroll reports must be submitted within seven days of the week ending regardless of when employees receive their paychecks. This disconnect forces contractors to manually manipulate data to meet reporting timelines.

Form WH-347 generation with required certifications. The Form WH-347 contains specific fields, layouts, and certification language that government agencies expect. While Gusto generates detailed payroll reports for accounting and tax purposes, it does not produce the WH-347 format or populate the Statement of Compliance that makes the payroll “certified”. Contractors must either manually transfer data from Gusto’s reports to WH-347 forms or export raw payroll data and manipulate it in spreadsheets before submission.

Federal Requirements: The Davis-Bacon Act Framework

The Davis-Bacon and Related Acts (DBRA) establish the legal foundation for certified payroll requirements, creating obligations that extend far beyond what Gusto’s platform addresses.

When Certified Payroll Becomes Mandatory

Federal law triggers certified payroll requirements when three conditions exist simultaneously.

The project must receive federal funding or assistance. This includes direct federal contracts, grants, loans, loan guarantees, insurance, or any other federal financial support. The funding source determines whether the Davis-Bacon Act applies. A construction project financed entirely with private money faces no federal prevailing wage obligations, while an identical project receiving even partial federal assistance must comply fully.

The contract value must exceed $2,000. This threshold applies to the total contract amount, not individual payments or project phases. Contractors cannot avoid compliance by structuring work into smaller contracts that individually fall below $2,000 if the total project value exceeds this amount.

The work must involve construction, alteration, or repair of public buildings or public works. This category encompasses roads, bridges, buildings, water systems, electrical infrastructure, and similar projects. The law excludes certain activities like transportation of materials to the job site, manufacturing of materials off-site, and landscaping or maintenance work unless performed as part of a construction project.

Who Must Submit Certified Payroll Reports

The Davis-Bacon Act creates compliance obligations for every contractor and subcontractor performing covered work, regardless of their position in the contracting chain.

Prime contractors bear direct responsibility for submitting their own certified payroll reports and ensuring all subcontractors submit compliant reports. This responsibility continues down through all tiers of subcontractors. A prime contractor remains accountable even when a fourth-tier subcontractor three levels removed fails to submit proper certified payroll.

The law makes no exceptions based on company size, contract amount, or percentage of work performed. A subcontractor performing $5,000 worth of electrical work on a $10 million federal project must submit the same certified payroll reports as the prime contractor managing the entire job.

Prevailing Wage Determinations: Where the Rates Come From

The U.S. Department of Labor publishes prevailing wage determinations that establish the minimum compensation contractors must pay for each job classification in each geographic area.

These determinations result from surveys that capture actual wages paid to workers in specific occupations within defined localities. The Department of Labor collects data from contractors, labor organizations, and other sources, then applies a three-step methodology to establish the prevailing wage. If more than 50 percent of workers in a classification receive the same rate, that rate becomes the prevailing wage. If no majority exists but at least 30 percent earn a specific rate, that rate becomes prevailing. Otherwise, a weighted average applies.

Wage determinations specify separate rates for dozens of job classifications. A single determination might list different prevailing wages for carpenters, electricians, cement masons, equipment operators (by equipment type), laborers (by work type), painters, plumbers, roofers, sheet metal workers, and many other trades. Each classification receives both a base hourly wage and a fringe benefit rate that together constitute the total prevailing wage obligation.

The determinations update periodically, and contractors must use the wage determination in effect when the contract is awarded or when work begins, depending on the specific project requirements. Using outdated wage determinations—even by mistake—constitutes a violation that requires back wages and penalties.

The Weekly Reporting Requirement and Its Implications

The Copeland Act requires contractors to furnish weekly statements on wages paid to each employee during the prior week. This weekly requirement creates several operational challenges that standard payroll systems like Gusto cannot address.

Contractors must submit certified payroll reports within seven days after the regular pay date for the pay period. If a contractor pays employees bi-weekly on Fridays, certified payroll for the first week of that pay period is due the Friday after payday, even though the contractor has not yet processed the full bi-weekly payroll in their system.

The weekly requirement applies even during weeks when no work occurs on the covered project. Contractors must submit “no work” reports documenting that zero hours were worked rather than simply skipping the submission. This creates an administrative burden when work stops temporarily due to weather, material delays, or scheduling issues.

Each report must include the specific week ending date, sequential payroll numbers that continue throughout the project duration, and detailed breakdowns of hours worked each day of that week. A project spanning six months might require 26 separate certified payroll submissions per contractor and subcontractor, each containing complete information for all workers who performed even one hour of labor that week.

State Prevailing Wage Laws: A Patchwork of Requirements

State prevailing wage laws create additional compliance layers that vary dramatically across jurisdictions, compounding the limitations of using Gusto for construction payroll.

States With Prevailing Wage Requirements

Thirty-two states maintain prevailing wage laws that apply to state-funded public works projects. These “Little Davis-Bacon Acts” operate independently from federal requirements, meaning contractors working on state projects must comply with state-specific rules even when no federal funding exists.

The states with prevailing wage requirements as of 2025 include: Alaska, California, Connecticut, Delaware, Hawaii, Illinois, Indiana, Kentucky, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, Ohio, Oregon, Pennsylvania, Rhode Island, Tennessee, Texas, Vermont, Washington, West Virginia, Wisconsin, and Wyoming.

Twenty-three states have eliminated prevailing wage requirements, including Alabama, Arizona, Arkansas, Colorado, Florida, Georgia, Idaho, Indiana (for certain projects), Iowa, Kansas, Louisiana, Mississippi, North Carolina, North Dakota, Oklahoma, South Carolina, South Dakota, Utah, and Virginia. Contractors working in these states face no state prevailing wage obligations, though federal Davis-Bacon requirements still apply to federally funded projects regardless of state location.

How State Thresholds Create Compliance Complexity

State contract thresholds range from zero dollars to over $1 million, creating vastly different compliance landscapes.

New York requires prevailing wages on all public works projects with no minimum contract threshold. A contractor performing $500 of repair work on a state building must submit certified payroll just as a contractor building a $50 million bridge must.

Connecticut sets its threshold at $1 million for new construction and $100,000 for renovation work. Maryland requires prevailing wages on projects valued at $250,000 or more. Missouri applies requirements to projects over $75,000. California sets one of the lowest thresholds at $1,000.

These threshold differences create planning challenges for contractors working across multiple states. A regional contractor bidding on three projects—a $500,000 job in Connecticut, a $300,000 job in Maryland, and a $100,000 job in California—must comply with certified payroll in California and Maryland but not Connecticut, even though Connecticut has stricter prevailing wage laws than either of the other states.

State-Specific Wage Determination Methods

States employ different methodologies for determining prevailing wage rates, resulting in significant rate variations for identical work.

California typically bases prevailing wages on collective bargaining agreements, meaning union contract rates become the prevailing wage even if non-union contractors employ the majority of workers in an area. This approach generally produces higher prevailing wages than survey-based methods.

Washington uses collective bargaining agreements when available, resorting to wage surveys only when union contracts do not exist for a particular classification. Texas takes a flexible approach, determining prevailing wages through locality surveys or by adopting the corresponding federal Davis-Bacon rates.

New York mandates that prevailing wage rates never fall below the statutory minimum wage but otherwise uses survey data to establish rates. The state requires detailed certified payroll reports documenting hours worked, trade classifications, and wages for each covered employee.

Multi-State Operations: Why One-Size-Fits-All Software Fails

Contractors operating in multiple states face simultaneous compliance with different wage rates, reporting formats, submission portals, and administrative requirements.

Consider a construction company with projects in three states. In New York, a boilermaker receives a base wage plus benefits totaling $26.85 plus 33.5 percent of the hourly wage. In Michigan, a laborer receives $12.67 per hour in benefits. In Connecticut, the project might not trigger prevailing wage requirements at all if the contract value falls below $1 million.

Some states require electronic submission through specific portals, while others accept paper or PDF forms. California, Washington, and other states maintain their own prevailing wage software systems with unique data formatting requirements. Contractors must adapt their payroll processes to accommodate these different systems rather than relying on a single unified platform.

Washington updates prevailing wage rates twice yearly, with changes taking effect 30 days after publication. Other states update rates annually or irregularly. Contractors must monitor multiple state agencies for rate changes and implement updates across their payroll systems to avoid using outdated determinations.

Three Real-World Scenarios: Where Gusto Falls Short

Examining specific construction scenarios reveals exactly how Gusto’s limitations create compliance risks and operational inefficiencies.

Scenario 1: Federal Highway Project With Multiple Trades

A general contractor wins a $5 million federal highway construction project in Ohio. The crew includes carpenters, cement finishers, equipment operators, laborers, and truck drivers, each governed by different prevailing wage rates from the applicable Davis-Bacon wage determination.

A laborer earning the company’s standard rate of $22 per hour works 30 hours on the federal highway project where the prevailing wage is $28 base plus $8 fringe, then spends 10 hours that week on a private commercial job at the standard rate. Gusto cannot automatically split this payroll: 30 hours at $36 total prevailing wage ($28 + $8 fringe paid as cash) and 10 hours at $22 standard rate. The contractor must manually calculate the difference, create supplemental payments, and track the split for certified payroll reporting.

The same laborer spends four hours operating a backhoe on Tuesday. The equipment operator prevailing wage is $35 base plus $10 fringe. Gusto has no mechanism to recognize this classification change or automatically apply the higher rate for those specific hours. The contractor faces three options: manually adjust the timesheet and create a separate pay entry, risk paying the lower rate and violating prevailing wage requirements, or abandon Gusto entirely for a construction-specific payroll system.

Scenario 2: State-Funded School Construction With Subcontractor Oversight

A prime contractor manages a $3 million state-funded school renovation in New York. The project involves six subcontractors: electrical, plumbing, HVAC, drywall, painting, and flooring specialists. New York requires certified payroll on all public works regardless of contract value.

The prime contractor uses Gusto for its own employees but receives certified payroll from subcontractors using LCPtracker, eBacon, and manual Excel spreadsheets. Consolidating these different formats into a unified submission package requires manual effort. One subcontractor submits a report listing workers as “laborers” when they performed carpentry work, violating classification requirements. Gusto provides no tools to detect this error before the prime contractor forwards the report to the state agency.

The electrical subcontractor works on the school project for three weeks, then moves to a private commercial project. The subcontractor continues using the same employee pay rates in Gusto, failing to recognize that the private project does not require prevailing wages. This error overpays workers on the private job (reducing profit margins) or underpays workers if the subcontractor drops rates inappropriately.

Scenario 3: Multi-State Contractor With Concurrent Projects

A regional contractor operates simultaneously in Pennsylvania, Maryland, and West Virginia. The company has 45 employees working across five projects: two federal Davis-Bacon projects in Pennsylvania, one state prevailing wage project in Maryland, one state project in West Virginia (which eliminated prevailing wage laws), and one private commercial project in Pennsylvania.

A foreman based in Pennsylvania works 20 hours on the federal project in PA (requiring $42/hour total prevailing wage), 10 hours on the Maryland state project (requiring $38/hour), and 10 hours on the West Virginia project (standard company rate of $35/hour). Gusto processes one rate for the foreman’s entire 40-hour week. The contractor must either:

1. Pay the highest rate ($42) for all hours, losing money on the non-federal work
2. Pay blended rates that violate prevailing wage law on the federal and state projects
3. Create three separate “pseudo-employees” in Gusto to track the different rates, complicating tax reporting and year-end W-2 generation
4. Manually calculate the wage differences and issue supplemental payments outside Gusto, creating reconciliation challenges

The company’s accountant spends 12 hours per week manually exporting Gusto payroll data, rebuilding it in Excel spreadsheets organized by project, calculating fringe benefit equivalencies, completing WH-347 forms for each project, and tracking submission deadlines. This administrative burden costs approximately $600 per week ($31,200 annually) in accounting time that construction-specific payroll software would eliminate.

Certified Payroll Software: What You Actually Need

Understanding the specific features that certified payroll requires reveals why contractors eventually abandon general payroll platforms like Gusto in favor of specialized construction payroll systems.

Essential Features Missing From Gusto

Prevailing wage rate database integration. Certified payroll software maintains continuously updated databases of federal Davis-Bacon and state prevailing wage determinations. These systems pull current wage rates automatically when contractors specify the project location, funding source, and contract award date. When the Department of Labor updates wage determinations, the software flags affected projects and adjusts future payroll calculations without manual intervention.

Gusto requires contractors to manually enter and maintain wage rates as custom pay types or compensation adjustments. No database integration exists. No automatic updates occur. Contractors bear full responsibility for monitoring DOL websites, identifying applicable wage determinations, extracting rate information, and manually inputting it into Gusto’s system—a process prone to errors and omissions.

Job costing with automatic wage rate application. Construction payroll systems assign employees to specific jobs or cost codes, then automatically apply the correct prevailing wage rate based on that job’s requirements. A worker clocking in to Job 2024-Federal-Highway automatically receives the Davis-Bacon rate associated with that project. The same worker clocking in to Job 2024-Private-Commercial automatically receives the standard company rate.

This automation extends to mid-shift job changes. Advanced systems track when a worker moves from one job to another during a single day and prorate wages accordingly. An employee working four hours on a prevailing wage job and four hours on a private job receives accurate split-wage calculations without manual intervention.

Gusto offers basic job costing for categorizing payroll expenses but does not link jobs to wage rates. Contractors must manually adjust each employee’s pay rate when they move between projects or rely on flat rates that either overpay on some jobs or underpay (violating prevailing wage law) on others.

Automated fringe benefit equivalency calculations. Certified payroll software calculates the hourly value of benefit contributions, compares them to required fringe rates, and automatically generates cash-in-lieu payments when benefits fall short. The system converts annual health insurance costs, monthly retirement contributions, quarterly bonuses, and paid time off accruals into hourly equivalents that appear correctly on certified payroll reports.

When benefit costs change—an insurance premium increase, a retirement plan amendment, a PTO policy adjustment—the software recalculates hourly fringe equivalents and adjusts future certified payroll submissions automatically. This dynamic calculation ensures continuous compliance even as benefit structures evolve throughout the year.

Gusto tracks benefit enrollment and processes payroll deductions but does not perform fringe equivalency calculations. The platform cannot compare benefit costs to prevailing wage fringe requirements or identify when cash-in-lieu payments are necessary. Contractors must perform these calculations manually using spreadsheets, a time-consuming process that introduces calculation errors.

Form WH-347 generation with embedded compliance checks. Dedicated certified payroll systems generate Form WH-347 automatically from processed payroll data. The software populates all required fields, formats data according to Department of Labor specifications, and produces the Statement of Compliance with proper certification language. Built-in validation checks verify that worker classifications match the wage determination, wage rates meet or exceed prevailing wage requirements, fringe benefits are calculated correctly, overtime calculations follow proper formulas, and all required fields contain valid data.

Reports that fail validation checks are flagged before submission, allowing contractors to correct errors while payroll data remains current. This real-time error detection prevents the submission of non-compliant reports that trigger investigations and back wage assessments.

Gusto generates detailed payroll reports for accounting and tax purposes but produces no certified payroll forms. Contractors must export raw payroll data, manipulate it in spreadsheets, manually populate WH-347 forms, perform their own compliance checks, and generate Statements of Compliance without software assistance. This manual process creates the conditions for the errors that result in DOL penalties.

Leading Certified Payroll Software Platforms

LCPtracker. LCPtracker operates as a cloud-based compliance management solution designed specifically for prevailing wage projects. The platform interfaces with leading payroll systems (including the ability to accept data exports from systems like Gusto) to streamline data entry. Contractors upload payroll data from their existing payroll provider, and LCPtracker automatically checks the data for accuracy and completeness against wage determination requirements.

The system supports both prime contractors managing subcontractor compliance and self-performing contractors submitting their own certified payroll. LCPtracker generates WH-347 forms, performs automated compliance validation, and supports electronic submission to various agencies. Pricing typically ranges from $10 to $12 per report, though exact costs vary based on project volume and feature requirements.

eBacon. eBacon provides web-based certified payroll software with comprehensive Davis-Bacon compliance features. The platform includes automated wage calculations that flag classification errors, generates compliant reports for federal, state, and local agencies, and maintains an integrated wage determination database that updates automatically. The system performs compliance checks that can be completed in seconds and offers DOL-approved reporting formats.

eBacon claims users can reduce time managing weekly payroll by 80 percent compared to manual processes. The software operates on a subscription basis with pricing per job rather than per user, making it cost-effective for contractors with varying project volumes.

FOUNDATION Software. FOUNDATION offers a complete construction accounting and payroll platform that includes a specialized certified payroll module. The system handles prevailing wage, Davis-Bacon, and union payrolls with automatic calculations and minimal data entry. Contractors can set as many rate tables as needed and let the software handle fringe reductions based on hourly or per-pay fringe costs.

FOUNDATION instantly creates print or electronic certified payroll reports for federal, state, and local agencies in their required formats. The platform integrates certified payroll with job costing, allowing contractors to track labor costs by project while maintaining compliance. As an enterprise construction management system, FOUNDATION requires significant implementation time and investment suitable for mid-size to large contractors.

Payroll4Construction. Payroll4Construction specializes exclusively in construction payroll, with certified payroll as a core feature rather than an add-on. The service handles complex prevailing wage, union fringe, and multi-jurisdiction scenarios automatically. The platform generates over 40 construction-specific reports including certified payroll, EEO reporting, new hire reporting, and union reports.

Payroll4Construction operates as a full-service payroll provider, processing payroll on behalf of contractors rather than as self-service software. This approach appeals to contractors who want to outsource the entire certified payroll function to specialists. The service provides unlimited support from construction payroll experts who understand industry-specific challenges.

ADP Through Marketplace Partners. ADP offers certified payroll capabilities through its Marketplace ecosystem rather than as a native platform feature. Through partners, ADP provides dynamic wage rate adjustments as employees switch between different projects or classifications, automated prevailing wage calculations, and certified payroll report generation.

ADP’s Construction Center of Excellence provides dedicated support for construction-specific payroll needs, including prevailing wages, unions, job costing, and certified payroll reporting. This service operates as an enhanced tier of ADP’s core payroll offering, suitable for larger construction firms that need enterprise-grade payroll with construction capabilities.

Three Practical Workarounds for Current Gusto Users

Contractors currently using Gusto who occasionally encounter certified payroll requirements have several options short of completely replacing their payroll system.

Option 1: Manual WH-347 Completion Using Gusto Data

Contractors with infrequent certified payroll needs—perhaps one or two projects per year—can manually complete Form WH-347 using data exported from Gusto.

Step 1: Export detailed payroll reports from Gusto. Run Gusto’s payroll register report for the specific week requiring certified payroll. Export the report to Excel or CSV format. The export should include employee names, identification numbers, hours worked, pay rates, gross wages, deductions, and net pay for all employees who worked on the covered project that week.

Step 2: Obtain the applicable wage determination. Visit the Department of Labor’s website or SAM.gov to retrieve the wage determination for your project. Download the complete determination showing all job classifications and their associated base wage and fringe benefit rates. Verify you have the wage determination that was current when the contract was awarded (or when work began, depending on the contract terms).

Step 3: Map employee classifications to wage determination classifications. Review the actual work each employee performed during the week. Match that work to the closest classification in the wage determination. Common mistakes occur when contractors use job titles from their payroll system rather than the specific classifications listed in the wage determination.

For example, a worker listed in Gusto as “General Laborer” might have performed cement finishing work. The wage determination lists “Cement Mason/Concrete Finisher” as a separate classification with a higher wage rate. The WH-347 must show the cement mason classification and confirm the worker received that higher rate.

Step 4: Calculate required prevailing wages and compare to actual wages paid. For each employee, multiply their hours worked by the applicable prevailing wage (base rate plus fringe rate). Compare this to what Gusto actually paid them. If Gusto paid less than the prevailing wage requirement, calculate the shortfall. You must issue a supplemental payment for any shortfall and document it on the certified payroll report.

Step 5: Calculate fringe benefit equivalents or cash in lieu. Determine the hourly value of fringe benefits you actually provided. If you contributed $412.50 per month to health insurance for an employee who worked 160 hours, the hourly fringe equivalent is $2.58. Compare this to the required fringe rate from the wage determination. Any shortfall must be paid as “cash in lieu of fringe benefits” and reported separately on the WH-347.

Step 6: Complete Form WH-347 manually. Download the form from the Department of Labor website. Manually enter all required information: contractor details, project information, week ending date, employee names and identification numbers, classifications, daily hours worked, wage rates, gross pay, deductions, and net pay. Complete the Statement of Compliance on page 2, certifying the accuracy of the information.

Step 7: Sign and submit the certified payroll. An authorized company representative must sign the Statement of Compliance. Submit the completed form to the appropriate agency (the federal contracting agency, state labor department, or prime contractor, depending on your contract requirements). Retain copies of all submitted certified payroll forms and supporting documentation for three years.

This manual process works for contractors with occasional certified payroll needs but becomes unsustainable when multiple projects require weekly submissions. The time investment—typically 2-4 hours per week per project—quickly exceeds the cost of dedicated certified payroll software.

Option 2: LCPtracker Integration for Report Generation

LCPtracker offers a middle-ground solution: continue using Gusto for payroll processing but leverage LCPtracker to generate certified payroll reports.

How the integration works. Contractors process payroll normally through Gusto, then export payroll data in CSV or Excel format. LCPtracker accepts this exported data through its import function. The contractor maps Gusto’s data fields to LCPtracker’s required fields (a one-time setup process), and LCPtracker automatically populates certified payroll forms.

LCPtracker performs automated compliance checks, verifying that classifications match the wage determination, wage rates meet prevailing wage requirements, and fringe benefit calculations are accurate. If the system detects discrepancies—a worker paid less than the required prevailing wage, incorrect fringe calculations, missing classification information—it flags those issues before report generation.

Once validated, LCPtracker generates Form WH-347 or other required formats in minutes. The system produces the complete certified payroll package including the Statement of Compliance ready for authorized signature. Contractors can submit reports electronically through LCPtracker to agencies that accept electronic submissions or print PDF copies for manual filing.

Cost and implementation considerations. LCPtracker typically charges $10-$12 per report, though pricing varies based on subscription level and project volume. For a contractor submitting one certified payroll report per week, annual costs approximate $520-$624. This cost must be weighed against the 2-4 hours of manual work eliminated each week—typically $1,040 to $2,080 in saved labor at typical accounting staff rates.

Implementation requires initial setup: creating a LCPtracker account, uploading wage determinations for active projects, configuring the data import mapping between Gusto’s export format and LCPtracker’s required fields, and training staff on the export-import-validate-submit workflow. Most contractors complete setup within a few hours.

Limitations of this approach. LCPtracker generates reports but does not fix the underlying problem: Gusto still cannot automatically apply correct prevailing wage rates during payroll processing. Contractors must manually adjust wages in Gusto if employees did not receive sufficient pay during the regular payroll run, then issue supplemental payments outside the system.

The integration also introduces data transfer friction. Each week requires exporting from Gusto, importing to LCPtracker, validating the data, correcting errors, regenerating reports, and submitting. While faster than fully manual WH-347 completion, this process still consumes administrative time that fully integrated construction payroll software eliminates.

Option 3: Hybrid Approach—Gusto for Core Employees, Specialized Software for Prevailing Wage Projects

Some contractors maintain Gusto for their administrative staff, project managers, and employees who never work on prevailing wage projects, while using dedicated construction payroll software for field employees who frequently encounter certified payroll requirements.

Separating employee populations. This approach works best when employee roles clearly divide into “administrative” and “field” categories with minimal crossover. The company controller, safety director, and office staff remain in Gusto at their standard salaries. Field supervisors, foremen, and craft workers move to the construction payroll system where prevailing wage tracking, job costing, and certified payroll generation are necessary.

Managing dual payroll systems. Running two payroll systems introduces complexity. The company maintains two software subscriptions (Gusto plus a construction payroll platform), processes payroll through two different systems each pay period, manages two sets of tax filings and year-end forms, and consolidates financial data from both systems for accounting purposes.

Most construction accounting software includes general ledger integration that accepts payroll data from multiple sources. Contractors export payroll summary data from both Gusto and their construction payroll system, then import the combined data into their accounting platform for job costing and financial reporting.

Cost-benefit analysis. A contractor with 5 administrative employees and 20 field employees might pay approximately $250 per month for Gusto ($49 base + $36 per-employee for 6 employees) plus approximately $400-$600 per month for construction payroll software serving 20 field employees. Total payroll software costs approach $650-$850 per month.

Compare this to $189 per month for Gusto serving all 25 employees (if prevailing wage requirements were ignored) or approximately $800-$1,000 per month for construction payroll software serving all 25 employees. The hybrid approach saves little if any money while adding administrative complexity.

The primary advantage of the hybrid approach is maintaining familiarity with Gusto for administrative functions while gaining construction-specific capabilities where they matter most. However, most contractors who adopt this approach eventually consolidate to a single construction payroll system once they experience the efficiency gains and compliance confidence that specialized software provides.

Common Mistakes to Avoid (And Their Consequences)

Understanding the specific errors that trigger Department of Labor investigations helps contractors prioritize compliance efforts and recognize why Gusto’s limitations create real risks.

Mistake 1: Worker Misclassification

The error. Contractors assign workers to the wrong job classification on certified payroll reports, typically listing workers in lower-paid classifications than the work they actually performed.

A worker classified as a “laborer” (prevailing wage $25 per hour) who operates heavy equipment for part of the day should be classified and paid as an “equipment operator” (prevailing wage $35 per hour) for those hours. Listing all hours under the laborer classification underpays the worker by $10 per hour for the equipment operation time.

Common misclassification scenarios include calling skilled trade workers “laborers” to avoid higher prevailing wages, using job titles from the company’s payroll system rather than classifications from the wage determination, failing to recognize when workers perform multiple classifications during a single day, and improperly classifying supervisors who perform manual labor alongside their supervisory duties.

Why it matters. The Davis-Bacon Act requires payment based on the actual work performed, not the worker’s job title or the classification that would be most cost-effective for the contractor. Misclassification constitutes wage theft. Workers are owed the difference between what they received and what they should have received based on proper classification.

The consequences. When discovered, misclassification violations require back wage payments to affected workers plus liquidated damages (additional penalties equaling the underpayment). A contractor who underpaid 10 workers by an average of $100 per week for 20 weeks owes $20,000 in back wages plus $20,000 in liquidated damages.

The Department of Labor may debar violators from federal contracting for up to three years, effectively ending the contractor’s ability to bid on government projects. If the agency determines the misclassification was intentional rather than a mistake, criminal prosecution becomes possible, including fines and potential imprisonment.

Mistake 2: Using Incorrect or Outdated Prevailing Wage Rates

The error. Contractors use wage rates from the wrong wage determination or fail to update rates when new determinations are issued.

Wage determinations are specific to geographic areas (often county-level), project types (building, highway, heavy construction), and time periods. Using a wage determination for the wrong county, the wrong type of construction, or an expired date results in paying incorrect wages.

The Department of Labor updates wage determinations periodically. Contractors working on long-duration projects must monitor for updates and implement new rates as required by the contract. Some contracts incorporate rate updates automatically; others lock in the original wage determination. Contractors who fail to understand which approach applies to their contract either overpay (reducing profit) or underpay (violating prevailing wage law).

Why it matters. Wage determinations vary substantially by location and project type. The prevailing wage for a carpenter in New York City differs from the rate in rural New York by $15 or more per hour. A contractor using the wrong determination systematically underpays every worker on the project, creating large accumulated back wage obligations.

The consequences. Using incorrect wage rates creates the same liability as worker misclassification: back wages, liquidated damages, and potential debarment. The severity depends partly on whether the error appears to be a good-faith mistake or deliberate attempt to reduce labor costs.

A contractor who uses rates from an adjacent county with slightly lower wages raises suspicion about intent. A contractor who uses rates from the correct determination but fails to implement a mid-project update has a stronger case for claiming the error was unintentional. In either case, the financial liability remains: workers must be made whole.

Mistake 3: Submitting Late, Incomplete, or Missing Reports

The error. Contractors fail to submit certified payroll reports by the weekly deadline, submit reports with missing information, or skip reporting for weeks when work temporarily stopped.

The seven-day submission deadline runs from the end of the pay period. A report covering the week ending Saturday, March 15, is due seven days after the regular pay date for that period. If payday is March 22, the certified payroll is due March 29. Submitting on March 30 is late, even by one day.

Incomplete reports lack required information: missing employee identification numbers, incorrect or absent job classifications, missing daily hour breakdowns (only weekly totals provided), unsigned Statements of Compliance, or missing fringe benefit calculations. Each missing element renders the report non-compliant.

“No work” weeks create confusion. When bad weather, material delays, or scheduling issues halt work for a week, contractors must still submit a certified payroll report documenting zero hours worked. Simply skipping that week’s submission violates the reporting requirement.

Why it matters. Weekly certified payroll submissions serve as real-time compliance monitoring. Contracting agencies use these reports to identify potential violations while projects remain active rather than discovering problems months or years later during closeout audits. Late or missing reports prevent this monitoring function.

Contracts often include provisions allowing the contracting agency to withhold progress payments when certified payroll submissions are delinquent. A contractor waiting for a $250,000 progress payment may find those funds held pending submission of three missing weekly certified payroll reports.

The consequences. Beyond payment withholdings, habitually late or incomplete certified payroll reporting creates a paper trail suggesting the contractor is not taking compliance seriously. This pattern influences how agencies respond when violations are discovered. An agency might accept a good-faith explanation for a wage calculation error from a contractor with a perfect submission record but view the same error as deliberate wage theft from a contractor with a history of late and incomplete reports.

Persistent reporting failures can lead to contract termination for cause and debarment from future federal contracting. The contractor loses not just the current project but also the ability to bid on government work for up to three years.

Mistake 4: Incorrect Fringe Benefit Calculations and Reporting

The error. Contractors miscalculate the hourly value of fringe benefits, claim credit for benefits that do not qualify under Davis-Bacon requirements, or fail to pay cash in lieu when benefit values fall short of the required fringe rate.

Common fringe benefit errors include using incorrect denominators when annualizing benefits (dividing by 2,000 hours instead of the actual hours worked), claiming credit for benefits paid with employee funds rather than employer contributions, counting benefits that do not meet Davis-Bacon’s “bona fide benefit” requirements, and failing to reduce fringe credits when employees work fewer hours than the annualization calculation assumed.

A particularly problematic error involves “fringe dumping”—paying excessive cash in lieu of fringes to employees who receive no actual benefits, then pocketing those fringe payments rather than providing them to workers. This practice constitutes fraud rather than a calculation error.

Why it matters. Fringe benefit calculations directly affect worker compensation. An employee entitled to $8 per hour in fringe benefits but receiving only $5 in actual benefits should receive $3 per hour as cash in lieu. If the contractor miscalculates and pays only $1 in cash in lieu, the worker is shorted $2 per hour—significant money over weeks or months of work.

The consequences. Fringe benefit calculation errors create back wage liability equal to the shortfall. If workers should have received $3 per hour in cash in lieu but received only $1, the contractor owes $2 per hour for every hour those workers performed on the project, plus liquidated damages matching the underpayment.

Fringe dumping—fraudulently claiming to provide fringes while actually withholding them—constitutes criminal conduct that can lead to prosecution, fines, and imprisonment. This moves beyond civil penalties into criminal liability because it demonstrates intentional wage theft rather than calculation mistakes.

Mistake 5: Inadequate Record Retention and Documentation

The error. Contractors fail to maintain complete records for the required three-year retention period, discard supporting documentation after submitting certified payroll reports, or cannot produce records promptly when the Department of Labor requests them during an investigation.

Required records include all certified payroll forms submitted, time cards or other time-tracking records for each employee, wage determinations applicable to each project, proof of fringe benefit contributions (insurance invoices, retirement account statements, PTO accrual records), apprenticeship registration documents for any apprentices employed, all correspondence with contracting agencies regarding the project, and contracts and subcontracts documenting project requirements.

Why it matters. Department of Labor investigations often occur years after project completion. An investigation launched in 2028 might examine a project completed in 2026. If the contractor cannot produce records to defend their compliance, the DOL presumes violations occurred.

The three-year retention requirement runs from project completion, not from when individual reports were submitted. A three-year project requires seven years of record retention (four years of active work plus three years post-completion). Contractors who purge records annually to free up storage space may destroy documentation still subject to the retention requirement.

The consequences. Failure to produce records when requested creates an adverse inference during investigations. The DOL assumes missing records would have revealed violations, shifting the burden of proof to the contractor to demonstrate compliance without documentation.

This practically guarantees adverse findings, back wage assessments, and penalties even if the contractor actually complied with all prevailing wage requirements. The inability to prove compliance becomes equivalent to proven non-compliance.

Compliance Penalties: What Non-Compliance Actually Costs

Understanding the financial and operational consequences of certified payroll violations reveals why investing in proper systems and processes is not optional for contractors pursuing government work.

Back Wages and Liquidated Damages

When violations are discovered, contractors must first make workers whole by paying all wages those workers should have received but did not. This includes underpayments from incorrect wage rates, worker misclassification, insufficient fringe benefits, or miscalculated overtime.

Back wage calculations compound quickly. Consider a contractor who misclassified five workers throughout a six-month project. Each worker should have received $35 per hour but was paid $28 per hour—a $7 hourly shortfall. Working 40 hours per week for 26 weeks, each worker is owed $7,280 in back wages ($7 × 40 × 26). Across five workers, the total back wage liability reaches $36,400.

Liquidated damages double this liability. The Contract Work Hours and Safety Standards Act imposes liquidated damages equal to the underpayment amount. The contractor owes $36,400 in back wages plus $36,400 in liquidated damages, totaling $72,800 in direct financial penalties.

These amounts come directly from the contractor’s profit margin. The work was already performed and original contract payment already received. The back wages and liquidated damages represent pure loss.

Withholding of Contract Payments

Contracting agencies possess authority to withhold progress payments and final payments pending resolution of certified payroll compliance issues. This creates immediate cash flow problems that can threaten business operations.

A contractor with $500,000 in outstanding invoices who faces a certified payroll investigation may receive no payments for months while the Department of Labor examines records, interviews workers, calculates back wage obligations, and negotiates resolution. Construction businesses operating on tight cash flow margins cannot survive extended payment delays.

Even after back wages are paid and violations resolved, withheld funds may not be immediately released. Agencies often maintain a portion of contract proceeds as security against future violations or worker complaints that arise after project closeout.

Debarment From Federal Contracting

Perhaps the most severe consequence, debarment prohibits contractors from receiving federal contracts or subcontracts for a specified period, typically three years.

Debarment effectively ends a contractor’s ability to pursue government work. The contractor cannot bid on federal projects as a prime contractor, cannot serve as a subcontractor on federal projects (since prime contractors cannot hire debarred subcontractors), and loses eligibility for federally-assisted projects that incorporate Davis-Bacon requirements.

For contractors who derive 30 percent or more of their revenue from government work, debarment represents an existential threat. The business must either find sufficient private work to replace lost government revenue or face closure.

The reputational damage extends beyond the debarment period. Bonding companies view debarment as a major risk factor and may refuse to bond the contractor or dramatically increase bond premiums. This makes it difficult to compete for large projects even after debarment expires.

Criminal Prosecution for Falsification

The most serious violations—those involving intentional falsification of certified payroll reports or fraudulent wage schemes—can result in criminal prosecution.

The Department of Labor explicitly warns that falsifying certified payroll statements can lead to fines and imprisonment up to five years. This criminal liability extends to the individual who signs the Statement of Compliance certifying the report’s accuracy.

Company executives, project managers, and payroll administrators who knowingly submit false certified payroll reports face personal criminal liability separate from any civil penalties imposed on the company. A conviction creates a permanent criminal record that affects professional licensing, bonding capacity, and future employment opportunities.

Real-World Example: Florida Contractor Penalty

A 2024 case illustrates how these penalties accumulate. A Florida-based contractor was ordered to pay $124,000 in back wages and fringe benefits after the Department of Labor found violations of the Fair Labor Standards Act, Contract Work Hours and Safety Standards Act, and Davis-Bacon Act.

The problems stemmed from failing to assign and pay correct prevailing wages and not accurately tracking hours worked. The contractor neither intentionally defrauded workers nor submitted knowingly false reports—these were compliance system failures and calculation errors. Yet the financial penalty reached $124,000, potentially representing the entire profit margin on the project.

This case demonstrates that good intentions do not protect contractors from liability. The obligation is strict compliance with prevailing wage requirements, not reasonable efforts or good-faith attempts. Systems that cannot ensure accurate wage calculations, proper worker classification, and compliant reporting create unacceptable risk.

Alternative Solutions: When to Abandon Gusto Entirely

For contractors regularly working on prevailing wage projects, the practical reality is that Gusto cannot serve as the primary payroll system without creating substantial compliance risk and administrative burden.

Cost-Benefit Analysis: Gusto vs. Construction Payroll Software

Gusto costs for a construction company with 25 employees approximate $189 per month using the Simple plan ($49 base + $6 per person × 25 employees). The Plus plan with enhanced features runs $380 per month ($80 base + $12 per person × 25 employees).

These costs do not include the hidden expense of manual certified payroll processing: exporting data, calculating prevailing wages, completing WH-347 forms, and tracking compliance. At 10-12 hours per week for a company managing three concurrent prevailing wage projects, this administrative burden costs approximately $600 per week or $31,200 annually at typical accounting staff rates.

Total annual cost for Gusto: $2,268 (Simple plan) + $31,200 (manual certified payroll labor) = $33,468.

Construction payroll software serving the same 25 employees typically costs $600-$1,000 per month depending on feature set and support level. Annual cost ranges from $7,200 to $12,000.

This cost eliminates the manual certified payroll processing burden. Automated prevailing wage tracking, job-based rate application, and WH-347 generation reduce weekly certified payroll administration to 1-2 hours for report review and submission. At $600 per week reduced to $100 per week, annual labor savings reach $26,000.

Total annual cost for construction payroll software: $12,000 (high-end software) + $5,200 (minimal certified payroll labor) = $17,200.

The construction payroll software saves $16,268 annually ($33,468 – $17,200) while dramatically reducing compliance risk. The return on investment appears within the first month of operation.

Signs It’s Time to Switch

Several indicators suggest a contractor has outgrown Gusto’s capabilities and should transition to dedicated construction payroll software:

You’re spending more than 5 hours per week on manual certified payroll processing. This threshold represents the breakeven point where software costs are offset by labor savings. Beyond 5 hours weekly, contractors are paying more in administrative time than construction payroll software would cost.

You’ve received a Department of Labor inquiry or failed an audit. Any contact from the DOL regarding potential violations signals that current compliance processes are inadequate. Switching to software with built-in compliance checks prevents future violations rather than continuing to risk penalties with manual processes.

You’re bidding on three or more concurrent prevailing wage projects. Multiple simultaneous projects multiply the administrative burden exponentially. Three projects each requiring weekly certified payroll reports mean processing 12 reports per month, tracking three different wage determinations, managing three sets of fringe benefit calculations, and maintaining three separate compliance files. Construction payroll software manages this complexity automatically.

You’ve lost a bid because your payroll system couldn’t handle the requirements. Some large federal contracts specify that bidders must demonstrate the payroll systems and processes necessary for Davis-Bacon compliance. A contractor using Gusto may be disqualified or viewed as higher risk than competitors using proven construction payroll platforms.

Your accounting firm has recommended upgrading to construction-specific software. External accountants reviewing a company’s financial records and compliance processes offer objective assessment of system adequacy. When accountants suggest upgrading payroll systems, contractors should heed that advice before problems occur.

Migration Planning: Moving From Gusto to Construction Payroll Software

Transitioning payroll systems mid-year requires careful planning to avoid disrupting payroll processing or creating tax reporting problems.

Timing the transition. The cleanest migration occurs at year-end or quarter-end, allowing contractors to close out Gusto’s records, finalize all tax filings, and start the new period fresh with the construction payroll system. Mid-year transitions are possible but create split-year W-2 reporting and require careful coordination between systems to ensure year-end tax forms capture all wages correctly.

Data migration. Most construction payroll providers offer data import services to transfer employee information, pay histories, tax withholding elections, and benefit enrollment from Gusto to the new system. This import process typically takes 1-2 weeks, including data validation to ensure everything transferred correctly.

Parallel processing period. Experienced contractors run one or two payroll cycles simultaneously through both Gusto and the new construction payroll system before fully cutting over. This parallel processing identifies any discrepancies in calculations, validates that the new system produces correct results, and gives payroll administrators time to learn the new software before depending on it exclusively.

Employee communication. Workers notice changes to their pay stubs, direct deposit account distribution, and benefits enrollment portals. Clear communication explaining the transition, highlighting any changes to pay stub formats or employee self-service systems, and providing support contact information prevents confusion and payroll-related questions from overwhelming administrators.

Frequently Asked Questions

Can Gusto generate Form WH-347 for certified payroll?

No. Gusto does not generate Form WH-347 or any certified payroll reports. The platform lacks the functionality to create Davis-Bacon compliant forms, requiring contractors to manually complete WH-347s using exported payroll data.

Does Gusto track prevailing wages automatically?

No. Gusto cannot automatically apply prevailing wage rates based on project location or contract requirements. Contractors must manually enter custom pay rates for each employee working on prevailing wage projects.

Can I use Gusto for construction payroll?

Partially. Gusto handles basic payroll processing for construction companies but lacks construction-specific features like job costing with automatic wage rate application, certified payroll reporting, prevailing wage tracking, and fringe benefit equivalency calculations.

What payroll software do construction contractors use for certified payroll?

Construction contractors typically use specialized software including LCPtracker, eBacon, FOUNDATION, Payroll4Construction, or ADP with construction-specific modules. These platforms automate prevailing wage tracking, job-based rate application, and Form WH-347 generation.

How much does certified payroll software cost?

Certified payroll software costs range from $10-$12 per report for basic services like LCPtracker to $600-$1,000 per month for comprehensive construction payroll platforms serving 20-30 employees.

What happens if I submit certified payroll late?

Late certified payroll submissions can result in withheld progress payments, contract compliance violations, and increased scrutiny from contracting agencies. Persistent late submissions contribute to adverse findings during Department of Labor investigations and can lead to debarment.

Do I need certified payroll for state-funded projects?

It depends on the state. Thirty-two states maintain prevailing wage laws requiring certified payroll for state-funded public works projects. Twenty-three states have eliminated prevailing wage requirements, meaning state projects in those states do not require certified payroll.

Can I export data from Gusto to complete WH-347 manually?

Yes. Contractors can export payroll data from Gusto to Excel or CSV format, then manually populate Form WH-347 using that data. This process requires 2-4 hours per week per project and introduces opportunities for calculation errors.

What’s the penalty for not doing certified payroll correctly?

Penalties include back wages owed to workers, liquidated damages equal to the back wage amount, withholding of contract payments, contract termination, debarment from federal contracting for up to three years, and potential criminal prosecution for fraudulent reporting.

How do I calculate fringe benefits for certified payroll?

Divide the total annual cost of fringe benefits by the employee’s total annual working hours to get the hourly fringe benefit rate. Compare this rate to the required fringe rate from the wage determination. Pay any shortfall as cash in lieu of fringe benefits.

Does QuickBooks Online do certified payroll?

QuickBooks Online Payroll does not natively generate certified payroll reports but offers better job costing capabilities than Gusto. Some contractors use QuickBooks with third-party certified payroll add-ons or manual WH-347 completion.

Can subcontractors submit certified payroll through the prime contractor’s system?

Prime contractors often use certified payroll platforms that allow subcontractors to submit reports directly through the prime’s system. LCPtracker, for example, provides subcontractor portals where subs upload their certified payroll for prime contractor review before agency submission.

What information must appear on certified payroll reports?

Certified payroll reports must include worker names and identification numbers, job classifications, daily and weekly hours worked (separated by regular and overtime), base wage rates, fringe benefit amounts, gross wages earned, itemized deductions, net wages paid, and a signed Statement of Compliance.

Are 1099 contractors included on certified payroll?

No. Certified payroll requirements generally apply only to employees classified as W-2 workers. Independent contractors properly classified as 1099 workers are not included on certified payroll reports.

How long must I keep certified payroll records?

Contractors must retain all certified payroll records, supporting documentation, time cards, wage determinations, and proof of fringe benefit contributions for three years after project completion.