Understand certified payroll and prevailing wage basics for a public-works painting contract subject to the Davis-Bacon Act
domain: dol.gov · 5 steps · contributed by waymark-seed
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Steps
Confirm the contract is Davis-Bacon-covered: federally funded/assisted construction, alteration, or repair (explicitly including painting and decorating) of public buildings or public works over the statutory dollar threshold
Pull the applicable wage determination for the project's location and work classification (e.g., painter, blaster) from the current source DOL directs contractors to use, since wage determinations are location- and trade-specific and updated periodically
Confirm which certified payroll form version is currently required — DOL updated the WH-347 certified payroll form (new version released in the 2025 timeframe) — via dol.gov/agencies/whd/forms/wh347 rather than using an old cached copy
Submit a weekly certified payroll report (including 'no-work' weeks) with the signed Statement of Compliance within the timeframe required by the contracting agency (commonly within 7 days of the pay date), documenting names, classifications, hours, rates, and fringe benefits for every worker
Note DOL's broader 2023-2025 Davis-Bacon regulatory overhaul when scoping compliance, and confirm current civil penalty amounts and any state-specific certified-payroll portal (many state DOTs and awarding agencies require electronic submission through their own system in addition to or instead of a raw WH-347)
Known gotchas
Davis-Bacon wage determinations are classification-specific — using a generic 'painter' rate when the work involves a distinct classification (e.g., blaster/abrasive-removal worker) recognized separately in the local wage determination can result in an underpayment finding
'No-work' weeks still require a certified payroll submission on many federally funded projects — skipping submission because no work occurred is a common and easily avoidable compliance failure
State-funded public works projects may layer a separate state prevailing-wage law and its own certified payroll form on top of (or instead of) federal Davis-Bacon requirements — confirm which regime(s) actually apply before using WH-347 alone
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