Construction: Job Site Time Tracking, Certified Payroll and Prevailing Wage

Construction time tracking has to do two things at once: record hours by worker and by project, and produce the weekly payroll detail that prevailing wage jobs require. On federal contracts covered by Davis-Bacon, contractors must submit certified payroll each week, commonly on form WH-347, and the numbers on it come straight from the time records.

This article explains what prevailing wage means for your timekeeping, how to track a worker who splits time between projects, how overtime works across jobs, and what to keep. It is general information, not legal advice. State prevailing wage laws differ, so verify with counsel or the relevant agency before bidding.

What prevailing wage requires of your records

The Davis-Bacon Act requires contractors on covered federal construction contracts to pay laborers and mechanics at least the wage and fringe benefit rates set in the wage determination for the project and classification. A covered contractor submits payroll weekly, with a statement of compliance, and the data must match the actual hours worked.

That means the time record must show the worker, the project, the day, the hours and the work classification. If the time record is a weekly total on a paper sheet, the certified payroll is built from guesses. Read FLSA timekeeping requirements for the baseline every employer must meet.

Tracking workers who split time between projects

A framer might spend Monday and Tuesday on a federally funded school project, Wednesday on a private home and the rest of the week on a state-funded job. Each project can have a different wage rate and different reporting rules. The only reliable way to separate them is to record project and classification at the time of the work.

Ask the crew to switch projects in the time system when they move, not at the end of the week. A foreman who tries to reconstruct three projects from memory on Friday will mix them up, and a mix-up on a covered job can mean back wages and debarment risk.

Construction crew checking in at a job site with a mobile time clock app

Overtime across projects: the math

Overtime for the FLSA is based on total hours in a workweek over 40, regardless of project. Federal contracts covered by the Contract Work Hours and Safety Standards Act also use a 40-hour week. Here is a hypothetical example with made-up rates: a worker earns $30.00 per hour on a private job and $42.00 per hour on a covered job (wage plus fringe paid as cash).

In one week he works 20 hours on each, 40 hours in total, so there is no overtime. If he works 26 hours on the covered job and 20 on the private job, that is 46 hours. Straight-time pay is (26 x $42.00) + (20 x $30.00) = $1,092.00 + $600.00 = $1,692.00. The weighted regular rate is $1,692.00 divided by 46 = $36.78, and the overtime premium is 6 x 0.5 x $36.78 = $110.34. Contract rules may require a different treatment on the covered portion, so confirm with a professional.

Keep the wage determination for each project with the payroll file, and note the effective date. Rates can change when a modification is issued, and the rate that applies is the one attached to the contract. A clear project folder with rates, classifications and weekly payroll copies makes an audit much easier.

Fringe benefits and classifications

Prevailing wage jobs set a total rate that includes cash wages and fringe benefits, which the contractor may pay in cash, in bona fide plan contributions, or in a mix. Time records matter here because fringe contributions are often calculated per hour worked. An error in hours becomes an error in contributions.

Classification matters just as much. A worker doing electrician's work must be paid as an electrician on that project, whatever the person's usual title. Record the classification for each entry, so a laborer who spends part of the day on a skilled task is reported correctly. See employee or independent contractor if you use subcontractors.

Job site capture and supervision

Construction sites move. A worker may arrive before the foreman, and a trailer clock does not help a crew spread over three floors and a yard. A phone-based time clock lets each worker record the start and end of work at the site, and GPS captured with the entry gives you a location to support the record.

Foremen should approve time daily or at least before the weekly cutoff. If something looks wrong, such as a worker clocked in for 14 hours, the foreman can fix it while the facts are fresh. Keep a note for any edit and keep payroll records at least 3 years, time cards at least 2 years, and longer where your state or the contract requires.

Audits and what investigators look for

Wage and hour investigators on prevailing wage jobs compare certified payroll to other evidence: daily logs, inspector reports, photos and worker interviews. If your certified payroll shows eight hours but the daily log shows a crew working ten, the gap is a finding. See DOL wage and hour audit.

The best protection is a time record that stands on its own: real punches, project codes, approvals and a change history. It does not remove the duty to pay correctly, but it lets you show how you got your numbers.

Common construction timekeeping mistakes

The most expensive mistake is rounding hours to the shift. A crew that works 7:00 a.m. to 3:30 p.m. with a 30-minute unpaid meal worked 8 hours, but a crew logged as "8 to 4:30" for every day may have worked more or less. Certified payroll with copied hours is easy to challenge.

Another is paying cash "per piece" or per day without tracking hours. Even where a day rate is lawful, the FLSA still requires hours worked to be recorded, and prevailing wage jobs need them for the weekly report.

A third is forgetting travel and training time. Time spent at required safety training, or traveling between sites during the day, is generally work time. See travel time pay for how those rules are applied.

How SimpleWorkshift Helps Construction Companies

SimpleWorkshift lets crews clock in and out from the iOS or Android app or the web, with GPS location captured with each entry, so hours are recorded at the job site. Managers see time entries and exceptions in real time, manage work schedules and shift changes per employee, and review overtime that is calculated automatically.

Custom reports and dashboards give you hours by employee and period for your payroll or certified payroll process, and payroll closing helps you finalize approved totals. SimpleWorkshift does not replace a certified payroll form, but it gives you the accurate hours to put on one. Try it free for 30 days at simpleworkshift.com.

About the SimpleWorkshift Team
We are an HR tech company building tools that save time and money for small and midsize businesses. We started a few years ago with one goal: to make powerful HR technology simple and affordable. Since then, we have kept improving our products together with our customers, because we believe that when managers spend less time on routine admin, they have more time for their people. Today our cloud platform covers time tracking, PTO and absence management and payroll closing, so you can manage your whole team in one place.