Companion Guide to Video - Project Construction and Contract Administration - Contractor Payroll Submittals and Statements of Compliance

Sep 22, 2026

Guide to weekly contractor payroll submittals for federally funded highway projects, explaining how LPAs (local public agencies) verify compliance with key federal labor laws. Details requirements stemming from the Copeland Act (anti-kickback), the Davis-Bacon Act (prevailing wages and benefits), and additional nondiscrimination and safety provisions. Describes required payroll elements, the attached Statement of Compliance signed by an authorized agent, and practical review methods such as “trust, but verify,” spot-checks, and employee interviews.

LanguageEnglish

CategoryLetters

FormatPDF

Pages3

Reading Time1 min

AccessFree to download

Contractor Payroll Submittals

Statement of Compliance Requirements

Copeland Act Overview

Davis-Bacon Act Overview

LPA Compliance Example (Johnson County)

Additional Resources

Companion Guide to Video August 2012 Project Construction and Contract Administration Contract Administration Contractor Payroll Submittals and Statements of Compliance [www.fhwa.dot.gov/federal-aidessentials](www.fhwa.dot.gov/federal-aidessentials) Contractors are required to submit weekly employee payrollson all federally funded projects The Federal-aid Highway Program is subject to Federal laws that regulate fair labor practicesand workers pay. The local public agency, or LPA, that uses Federal-aid funds is responsible for verifying that its contractors comply with these labor laws and all other Federal requirements. Contractors are required to submit employee payrolls on all federally funded projects. Submitted payrolls are used to verify that the requirements of four labor related laws are complied with. These laws are the Copeland Act, the Davis Bacon Act, the Fair Labor Standards Act, and the Civil Rights Act. These laws are important because they free employees from coercion, ensure payment of prevailing wages and benefits, provide for nondiscrimination of workers, and often require actions by Federal funding recipients. First, let’s look at The Copeland Act of 1934. This act was enacted to stop the common practice of contractors and subcontractors from forcing employees to give up part of their pay in order to continue working on a federally funded project. For this reason, the act is sometimes referred to as the “anti-kickback act." As a first step, Federal-aid contracts must include the requirements of the act for contractors. All contractors on federally funded projects are required by the U.S. Department of Labor to submit weekly payroll records that contain the employee’s full name and employee number, classification code, hourly wage, hours worked, gross wages, itemized deductions , and net wages. Form FHWA-1273- “Required Contract Provisions Federal-Aid Construction Contracts” -includes this requirement and other provisions mandated for federally assisted construction contracts. In addition, a Statement of Compliance must accompany each contractor payroll. The Statement of Compliance is attached to a payroll submittal and certifies that the payrolls are correct and complete, that the wage rates paid are not below those required by the wage decision in the contract, and that each laborer or mechanic’s classification conforms to the work performed. The statement must be signed by an authorized agent of the contractor, indicating that the facts represented in the payroll are true. Violation of the act is a crime that can result in severe penalties, including fines and imprisonment. Another law that deals with contractor payrolls that applies to Federal-aid contracts is the Davis-Bacon Act of 1931. This law requires that contractors and subcontractors pay on-site workers no less than the locally prevailing wages and benefits. The U.S. Department of Labor tracks this data and develops wage decisions that are incorporated into every Federal-aid contract. The act applies to contractors and subcontractors who perform work on Federal or federally assisted construction contracts in excess of $2,000 . Therefore, the Davis-Bacon requirements are relevant for Federal-aid contracts. The contractor may choose to use a U.S. Department of Labor Payroll WH-347 form to submit payroll information and the statement. While use of the form is optional, the information it provides is mandatory. The weekly payrolls should be checked to verify that each laborer or mechanic has been paid an appropriate wage and has not been subjected to coercion by the employer. Other laws and regulations, such as the Fair Labor Standards Act and the Civil Rights Act, have additional provisions for nondiscrimination in personnel practices, paying minimum wage rates , and ensuring job-site safety. Let’s now look at how an LPA complies with these requirements by using a fictional Johnson County project as an example.

FAQs

What must contractors submit for weekly payrolls on federally funded projects?

Contractors must submit weekly employee payroll records containing required identifying and wage and hours information, along with a signed Statement of Compliance for each payroll submittal.

What does the Statement of Compliance certify?

It certifies that the payrolls are correct and complete, wage rates meet or exceed the contract wage decision, classifications match the work performed, and it is signed by an authorized contractor agent.

How does an LPA verify contractor compliance during construction?

An LPA includes required provisions in the contract and, during construction, reviews weekly payroll submittals (e.g., WH-347 usage), performs spot-checks, conducts brief employee interviews, and maintains a project file for records and verification documents.

Sep 22, 2026

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