Published date: 04/16/2026
Aliecia Taormina, CCEP, MCA has over 20 years of experience in construction (including a role as a Senior Compliance Manager of a Fortune 300 contractor), accumulating extensive prevailing wage and Davis-Bacon knowledge over her career.
Question
We are a union subcontractor performing asphalt and concrete work and have recently been required to submit certified payroll reports through LCPtracker. We report base wages and fringe benefits using union rates, but prime contractors are requesting paystubs and noting that the base wage shown on certified payroll does not match paystub amounts, which reflect post‑tax and post‑deduction wages. How should base wages be properly reported and explained, and what’s the best way to address these discrepancies to avoid payment delays?
Answer: This is a common point of confusion when contractors first transition to Certified Payroll Reporting (CPR) in LCPtracker, particularly for union contractors. So, when you are entering the payrolls into LCPtracker, the base (straight‑time) hourly wage reported in LCPtracker represents the employee’s gross hourly rate before any deductions, including taxes, union dues, benefit withholdings, or other payroll deductions. This is consistent with prevailing wage reporting requirements, which require contractors to report gross wages earned, not net “take‑home” pay reflected on a paycheck. If there are items on the remuneration statement (check stub) that do not match the certified payrolls, it might be important to explain those differences (or be able to) otherwise this could be an issue if there was ever an investigation for the project.
It is important to note that if the union wages are lower than the prevailing wages on the wage determination, it is important to understand that the employee must be paid the higher hourly wages that are stated in the wage determination.
Question
When reporting prevailing wage, are apprentices entitled to 100% of fringe benefits, or should fringes be paid based on their apprenticeship percentage level?
Answer: Great question! The answer is that it depends. On Davis-Bacon projects, apprentices can be paid fringe benefits in more than one way, so both situations are possible. It is important that you understand the apprenticeship program documentation first to see how apprentices should be paid fringe benefits. If the program doesn’t detail this out (or if it is silent), then apprentices are required to be paid the full fringe benefit rate like journey workers.
In fact, there are three common ways apprentices may receive fringe benefits:
- They may be paid fringes based on their apprentice dispatch paperwork or the applicable collective bargaining agreement.
- They may be paid the full fringe benefit rate, the same as journey workers.
- They may be paid fringes at the same percentage as their apprenticeship wage level.
Question
We completed a project that we did not initially realize was subject to prevailing wage. After completion, the general contractor issued a change order to cover the additional prevailing wage costs. Can we pay employees the wage difference as a lump‑sum adjustment and submit it on a single certified payroll?
Answer: Aah, this one is a tricky situation. The great news is that the general contractor is providing a change order for the additional prevailing wage costs. You can absolutely pay employees the difference in one lump sum, but you’ll need to have backup documentation that proves the employees were paid accurately. However, it would be best to continue the discussion with your general contractor regarding how they want the certified payroll reporting (CPRs) done. For example, if the project is covered under Davis-Bacon rules, submitting one certified payroll report for the entire project in lieu of CPRs for multiple weeks would NOT be in compliance. In our experience, we have seen contractors note an employee was paid with more than one paycheck for a workweek on their weekly certified payroll reports.
Factors like the number of workers, amount of performing weeks, and the additional overhead time and cost it would take to generate certified payroll reporting should absolutely be a part of that conversation. Bear in mind that certified payroll reporting not only lists the wages the employees were paid, but also the craft/classification and total hours workers generated in a work week. Additionally, it would be best to verify if the prevailing wage rules for the project require any restitution interest to be paid to the employee.
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These materials are being issued with the understanding that LCPtracker is not engaged in rendering legal or other professional services and is providing these for informational purposes only. If legal, accounting, or tax expert assistance is required, the services of a competent legal, accounting or tax professional should be sought.
