The Mistakes That Get a Certified Payroll Rejected
A certified payroll comes back for one of a small number of reasons, and the same ones recur week after week: a rate that is a little under the determination once fringe is counted, hours in two classifications lumped onto one line, an overtime rate figured on the wrong base, a worker shown as an apprentice without a registration, a deduction that is not on the permitted list, a missing week or a broken payroll number sequence, an identifying number left blank, or a Statement of Compliance whose fringe boxes do not match page 1. Each one is a rule, and each one is visible on the form before it is signed.
1. The rate is short once fringe is counted
The determination says 22.50 basic plus 8.10 fringe. The payroll shows 21.50 in column 6A and 8.10 in 6C. That is 29.60 against an obligation of 30.60, a dollar short on every hour, and it compounds into restitution with interest over a job. Nothing in the payroll looks wrong until the two numbers are added. The fringe guide covers the arithmetic.
2. Two classifications on one line
A worker who framed on Monday and cleaned up on Friday is two lines: carpenter hours at the carpenter rate and laborer hours at the laborer rate. Putting the whole week on the higher-rate line overpays and misstates the classification; putting it on the lower one underpays. The instructions require a separate entry per classification.
3. Overtime on the wrong base
The overtime rate is one and one-half times the basic rate in the determination or the higher actual rate paid, excluding fringe. Contractors who pay one all-in cash rate often figure overtime on the basic rate alone when the cash they pay is, on paper, all wage; others multiply the fringe. The overtime guide works both cases.
4. An apprentice who is not registered
Column 2 says RA, column 6A shows a percentage rate, and there is no individual registration on file. That worker is a journeyworker paid short for every hour, and page 2 paragraph 3 was certified falsely. The apprentice guide has the registration and ratio rules.
5. A deduction that is not permitted
A uniform charge, a tool purchase, a damage recovery or a shortage taken from pay on certified work is a Copeland Act violation unless it fits 29 CFR 3.5 or has an approval under 3.6. Column 8 shows it; paragraph 1 certifies that no such deduction was made. The deductions guide lists what is allowed.
6. A missing week or a broken sequence
Payrolls are numbered from 1 for the contract, one per week of covered work. A reviewer who sees payroll 7 followed by payroll 9 asks for 8. If no covered work was done, a short statement of that keeps the sequence intact; if work was done and the payroll is late, it is late against the seven-day delivery rule in 29 CFR 3.4.
7. A blank or full identifying number
Column 1E must carry an individually identifying number, in practice the last four digits of the Social Security number. Blank is a rejection. The full number is worse: the weekly submission is not supposed to carry it, and the submission may be handled by people who should never see it.
8. Page 2 does not agree with page 1
Box (a) ticked, fringe paid to plans, while 6B is empty and 6C carries cash. Or both 6B and 6C filled with no exception noted. The fringe boxes on the Statement of Compliance have to describe what page 1 shows.
9. Hours on the wrong day
Column 4 is dated. A week ending date changed after the hours were typed in a positional spreadsheet shifts every day’s hours under a different date, and the form then swears that Monday’s eight hours were worked on Saturday. It has happened in tools that store hours by column rather than by date.
10. Arithmetic
Column 5 that does not equal column 4. A 7A that is not hours times rate. A 9 that is not 7B minus column 8. Typed totals drift; derived ones do not.
The pattern. Every one of these is checkable from the form and the determination before signing, with no information the contractor does not already have. A review is a comparison, and the comparison can be done first.
Common questions
What happens to a payroll with an error?
The agency asks for a corrected payroll for that week, and any underpayment is paid as restitution and shown on the corrected payroll. Patterns of the same error draw an investigation rather than a request.
Is a typo a false statement?
Willful falsification is what the statute punishes. A typo is a mistake to correct. A rate that was never checked against the determination, week after week, is harder to call a typo.
Can I fix a payroll from three months ago?
Yes, with a corrected payroll marked as such and the back wages paid. Corrections found by the contractor are treated very differently from the same errors found by a reviewer.
Check it before you sign it
EG Certified Payroll was built around this list. Check reads the whole payroll against the wage determination and the rules, names the worker, the cell and the amount, and will not approve a payroll with a blocking finding.
See EG Certified Payroll (WH-347)Free trial, the full product; every printed page carries a TRIAL COPY mark until a license is activated. Windows Excel.
More in this series: Prevailing Wage and Fringe Benefits on Certified Payroll · Certified Payroll in Excel: What a Spreadsheet Has to Get Right · All certified payroll guides
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