Certified Payroll numbering and the submission of “No Work” performed reports should be easy to figure out, but the way that the instructions provided on the U.S. Department of Labor website are written is very confusing – see this question submitted by a reader.
Our company is fairly new to working on Prevailing Wage jobs and submitting certified payroll reports and I’m so confused about the requirements for numbering the reports and the submission of “No Work Performed” payrolls. The U.S. Department of Labor (DOL) website states payrolls must be submitted sequentially and should be based on the weeks worked under a contract but the instructions also states submit for no work week. Can you tell me which is correct? Thanks, Pamela
Thanks for stopping by and submitting a question. Let’s see if I can help clear things up for you, because this really is one of those “grey” areas and really it will all depend on the contract (or so I’ve found).
First of all – let’s look at the government’s instructions, which state:
- Number each weekly payroll report sequentially. Begin the sequence with “Initial” or #1.
- Submit payrolls weekly and without interruption, through the end of the contract.
- When a week involves no work to report, the contractor must still submit a payroll form indicating that “No Work” was performed – e.g. No Work Week – Payroll #5
So, basically what this is saying is that you should submit and number the certified payroll reports sequentially, beginning with payroll #1 starting on the first week that you actually have employees working on the job site and for every week afterward until you have completed the work that you were hired to do.
“No Work” payrolls should be submitted whenever there is a temporary break in your work on the project and, therefore, you will have no employees on the job site. For example, you have employees working on the job site weeks 1-4; but on week 5 and 6 you have no employees on the job site – then for weeks 5 and 6 you would submit “No Work Performed” payrolls for those weeks.
Now, here is where it gets a little “dicey”. The following is from the HUD (Housing and Urban Development) publication entitled: A Contractor’s Guide to Prevailing Wage Requirements for Federally-Assisted Construction Projects.
If you know that your firm will not be working on the project for an extended period of time, you may wish to send a short note to the general contractor and/or contract administrator to let them know about the break in work and to give an approximate date when your firm will return to the project. If you number your payrolls consecutively or if you send a note you do not need to send “no work” payrolls.
As another twist, I’ve seen it be a common requirement that you begin submitting payroll reports (even if you are not on the job site) from the first week that the project started.
Recommended best practice:
Because this area can be so “grey”, I have always recommended that you submit consecutively numbered payrolls showing both work and no work for the entire time that your company is actively working (or waiting to work) on the project – until such time that you have actually completed all of the work that you were hired to do. When you have completed all of the work and are submitting your last certified payroll report (let’s say it’s in week 26) that last payroll should be number “26-FINAL”.
I hope you’ve found this helpful. If so, please feel free to leave a comment or share it on your favorite social media network for others.