Many SCA compliance failures are preventable. While legal and consultant guidance is important, contractors often avoid issues by getting the basics right and keeping clear, accurate records.
Key steps include:
Ensure workers are paid using an hourly rate, not a daily rate, even if the client is billed daily. The hourly rate must meet or exceed the applicable Wage Determination rate for the worker’s classification and location, whether under an SCA or DBA contract.
Pay required fringe benefits and show them as a separate payroll line item.
Maintain your own timekeeping records, even if you bill using a client or contractor timekeeping system.
Clearly document regular hours, overtime, per diem, reimbursements, and expenses on the employee’s pay statement.
Make sure every worker has access to their payslip.
Provide each worker with a simple, signed acknowledgment letter confirming their WD code, occupational classification, job title, houly rate, fringe benefit amount, overtime rate, and any additional benefits, such as per diem, truck pay, or other allowances. Clear communication helps prevent confusion and reduces the likelihood of complaints.
Strong documentation, transparent payroll practices, and proper worker classification can go a long way toward reducing the risk of DOL audit findings.
The WD Rates can be obtained from
the U.S. government’s System for Award Management SAM.gov.