INVOICING AND PAYMENT PROCEDURES
Timekeeping and Certified Payroll
All companies subcontracted by WWC to work on government funded disaster relief projects are required to submit detailed time cards and certified payroll forms (Form WH-347) for every worker working on the project every week, as required by federal law under the Davis-Bacon Act and/or the McNamara-O’Hara Service Contract Act. Many WWC projects are government contracts that fall under the provisions of the DBA and/or the SCA, which require all workers on federally funded or federally assisted projects to be paid at least the minimum prevailing wage for that area. As such, by law, all contractors and subcontractors must certify that all workers on the project are being paid at least the prevailing minimum wage as established by the Department of Labor’s wage determination schedule.
In order to be compensated for services, all WWC subcontractors must complete federal form WH-347 certifying that their payroll meets the prevailing wage standards and return it to WWC weekly. The current prevailing wage determinations for each state and county are defined by the Department of Labor and can be found online. In addition to certified payroll forms, vendor/subs must submit detailed time cards reflecting the hours worked for every worker during the workweek. This applies to Owner-Operators, as well, regardless of classification. The U.S. Department of Labor requires WWC to collect this information for recordkeeping purposes in the event of an audit; thus, every worker must track their hours worked and submit time cards and certified payroll forms weekly, including Owner-Operators.
All completed and signed WH-347 forms must be submitted back to WWC by 12:00 noon on Monday showing the hours worked and wages paid for each employee for the preceding week. A blank fillable WH-347 Form can be downloaded here and used for this purpose. Completed forms should be sent to firstname.lastname@example.org with "Certified Payroll Form" in the subject line of the e-mail, with email@example.com and firstname.lastname@example.org being CC’d on the email. Failure to comply may result in the delay of payroll processing for that vendor/sub.
CERTIFIED PAYROLL INSTRUCTIONS FOR SUB-CONTRACTORS
Sub-contractors must fill out Form WH-347 as follows:
Contractor or Subcontractor: Fill in your company's name and check appropriate box.
Address: Fill in your company's address.
Payroll No.: Each payroll must be numbered. Your first payroll will be #1… the second #2 … and so on.
For Week Ending: List the workweek ending date. – subcontractor’s invoice billing period must match the dates used for the subcontractor’s payroll week.
Project and Location: List the name of the project (e.g. USACE Georgia Debris Removal Project)
Project or Contract No.: W912P8-14-D-0020/XXXX (where XXXX is the task order you are working on)
Column 1 - Name and Individual Identifying Number of Worker: Enter each worker's full name and the last four digits of the worker's social security number on each weekly payroll submitted.
Column 2 - No. of Withholding Exemptions: Not required
Column 3 - Work Classifications: List classification descriptive of the work performed by each employee. The WWC will provide subcontractor with work classification descriptions as well as the correlating wage for each work classification. There is one set of rates for work performed in Crisp County and a second set of rates when the employees are working in any other county on the GA Army Corps of Engineers project for Hurricane Michael in Georgia. If additional classifications are deemed necessary request for additional classification should be made through the WWC. An individual may be shown as having worked in more than one classification provided an accurate breakdown or hours worked in each classification.
Column 4 - Hours worked: List the day and date and straight time and overtime hours worked in the applicable boxes. On all contracts subject to the Contract Work Hours Standard Act, enter hours worked in excess of 40 hours a week as "overtime".
Column 5 - Total: Self-explanatory
Column 6 - Rate of Pay (Including Fringe Benefits): The regular rate of pay is listed; the fringe amount must be listed separately. (Example: base wage per SCA for a laborer is $11.41 and the Health and Welfare “fringe” is $4.18)
Column 7 - Gross Amount Earned: Enter gross amount earned on this project. If part of a worker's weekly wage was earned on projects other than the project described on this payroll, enter in column 7 first the amount earned on the Federal or Federally assisted project and then the gross amount earned during the week on all projects, thus "$163.00/$420.00" would reflect the earnings of a worker who earned $163.00 on a Federally assisted construction project during a week in which $420.00 was earned on all work.
Column 8 - Deductions: Five columns are provided for showing deductions made. If more than five deductions are involved, use the first four columns and show the balance deductions under "Other" column; show actual total under "Total Deductions" column; and in the attachment to the payroll describe the deduction(s) contained in the "Other" column. All deductions must be in accordance with the provisions of the Copeland Act Regulations, 29 C.F.R., Part 3. If an individual worked on other jobs in addition to this project, show actual deductions from his/her weekly gross wage, and indicate that deductions are based on his gross wages.
Column 9 - Net Wages Paid for Week: Self-explanatory.
NOTE: Employees accrue 1 hour of “sick” pay for every 30 hours they work. If the employee uses any of his or her sick leave time, the leave must be listed on the certified payroll form for that week. An employee must be permitted to use his or her accrued sick leave time, with pay, for their own illness, injury or other health-related needs, including preventive care; to assist a family member (or person who is like family to the employee) who is ill, injured, or has other health-related needs, including preventive care; or for reasons resulting from, or to assist a family member (or person who is like family to the employee) who is the victim of, domestic violence, sexual assault, or stalking. Subcontractor must accrue 8 hours of “Holiday Pay” for any week worked where a federal holiday is observed.
Additional information on contractor requirements and worker protections under the law is available at https://www.dol.gov/whd/govcontracts/. Additional information and guidance on how to fill out the form can be found at https://www.dol.gov/whd/regs/compliance/web/SCA_FAQ.htm, https://www.dol.gov/whd/forms/wh347instr.htm, and https://www.foundationsoft.com/tips-davis-bacon/.
Tickets for work performed are collected by the vendor/sub and then submitted to WWC for processing and payment. Payments will be based on tickets submitted; vendor/subs will not be paid for claims of work performed that lack documentation, therefore keeping track of tickets is mandatory in order to be compensated for services.
Subcontractor companies and drivers should make copies or photographs of their tickets to keep for their records prior to submitting them to WWC. Information from the tickets must be compiled and entered into a WWC invoicing spreadsheet that can be downloaded here.
The WWC billing cycle runs from Sunday through Saturday. Vendor/subs must compile all tickets collected from Sunday through Saturday, enter the ticket information into the invoicing spreadsheet, and then submit the invoice along with copies of the tickets to WWC no later than 12:00 noon on Monday every week for work performed the previous week. Ticket and invoices not received by Noon on Monday will not be processed until the following week, which will delay payment.
The best practice is for workers/drivers to inventory and log their tickets daily at the end of every work day, instead of weekly, to prevent the number of tickets from accumulating. In this manner, drivers/workers can simply submit their already tallied weekly totals of tickets at the end of the workday on Saturday. Vendor/subs and their workers are strongly advised not to wait until the end of the week and attempt to tally hundreds of tickets at once. This approach has proven problematic in the past, resulting in many a delayed payment to vendor/subs and is thus ill-advised.
Vendor/subs must assemble their tickets, invoices, certified payroll forms, and time cards for all their workers, then submit the entire packet to WWC weekly via email. Upon receipt, WWC will process the invoices and supporting documents. Vendor/subs can expect to be paid promptly after WWC receives payment from the Prime, which typically ranges anywhere from 14 to 30 days following submittal, depending on the project and contract.
Note: Due to the administrative processing procedures in place among the various tiers, payments to 2nd tier subcontractors routinely take between 14 and 30 days, but can sometimes take longer; moreover, if a vendor/sub’s paperwork isn’t submitted thoroughly and properly, the paperwork can be kicked out and returned for correction, resulting in further delays in payment. Therefore, 2nd Tier vendor/subs should maintain enough working capital to carry payroll for their workers for up to several weeks while invoices are being processed. Failure to do so could create cash flow problems for smaller vendor/sub companies with decreased cash reserves. As a rule, 2nd Tier subs should be mindful of the delays associated with government projects and budget their resources accordingly.