What are acceptable ways to confirm that payroll hourly rates have been reviewed and found to correspond with the ones on the applicable wage determination?
Date Published: May 2015
Adequate documentation of payroll review can be based on establishing a reasonable, objective set of records that can be verified by a third party. A suggested format would include a brief statement, signed and dated by the reviewer, indicating that a specifically identified payroll document had been compared to specific wage determination, along with notation whether or not any discrepancies have been identified. The applicable payroll and wage determination could either be attached or referenced to a location that is readily accessible. Depending upon the size of the project and the number of contractors, subcontractors, and workers, the grantee should conduct periodic employee interviews using the Form HUD-11 and compare the information from those interviews to payrolls received. Finding discrepancies, depending upon their severity and the grantee’s knowledge of the general contractor, may trigger the need for more frequent site visits and interviews. All of this review documentation could be subject to some level of supervisory quality control, which could be done on a sample basis, allowing for increased supervisory review if discrepancies arise.