Guides / Apprentices on certified payroll

Apprentices on certified payroll

An apprentice rate is a discount on the full journeyworker rate. You only get to use it under two conditions, and missing either one turns a discount into underpayment.

The worker has to be in a registered program

An apprentice rate is only valid if the worker is registered in a program approved by the DOL Office of Apprenticeship or a State Apprenticeship Agency. Someone you call an apprentice in the shop, but who is not registered, is not an apprentice on a Davis-Bacon job. They have to be paid the full journeyworker rate for the classification, base and fringe. Pay them the apprentice rate instead and that gap is back wages you owe.

The rate has to match the step

A registered program pays apprentices as a percentage of the journeyworker rate that steps up over time. The rate on the payroll has to match the worker's actual step in the program schedule, and the fringe follows whatever the wage determination or the program requires for that step. Column 2 marks the worker RA and lists the level of progression, so the reviewer can check the rate against the step.

The ratio on site is capped

The number of apprentices you can have working next to journeyworkers is capped by the ratio in the approved program standards. If you run more apprentices than the ratio allows on a given day, the ones over the limit have to be paid the full journeyworker rate for that day. This is the part people forget, because the program lets them register plenty of apprentices, but the job site ratio is a separate limit.

Page 2 has to name the program

If any apprentice worked in the period, box 4 on the Statement of Compliance gets checked, and you list each program, whether it is registered with the federal office or a state agency, and the classification. More than three entries need an addendum.

Apprentice rows are one of the most common reasons a payroll gets a second look, because the rate, the step, the ratio, and the program all have to agree. If yours has apprentices on it, that is exactly the kind of thing worth a check before it goes in.