Common Mistakes in FAR 22.406-7 Labor Compliance Checks
On federal construction projects, contracting officers are obligated to enforce strict labor standards across all covered contracts. Under Acquisition.GOV FAR 22.406-7, contracting officials conduct regular checks and investigations to verify that trade contractors fulfill their labor obligations. For interior subcontractors, framing crews, and general contractors, misunderstanding how these checks operate can create severe project friction. Reviewing the most frequent missteps helps teams maintain clean records and pass on-site evaluations without disruption.
Mistake 1: Treating Standard Form 1445 Employee Interviews as Informal Chats
Under federal procurement regulations, regular compliance checking includes direct employee interviews. Contracting officers use these field conversations to test payroll accuracy against actual jobsite conditions. Subcontractors often make the mistake of failing to prepare their workforce for these routine visits or assuming inspectors are merely asking casual questions.
The contracting officer conducts employee interviews specifically to determine:
- The correctness of job classifications assigned to trade workers
- Actual rates of pay received by employees on site
- Fringe benefits payments disbursed or contributed on their behalf
- The exact hours worked on the project
These interviews are documented using Standard Form 1445. If an employee's description of their hourly duties or wage rate conflicts with the certified reports submitted by the office, the discrepancy immediately surfaces during the review. Estimators and project managers must understand prevailing labor classifications when bidding work, as outlined in our guide on Davis-Bacon prevailing wage myths vs. facts for bidders.
Mistake 2: Neglecting On-Site Postings and Crew Classification Inspections
Regular compliance checking under Acquisition.GOV FAR 22.406-7 also involves formal on-site inspections. Many specialty trade contractors assume compliance begins and ends with submitted forms, but physical jobsite conditions receive equal scrutiny from contracting officers.
During an on-site inspection, federal officials verify three specific elements:
- The specific type of work performed by trades on the jobsite
- The number and classification of workers actively on site
- Full fulfillment of required jobsite posting requirements
A frequent error occurs when framing or drywall crews carry out specialized technical installations while listed as general laborers, or when required labor posters are missing from common jobsite areas. If field inspectors observe workers handling tasks that do not match their assigned worker classifications, compliance issues are recorded right away.
Mistake 3: Submitting Late or Incomplete Certified Payrolls
A central pillar of labor compliance is the routine payroll review. Contracting officers examine submissions to verify that the payrolls of prime contractors and subcontractors are submitted on time, are fully complete, and comply with all contract labor requirements. Falling behind on administrative submissions or providing incomplete documentation is one of the most widespread contractor errors.
Prime contractors bear responsibility for every tier beneath them. If a drywall or acoustical ceiling subcontractor delays payroll paperwork or leaves out required classification details, the entire compliance stream breaks down. To avoid common payroll reporting traps, review our walkthrough on FAR 22.406-6 certified payroll mistakes on federal bids.
Mistake 4: Failing to Reconcile Field Data with Daily Construction Logs
Contractors often fail to realize that federal compliance checking is an integrated cross-referencing process. Under the FAR regulations, contracting officers do not review payroll documents in total isolation. Instead, they perform a direct comparison between interview records, on-site inspection findings, and certified payroll reports against available project data.
This comparison specifically incorporates:
- The daily inspector's report prepared by government staff
- Daily logs of construction maintained on the site
A severe mistake is reporting four carpenters on a certified payroll submission for a Tuesday when the daily inspector's report or construction log records seven workers hanging drywall on that same day. When workforce numbers, hours, or classifications in the daily logs fail to match the payroll reports, contracting officers immediately spot the inconsistency.
Mistake 5: Overlooking Triggers for Special Compliance Checks
While regular checks occur systematically, contracting officers are also authorized to initiate special compliance checks. Contractors frequently underestimate how quickly routine administrative oversights can escalate into targeted investigations. Under FAR 22.406-7(c), situations that may require special compliance checks include:
- Inconsistencies, errors, or omissions detected during regular compliance checks
- Receipt of a complaint alleging labor standards violations
When an outside complaint alleging violations is received, the contracting agency reviews its merits. If the initial complaint is not specific enough, the regulations state that the complainant shall be advised of that fact and invited to submit additional information. Clean records, accurate worker classifications, and timely submissions prevent routine checks from turning into expanded compliance investigations.
Sources
Published October 31, 2026. No affiliate links on this page. Facts come from the sources linked above; check them for updates.