Davis-Bacon & CWHSSA Overtime Math: Stop Overpaying Fringes or Risking $32/Day Fines

Standard payroll software gets Davis-Bacon overtime wrong in two expensive ways. Either it multiplies your cash-in-lieu fringes by 1.5× and bleeds thousands in extra labor cost, or it underpays the half-time base premium.

Underpaying by even ten cents an hour triggers back-wage withholding plus $32 per worker per day in CWHSSA liquidated damages (29 CFR § 5.5(b)(2)).

1. Your Exact 29 CFR § 5.32 Overtime Formula

2. Three Overtime Rules Every Subcontractor Bookkeeper Needs

• Pay fringes at 1.0× on overtime, never 1.5×. You owe full prevailing fringes on every overtime hour worked. However, the 0.5× premium applies only to the base wage, never to Column 6B plan credits or Column 6C cash-in-lieu fringes.
• Paying above the SAM.gov base rate raises your overtime floor. Suppose SAM.gov sets Electrician pay at $38.50/hr base + $14.20/hr fringe, and you pay $39.00/hr base cash. Your minimum Column 6A overtime cash rate is 1.5 × $39.00 = $58.50/hr, plus $14.20/hr fringe.
• Watch the split-trade 40-hour trap. Suppose one employee logs 24 hours as an Electrician and 22 hours as an HVAC Mechanic on the same federal job. That totals 46 hours, so you owe 6 hours of CWHSSA overtime even though neither trade crossed 40 hours alone.