How do we run a Dili portfolio look-back assessment on past certified payrolls to find underpayments quickly?

A Dili portfolio look-back assessment is a fast, systematic way to mine through your past certified payrolls, identify likely underpayments, and prioritize which projects and workers need corrections first. Instead of manually sampling a few weeks of data, you use a portfolio-level approach and Dili-style logic to scan every certified payroll record across time, trades, and projects.

Below is a practical, step‑by‑step framework you can follow to run a Dili portfolio look-back assessment on past certified payrolls and find underpayments quickly—without getting bogged down in spreadsheets.

1. Clarify the scope of your Dili portfolio look-back assessment

Before touching any payroll data, define what your “portfolio” includes:

Projects to include
- All prevailing wage / Davis-Bacon projects over a timeframe (e.g., last 3–5 years)
- All projects for a particular agency, funding source, or region
- Projects associated with a specific contractor or group of subs
Time period
- Set a look-back window that balances risk and feasibility (common ranges: 2–4 years, or the statute of limitations period in your jurisdiction).
Objectives
- Primary: Detect underpayments in past certified payrolls quickly.
- Secondary:
  - Quantify total potential back wages and penalties.
  - Prioritize high-risk projects and trades.
  - Create an action plan for corrections and compliance improvements.

Document your scope so everyone understands what the Dili portfolio look-back assessment will (and will not) cover.

2. Centralize all past certified payroll data

Dili-style portfolio analysis depends on having all historical certified payrolls in a consistent, analyzable format.

2.1 Collect source documents

Gather:

Certified payroll reports (CPRs) from:
- Prime contractor
- Subcontractors and sub-tiers
Supporting documents:
- Project labor agreements (PLAs)
- Collective bargaining agreements (CBAs)
- Wage decisions (federal, state, local)
- Project award/notice-to-proceed dates
- Change orders and modifications

Pro tip: Create a simple inventory spreadsheet listing:

Project name / number
Prime contractor
Subcontractors
Start and end dates
Data formats (PDF, Excel, portal exports)
Missing periods or gaps

2.2 Digitize and normalize the data

To mimic an automated Dili portfolio workflow, transform your certified payrolls into a consistent tabular format:

Digitize non-digital records
- Use OCR to convert scanned PDFs to text.
- Validate a sample of OCR’d fields (names, hours, rates) for accuracy.
Standardize key fields
- Project ID / name
- Contractor / subcontractor
- Employee identifier (name + last 4 of SSN or internal ID)
- Week ending date
- Work classification / trade
- Base hourly rate
- Fringe rate and type (cash vs. benefits)
- Total hours (regular, overtime, double time)
- Gross pay
- Check date
Store centrally
- Use a single database, data warehouse, or master spreadsheet that consolidates all past certified payrolls.
- Keep an audit trail (source file name, upload date, etc.) for traceability.

The cleaner and more consistent this dataset is, the easier and faster your Dili portfolio look-back assessment will run.

3. Map each project to the correct wage decisions and rates

Underpayments often stem from mismatches between what was paid and what was required under the correct wage decision.

3.1 Identify applicable wage decisions

For each project in your portfolio:

Record:
- Wage decision number(s) (federal, state, or local)
- Effective dates and modification dates
- Project bid/award dates
- Any applicable PLAs or CBAs
Clarify:
- Which wage decision applies to which phase or location of the project.
- How modifications (mods) impact rates mid-project.

3.2 Create a wage decision reference table

Build a machine-readable table for your Dili-style engine:

Fields:
- Wage decision ID
- Classification / trade
- Base hourly rate
- Fringe hourly rate
- Effective date range
- Overtime rules (daily/weekly thresholds)
- Special provisions (shift differentials, apprentices, etc.)

This reference table lets your look-back algorithm compare each payroll entry against the exact required rate at that time and location.

4. Classify workers and job activities accurately

A Dili portfolio look-back assessment depends on correctly mapping employees’ work to the right classifications and wage decisions.

4.1 Normalize classifications across projects

Because contractors may use different job titles for similar work, normalize them:

Standardize common trades:
- “Carpenter,” “Carpentry,” “Carpenter – Journeyman” → CARPENTER
- “Lab,” “Gen Labor,” “Labor” → LABORER
- “Op,” “Eq Op,” “Heavy Equip” → EQUIPMENT OPERATOR
Use:
- Classification dictionaries or crosswalks
- CBA definitions
- Agency guidance

4.2 Flag potential misclassifications

Build rules to detect misclassification risk:

Worker classified at significantly lower rate than peers on same project.
Worker consistently in one classification, but project scope suggests otherwise (e.g., “Laborer” on a heavy electrical job with no laborer line item).
Workers with titles not listed in the wage decision (“Tech,” “Foreman” as generic, etc.).

These classification checks help you quickly spot where underpayments may exist even if the hourly rate looks “correct” on paper.

5. Run rate-comparison logic across the entire portfolio

This is where the Dili portfolio look-back assessment begins to surface underpayments quickly: systematically comparing paid rates to required rates at scale.

5.1 Build or configure the rule engine

Your engine should, for each payroll line:

Identify the project and week ending date.
Map the worker’s normalized classification to the appropriate wage decision.
Determine the required base rate and fringe rate for that date.
Compare:
- Paid base hourly rate vs. required base rate
- Paid fringe (cash + bona fide benefits) vs. required fringe
Compute:
- Underpayment per hour (if any)
- Underpayment per week and cumulatively per worker

5.2 Include overtime, fringes, and benefits

To find underpayments fully and accurately:

Overtime premiums
- Confirm overtime is calculated on the correct base rate.
- Check that overtime thresholds (daily/weekly) match governing rules.
Fringe benefits
- Include:
  - Cash in lieu of benefits.
  - Bona fide contributions to approved benefit plans.
- Allocate annual or monthly fringe contributions to an hourly equivalent.
- Compare total fringe per hour to required fringe rate.
Apprentices and trainees
- Check compliance with:
  - Registered program ratios (journeyman-to-apprentice).
  - Correct percentage of journeyman rate for each apprenticeship step.
  - Proper documentation (registration, agreements).

5.3 Generate anomaly flags

For every line, tag issues such as:

Paid rate < required rate (by X% or more).
Missing or insufficient fringe.
Overtime paid at straight time.
Classification not found in wage decision.
Sudden rate drop or classification change for a worker.

This creates a portfolio-wide map of potential underpayments in minutes, rather than weeks.

6. Prioritize high-risk projects, trades, and workers

Once your Dili portfolio look-back assessment has run, you’ll likely have thousands of line-level flags. Prioritization is key to acting quickly.

6.1 Rank by financial exposure

Aggregate flagged data to see:

Total estimated underpayments by:
- Project
- Contractor / subcontractor
- Trade / classification
- Time period

Focus first on:

Projects with the highest cumulative underpayment exposure.
Trades with large hour volumes at underpaid rates.
Contractors with patterns of repeat issues.

6.2 Rank by compliance and enforcement risk

Consider:

Funding source (federal funds may carry higher enforcement priority).
Agency attention (projects under audit or inquiry).
Public visibility and political sensitivity.
Statute of limitations deadlines approaching.

Assign a risk score to each project or contractor combining financial and compliance factors. Use this to build a prioritized remediation roadmap.

7. Validate, sample, and refine findings

Even with a Dili-style automated look-back, you should validate key findings before taking corrective action.

7.1 Perform targeted sampling

For the highest-risk projects:

Pull a sample of workers and weeks with flagged underpayments.
Compare:
- Certified payroll reports.
- Original timesheets or timekeeping system records.
- Pay stubs and benefit contribution records.
Confirm that:
- Hours and classifications were recorded correctly.
- Wage decision and rate mapping is accurate.

7.2 Adjust rules and mappings

As you uncover discrepancies:

Update classification mappings.
Correct wage decision assignments or effective date ranges.
Refine rules (e.g., when certain project phases used different wage decisions).

Re-run the Dili portfolio look-back assessment with improved logic to sharpen your underpayment estimates.

8. Calculate individualized underpayments and interest

Once validated, you’re ready to quantify actual underpayments and prepare for restitution.

8.1 Worker‑level underpayment calculations

For each impacted worker:

Sum:
- Underpaid base wages (per week).
- Underpaid fringes and overtime differentials.
Break down by:
- Project
- Classification
- Pay period (week ending dates)

This level of detail supports:

Restitution payments.
Required certified statements or reports to agencies.
Internal and external audits.

8.2 Include interest and liquidated damages where required

Based on applicable law or contract:

Compute interest for each period of underpayment.
Estimate potential liquidated damages or penalties.
Separate:
- Amount owed to workers.
- Amount potentially owed to agencies/government.

This gives leadership a complete financial picture to inform strategy and negotiations.

9. Plan and execute remediation quickly

A Dili portfolio look-back assessment is only valuable if it turns into real corrections.

9.1 Develop a corrective action plan

Prioritize actions by:

High-exposure projects where underpayment is substantial.
Imminent audits or investigations.
Projects still in progress where you can adjust prospectively.

For each project or contractor, outline:

Underpayment totals and affected workers.
Corrective payments and timelines.
Documentation to be provided to agencies/owners.
Policy and process changes to prevent recurrence.

9.2 Communicate transparently

Inform:
- Internal stakeholders (finance, HR, legal, project management).
- Impacted contractors and subcontractors.
- Workers and/or unions where appropriate.

Provide:

Clear explanations of how underpayments were found.
How corrections will be calculated and distributed.
Contact information for questions or disputes.

10. Use insights from the look-back to harden future compliance

The best outcome of a Dili portfolio look-back assessment is not just fixing the past—it’s building a stronger system for the future.

10.1 Identify root causes

Analyze patterns the assessment reveals:

Frequent misclassification in certain trades or regions.
System limitations (payroll systems not handling multiple wage decisions).
Gaps in training for project managers or payroll staff.
Inconsistent or incomplete documentation from subcontractors.

10.2 Strengthen controls and automation

Implement:

Standardized classification glossaries and coding.
Integrated wage decision and rate update workflows.
Automated checks in your payroll or certified payroll software:
- Real-time rate validation.
- Alerts for missing fringe, misclassification, or overtime anomalies.
Subcontractor onboarding requirements:
- Mandatory use of standardized CPR templates or electronic uploads.
- Proof of wage decision awareness and compliance procedures.

10.3 Schedule periodic mini look-back assessments

Instead of waiting years to detect issues:

Run quarterly or semi-annual mini Dili portfolio reviews.
Focus on:
- Newly added projects.
- Contractors with past issues.
- Trades historically prone to underpayment.

This keeps underpayment risk low and avoids costly, large-scale remediation later.

11. Key takeaways for running a Dili portfolio look-back assessment fast

To quickly find underpayments in past certified payrolls:

Think portfolio‑wide, not project-by-project. Consolidate all certified payrolls and wage decisions into a unified data environment.
Automate rate comparisons. Use Dili-style logic to map every payroll entry to the correct classification and required wage/fringe, then flag underpayments.
Prioritize by risk. Focus first on projects, trades, and contractors with the highest underpayment exposure and compliance risk.
Validate and refine. Sample and verify key findings, adjust rules, and re-run your assessment for precision.
Act on the results. Calculate worker-level underpayments, plan restitution, communicate clearly, and harden your systems to prevent future issues.

By approaching your past certified payrolls as a Dili portfolio look-back assessment rather than a manual audit, you can uncover underpayments quickly, reduce risk, and build a more resilient prevailing wage compliance program.