Groundwork

Compliance & Payroll

Hawaii Prevailing Wage (HRS Chapter 104): A GC's Guide

Hawaii runs its own prevailing wage schedule, layered against federal Davis-Bacon rates on federally-funded work. Here's how the two interact.

The Groundwork TeamUpdated 2 min read

On this page
  1. Hawaii's schedule is state law, independent of federal funding
  2. When both apply, you pay the higher rate: by classification, not by job
  3. Fringe benefits work differently than people expect
  4. What this means for your estimate, not just your payroll
  5. Building this in, not bolting it on

If you're bidding public work in Hawaii, you're dealing with two potential wage floors at once: Hawaii's own prevailing wage schedule, administered by the Department of Labor and Industrial Relations (DLIR) Wage Standards Division under HRS Chapter 104, and (if the project has federal funding) the federal Davis-Bacon wage determination for that county. Most national certified-payroll tools have no idea Hawaii's schedule exists. Here's what you actually need to know.

Hawaii's schedule is state law, independent of federal funding

HRS Chapter 104 requires prevailing wages on Hawaii public works contracts regardless of whether federal money is involved. DLIR publishes its own wage rate schedule by trade and island. This applies even on a purely state- or county-funded job with zero federal dollars. A lot of contractors used to exclusively private work don't realize this until their first public bid.

When both apply, you pay the higher rate: by classification, not by job

On a federally-assisted Hawaii public project, both the DLIR schedule and the federal Davis-Bacon wage determination for that county can apply simultaneously. The rule is straightforward in principle and easy to get wrong in practice: for each labor classification, you owe whichever rate is higher, state or federal, and not "check which schedule is generally higher and use that one for the whole job." A carpenter might have the state schedule as the higher rate while an electrician on the same job has the federal rate as higher. Executive Order 14026's federal contractor minimum wage can add a third floor to check on some contracts.

Fringe benefits work differently than people expect

Like Davis-Bacon, Hawaii's prevailing wage is a base rate plus a fringe benefit component, and the fringe piece can be satisfied through bona fide benefit plans rather than straight cash. The same documentation discipline that federal certified payroll requires applies here, and the state's own Chapter 104 guidelines and memoranda are where the fringe questions get answered in writing. An ad hoc benefit that doesn't meet the bona fide test doesn't count toward the fringe requirement, federal or state.

What this means for your estimate, not just your payroll

The place this actually costs money is at bid time, not payroll time. If your estimator prices labor off a blanket internal rate instead of the real, per-craft, take-the-higher-of-two floor, you can underprice a bid on classifications where the state or federal rate is higher than what you assumed, and then be contractually stuck paying the real rate on a job you priced wrong. The wage floor needs to be checked at the estimate, not discovered at payroll.

Building this in, not bolting it on

Groundwork resolves prevailing wage per craft against both the DLIR schedule and Davis-Bacon wage determinations, takes the higher of the two automatically, and uses the same resolved number in the estimate QA gate and the certified payroll run, so the number you bid and the number you pay are checked against the same source, not two spreadsheets that can quietly drift apart. See the product overview for the shape of it, Look up Hawaii prevailing wage rates for the lookup itself, and Generate certified payroll for the weekly run.

Sources

Primary, public references for the rules described above. Check them against your own contract before you act on any of this.

  1. Prevailing Wages on Public Works, HRS Chapter 104 (State of Hawaii, Wage Standards Division)https://labor.hawaii.gov/wsd/prevailing-wages-on-public-works/
  2. Chapter 104 Guidelines and Memoranda (State of Hawaii, Wage Standards Division)https://labor.hawaii.gov/wsd/guidelines/
  3. Davis-Bacon Wage Determinations (SAM.gov)https://sam.gov/content/wage-determinations
#hawaii#prevailing wage#dlir#certified payroll
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