Subcontractor Labor & Wage Information and Compliance

Subcontractor Labor & Wage Information and Compliance

Learn more about how to succeed as a subcontractor on the Brent Spence Bridge Corridor Project.

The $3.6 billion infrastructure investment in the Brent Spence Bridge Corridor (BSBC) Project creates a historic opportunity to build a career or grow a small company in Greater Cincinnati. The project team is committed to helping individuals and small businesses benefit from this once-in-a-lifetime opportunity.

As a federally-funded project, the Brent Spence Bridge Corridor (BSBC) project strictly adheres to all federal requirements for transportation and infrastructure construction, including compliance with the federal prevailing wage. In addition to being the right thing to do, compliance ensures the project is constructed and maintained by the highest quality of labor reasonably available, and that everyone working on the project is compensated appropriately for the tremendous value of their services.

Please note that even though this is a bistate project, work done will be compensated at the same federally-determined rate regardless of the state in which it’s performed. The rate will be added to this page when it’s available.

This page provides links and resources needed to be successful on this project. Be sure to check back periodically as the project moves into the construction phase. More information will be added as it becomes available.

Federal Prevailing Wage and DBE Compliance Checklist

Where do I start?

  • First, you’ll need a “My ODOT” account. This is needed regardless of the state in which your business is based or the state in which you’ll be doing work. You can create that here.
  • Keep in mind that payrolls will be submitted to AASHTOWare Project, Civil Rights and Labor (CRL). Here is more information about this process.
  • Training Modules for CRL payroll submission can be found on the AASHTOWare website once you’ve registered.
  • You can find the FAQ for this process here.

Prevailing Wage

All contractors and subcontractors must comply with State and Federal employment laws including Fair Labor Standards Act and Davis-Bacon and Related Acts.

Project Bulletin Board for Posters/Notices

Prime contractors working on the BSBC Project must post all required state and federal posters on the jobsite in an area easily seen by all workers, including subcontractors. You can download these posters here.

  • Be sure these posters are displayed before work begins on your project.
  • Posters must be large enough to be easily readable and placed in high-visibility areas that workers will typically be in before, during, and after work shifts.
  • For jobsites with multiple locations, mount posters on a portable poster board to make sure workers have access no matter where they are working, such as foreman, supervisor or employee vehicles, or in an offsite job trailer.
  • Poster placement will be verified by BSBC compliance officers.
  • In addition to the posters, a current wage determination and the contractor’s Equal Employment Opportunity (EEO) officer’s name and contact information (cell and email) must be posted in the same easily accessible and visible area.

Equal Employment Opportunity (EEO) Requirement

  • Contractors must comply with the nondiscrimination requirements provided in their BSBC contract.  
  • Contractors will permit interviews of employees and owner-operators on the project.

Federal Wage Requirements

  • Workers employed on the BSBC project must be paid at or above the specified prevailing wage rates for the type of work performed.
  • Workers must be paid overtime for all hours worked above a 40-hour work week. Violations may subject the contractor to state and federal penalties.
  • The contractor must pay for workers’ applicable lodging and travel according to the criteria in Federal Regulation 29 CFR3.5(j) and 29 CFR 5.29(f).
  • Contractors violating labor requirements are subject to a penalty to be paid in addition to any wage underpayments. Liquidated damages may also apply.

Payroll Requirements

  • Certified payrolls must be submitted through AASHTOWare Project, Civil Rights and Labor (CRL)
  • Make sure all labor compliance documents are accurate and include the correct contract number before you submit them.
  • Certified payrolls must be submitted weekly. The first payroll is due two weeks after the first day of work and submitted weekly from that point forward.
  • Contractor payroll records must be preserved for three years after the final project payout.
  • Further instruction on payroll submittal can be found here.


  • A valid apprentice certificate must accompany the certified payroll for all apprentices working that week.

Disadvantaged Business Enterprise (DBE) 

  • All DBEs must perform a commercially useful function in order for them to count toward contract participation requirements.
  • Contractors must make sure the listed DBE performs the work that is specified in their subcontract agreement.
  • A DBE’s certified status will not determine whether the DBE is performing a commercially useful function.