HUD-11 employee interview form: what it asks and how it is checked against your payroll
This page reads the HUD-11 (03/2025 edition), HUD Handbook 1344.1 REV-3, chapter 5 (January 2023), and 29 CFR 5.5.
Last reviewed against the sources it cites
The short answer
The HUD-11 is the Record of Employee Interview, which an inspector fills in on site with one of your workers; you do not submit it. An examiner compares it to your payroll and notes differences in item 16. Handbook 5-10(L) requires a correction payroll for every noted difference, while 5-12 asks for an explanation and/or correction of an apparent underpayment. Chapter 5 does not say how the two fit, so ask the agency which it wants.
- The copy on HUD's site is the 03/2025 edition, OMB Approval No. 2501-0009, expiring 03/31/2028, and it says previous editions are obsolete.
- 29 CFR 5.5(a)(3)(iv)(A) requires you to permit authorized representatives to interview your workers during working hours on the job.
- Under Handbook paragraph 5-9(C)(5), the examiner compares the HUD-11 to the corresponding certified payroll, notes any discrepancy in field 16, and signs fields 17a and 17b.
- Handbook paragraph 5-10(L) requires a correction payroll for every discrepancy brought to the employer, while 5-12(A) has the agency note a satisfactory explanation of an apparent underpayment to the file; chapter 5 does not say how the two fit.
- Under paragraph 5-10(L), only the worker's name, the interview date and the interviewer's observations may be released to you; the worker's statements need prior written consent.
- If wage violations are not corrected within 30 days after the prime contractor is notified, paragraph 5-11(H) lets the agency withhold payments due to the contractor.
What the HUD-11 is
The HUD-11 is an inspector's record of an on-site interview with one of your workers. Its instructions say HUD and local agency staff use it, and that comparing it to your certified payroll tests whether the payroll is accurate. You do not complete or submit it.
The handbook says HUD Labor Standards Specialists (LSS) cover certain multifamily programs and local contracting agencies (LCA) handle programs such as CDBG and HOME. Whether Davis-Bacon reaches your funding is in our housing authority guide.
Which edition is current
HUD's file is Form HUD-11 (03/2025), OMB No. 2501-0009, expiring 03/31/2028, and says previous editions are obsolete. An Iowa DOT special provision (effective May 21, 2024) reproduces Appendix 2 of Iowa's 2022 CDBG Management Guide, which holds a HUD-11 dated 02/2009 and an instructions page dated 08/2004. If an agency gives you an older copy, ask which edition it uses.
What you have to do when an inspector asks
Under 29 CFR 5.5(a)(3)(iv)(A) (eCFR, current as of November 3, 2026), you must permit authorized representatives to interview workers during working hours on the job. Under (iv)(B), refusal can lead to suspended payments after written notice and may be grounds for debarment under 29 CFR 5.12.
The January 2023 handbook (5-9(C)(2)) cites this duty as 29 CFR 5.5(a)(3)(iii); the current eCFR text puts it at (a)(3)(iv)(A). Read the clause written into your contract, which may carry the older numbering.
The form calls for individual, private interviews, with every laborer and mechanic made available on request. The worker's own participation is voluntary.
Question by question: what it asks and what it is checked against
The right column is a plain reading of where each answer shows up in payroll records, not HUD's method. The form's instructions (Items 16 to 17b) compare the classification and wage rate to the wage decision, and the observed duties to the classification. Handbook chapter 5 says the HUD-11 should agree with the payroll (5-10(L)).
| Item | What it records | Where it shows up in your payroll records |
|---|---|---|
| 2a to 2d | Name, contact details, and whether ID was checked. | Name and an individually identifying number, such as the last four Social Security digits. Handbook 5-10(C) wants it on a worker's first payroll, then only to tell workers apart; 29 CFR 5.5(a)(3)(ii)(B) reads as one on every weekly payroll. Include it every week unless your agency says in writing it does not require that. |
| 3a to 4c | Time on the job, weekly hours, last day's hours, hourly rate, medical and pension, frequency of pay. | Daily and weekly hours, and rate and fringe against the wage decision. 29 CFR 5.5(a)(1)(i) requires pay at least weekly. |
| 5 to 7 | Classifications, duties, tools. The classification must name the trade, such as Carpenter, not "journeyman" or "mechanic". | The classification column. Pay follows the work actually performed, and split time must be recorded in each classification (29 CFR 5.5(a)(1)(i)). |
| 8 and 8a | Apprentice or trainee, and a copy of the certificate. | Apprentice rows. HUD's handbook (5-10(G)) wants the apprentice's registration with the first payroll listing them, plus ratio and wage schedule papers. |
| 9 and 10 | Paid for all hours, and at least time and a half over 40 in a week. | Total hours and overtime. |
| 11 | Ever threatened or coerced into giving up any part of pay. | No payroll column. It asks about kickbacks. The contract clause bars any "deduction or rebate" beyond Copeland Act deductions (29 CFR 5.5(a)(1)(i)), and your Statement of Compliance certifies pay "without rebate" (5.5(a)(3)(ii)(C)(2)). |
| 13 and 14 | Duties the interviewer observed (13). Remarks (14). | Item 13 meets the classification, as the instructions ask whether observed duties fit it. Item 14 has no payroll field. |
How the comparison works
- The interviewer records it. Per paragraph 5-9(C)(4), the interviewer notes the duties observed and whether the worker's statements fit, then signs.
- An examiner compares it to your payroll. Completed forms go to the LSS or LCA for comparison during regular reviews. The result goes in item 16, and the examiner signs items 17a and 17b.
- You explain or correct. Handbook 5-10(L) says every noted discrepancy is brought to your attention and you are required to submit a correction payroll. The undated HUD Exchange guide gives the example of a worker missing from the payroll for the interview date. For an apparent underpayment, 5-12 has the agency request an explanation and/or correction, and a satisfactory explanation is noted to the file (5-12(A)(1)). Chapter 5 does not say how 5-10(L) and 5-12 fit together, so ask the agency which it wants.
What you will and will not be told
The form says the interview and the information collected are confidential. Paragraph 5-10(L) says the worker's name, the interview date and the interviewer's observations may be released to you, but not the worker's statements without prior written consent. A note there explains that every worker must be made available for interview on site, so release reflects the interviewer's observation, not the worker's statements. Paragraph 5-9(C)(1) has interviewers tell workers their identity is disclosed only with written consent, so ask the agency what it releases.
What a mismatch leads to
From chapter 5:
| Difference | What follows |
|---|---|
| Classification or rate does not match the wage decision | Reclassify, or request an additional classification and rate (5-10(E); see our SF-1444 guide). Underpayments are repaid (5-10(F)) as hours times the rate gap, or wages earned minus wages paid (5-11(A)). |
| Overtime not paid | On projects subject to the Contract Work Hours and Safety Standards Act (CWHSSA), restitution (5-10(H)) and possibly liquidated damages: $27 a day in the handbook's 2021 example, $33 in 29 CFR 5.5(b)(2) now, so ask your agency which applies. The 5.5(b) clauses go in contracts over $100,000 subject to CWHSSA overtime. On other projects the agency should refer overtime violations to DOL under the Fair Labor Standards Act (5-10(H)). You have 60 days to ask in writing for a reduction or waiver of liquidated damages (5-13(A) and (B)). |
| Unauthorized deduction | Submit documentation of the worker's consent, and repay unauthorized or impermissible deductions (5-10(J)). |
| Unregistered or excess apprentice | Paid the wage decision rate for the work performed, with restitution (5-10(G)). |
| Payroll that hides underpayment | The handbook says monitoring is primarily focused on identifying willful violations such as falsified payrolls (5-9, opening paragraph). Falsified certifications can bring civil or criminal prosecution (29 CFR 5.5(a)(3)(ii)(F)). |
A correction payroll lists each worker repaid and the restitution paid, with a signed Statement of Compliance (5-11(E)). Where your explanation does not negate the back-wage finding and you agree to pay, the corrected payroll is due within 30 days (5-12(A)(2)(a)); 5-10(L) states no deadline. If violations stay uncorrected 30 days after the prime contractor is notified, the agency may withhold payments (5-11(H)).
Appeal rules depend on who issued the determination. For HUD's Davis-Bacon and Labor Standards staff, paragraphs 7-5 and 7-6 require a written appeal by receipted mail, received or postmarked within 30 days of the notice. For a local contracting agency, paragraphs 7-10 and 7-11 send the appeal to HUD within 30 days. Follow the notice of right to appeal in your determination.
Make your payroll match the work
- Hold apprentice papers. The regulation requires written evidence of registration, ratios and wage rates (29 CFR 5.5(a)(3)(i)(D)). HUD's handbook (5-10(G)) asks for the individual registration with the first payroll that lists the apprentice, and the ratio and wage schedule papers too.
- Do not coach or probe. 29 CFR 5.5(a)(11) makes it unlawful to threaten or discriminate against a worker for cooperating in an investigation or compliance action.
- Correct on a new payroll. The contractor signs it. See how to fill out the WH-347 and ink or e-sign on HUD jobs.
Help with your project
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Questions
Do I fill out or submit a HUD-11?
Can a worker refuse to be interviewed?
Can I see what my worker told the interviewer?
Which edition of the HUD-11 is current?
Sources
Every figure on this page links to its source where it first appears. The full list, in order:
- HUD-11 (03/2025 edition) hud.gov
- HUD Handbook 1344.1 REV-3, chapter 5 (January 2023) hud.gov
- 29 CFR 5.5 ecfr.gov
- Iowa DOT special provision ia.iowadot.gov
- HUD Exchange guide files.hudexchange.info
- paragraphs 7-5 and 7-6 hud.gov