Cash-in-lieu of fringe benefits calculator

Cash in lieu of fringe benefits is the part of a prevailing wage determination's fringe rate that your bona fide plan does not cover, paid straight to the worker instead of into the plan. On the federal Form WH-347, column 6C is titled "payment in lieu of fringe benefits" and asks for the total amount in cash provided in lieu of fringe benefits during the workweek. California's version of the same idea runs through Labor Code section 1773.1: employer payments to a plan are a credit against the fringe portion of the prevailing rate, and whatever the credit does not reach still has to be paid, in cash, to make up the rate. Enter your numbers below to find that figure.

The calculator

Two numbers drive this: the fringe rate the wage determination requires per hour, and the hourly credit your plan actually earns. The hourly credit is your plan cost for the period divided by the hours it covers. California requires that credit to be computed on an annualized basis whenever an employer's public works payments for a benefit are higher than what it pays for the same benefit on private construction, unless one of a short list of exceptions applies, under Labor Code section 1773.1(e), and any director-issued exemption from that annualization requirement was revoked effective January 1, 2026, under 1773.1(f). Federal Davis-Bacon rules reach the same annualization approach in the Department of Labor's compliance principles under 29 CFR 5.25(c). Whatever is left of the fringe rate after that credit is the cash in lieu owed on the check.

Cash in lieu owed, per hour $8.00 plan credit is $6.00 an hour, against a required $14.00

Total cash in lieu for the period: $1,200.00, that hourly figure multiplied by the hours entered above. If your plan cost divided by hours already meets or beats the fringe rate, cash in lieu is $0. A plan that costs more per hour than the fringe rate still only earns a credit up to the rate; the extra is not owed back to you and it is not required, it is simply not needed to meet the obligation.

Worked example, at these defaults

A determination sets the fringe rate at $14.00 an hour. A contractor pays $900 into a bona fide health plan for a worker over a 150 hour period. Divide $900 by 150 hours and the plan earns a $6.00 hourly credit. Subtract that from the $14.00 required and $8.00 an hour has not been covered by the plan. Over the 150 hour period, that is $1,200 that has to reach the worker in cash, on top of the base hourly rate, to bring the total up to what the determination requires. Pay nothing into a plan at all, and the full $14.00 an hour becomes cash in lieu, which both federal Davis-Bacon rules and California's Labor Code 1773.1 allow: the whole rate, base plus fringe, may be paid entirely as cash wages.

Where cash in lieu shows up on the filing

The two systems place this figure differently, and getting the placement wrong is its own kind of error. On the federal WH-347, cash in lieu is its own column, 6C, separate from the straight hourly rate in 6A and the plan credit in 6B. California's DIR eCPR does not carry a matching separate field. Per DIR's own eCPR FAQ, "if you pay them directly to the worker, then yes, you should include them in the hourly wage; however, if you pay any fringe benefit into a fund or to a committee, then you should not include it in the hourly wage paid, but indicate it in the contribution section." Cash in lieu, in other words, gets folded into the hourly base wage on the eCPR rather than broken out. Deductions, contributions, and payments on the eCPR are reported by the hour, but not every field follows that rule; net wages paid, for example, is still keyed to the week, one of several format differences covered in our California certified payroll guide. Our guide to the WH-347, line by line, and the fuller worked example in the fringe benefit statement guide, cover the rest of both forms.

What counts as a bona fide plan in the first place

The credit only exists for a real plan. California's list of qualifying employer payments, in Labor Code 1773.1(a), covers health and welfare, pension, vacation, travel, subsistence, apprenticeship or other training programs (see our guide to CAC training fund contributions), and administrative or industry advancement funds tied to a collective bargaining agreement. The definitions at Title 8 of the California Code of Regulations, section 16000, describe a qualifying plan as a rate of contribution irrevocably made to a trustee or third person, or the reasonably anticipated cost of a written, financially responsible unfunded plan, and the same regulation lists "vacations and holidays with pay, or cash payments in lieu thereof" among the benefit categories the prevailing rate is built from. A payment a law already requires you to make, workers' compensation or Social Security among them, does not qualify for the credit on either side. California's Labor Code section 1773.1(c) states that credit shall not be granted for benefits required to be provided by other state or federal law, and the federal rule at 29 CFR 5.29(f) excludes any fringe benefit a contractor is obligated to provide under other Federal, State, or local law, naming payment for workers' compensation insurance as its example. Contributions do not have to land in the same pay period as the wages; Labor Code section 1773.1(d) only requires that they be made regularly, on no less than a quarterly basis, to keep counting toward the credit.

Questions

What is cash in lieu of fringe benefits?
It is the part of a prevailing wage determination's fringe rate that a worker is paid in cash on the check rather than through an employer contribution to a bona fide benefit plan. On the federal WH-347 it is column 6C, "payment in lieu of fringe benefits." California's Labor Code 1773.1 reaches the same result through the employer payment credit: whatever the credit does not cover still has to reach the worker in cash.
How do I calculate cash in lieu of fringe benefits?
Divide your bona fide plan's cost for the period by the hours it covers to get an hourly credit. Subtract that credit from the fringe rate the wage determination requires. What is left, if anything, is the cash in lieu owed per hour, and multiplying it by hours worked gives the total for the period. The calculator on this page does that math.
Can a contractor pay the entire prevailing wage rate in cash, with no plan at all?
Yes. Federal Davis-Bacon rules allow the total determination rate, base plus fringe, to be paid entirely as cash wages, and California's Labor Code 1773.1 treats employer payments to a plan as an optional credit rather than a mandatory one. Choosing to pay it all in cash does not change what the worker is owed in total, only how it is labeled on the filing.
Does cash in lieu of fringe benefits count toward the prevailing wage rate?
Yes, it has to. The fringe portion of the determination is not optional; it is met either through a bona fide plan credit, cash in lieu, or a combination of both. A worker's total hourly pay, cash wages plus any plan credit, still has to reach the full rate the determination sets.
How is cash in lieu of fringe benefits reported on California's eCPR versus the WH-347?
Differently. The WH-347 breaks it out as its own column, 6C, apart from the straight hourly rate and the plan credit. DIR's eCPR FAQ states that a fringe benefit paid directly to the worker should be included in the hourly wage rather than reported as a separate contribution, so cash in lieu is folded into the hourly base rate field on the California filing instead of standing on its own line.
What if my plan contribution is less than the required fringe rate?
The plan only earns a credit for what it actually costs per hour. Whatever remains of the determination's fringe rate after that credit still has to reach the worker in cash to bring the total up to the required rate.
What if my plan contribution is more than the fringe rate requires?
The credit tops out at the fringe rate the determination requires. An employer payment above that is not clawed back and is not treated as an underpayment elsewhere; it simply is not needed to satisfy the fringe obligation, and the cash-in-lieu figure for that hour is $0.
Does cash in lieu need to be annualized the way a plan credit does?
The annualization rule under 29 CFR 5.25(c), described in the Department of Labor's Davis-Bacon compliance principles, applies to converting a plan's cost into an hourly credit, not to cash itself. Cash in lieu is already a straight per-hour or per-period dollar figure, so there is no conversion to make; it is simply the shortfall between the required fringe rate and whatever hourly credit the plan earns.

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