Workers Comp Audit Guide 2026: Class Codes, Payroll Tie, and Premium Control
Prep Checklist
- Payroll register = 941 = GL by class — see Payroll Year-End.
- Class codes by duties, not titles; split multi-duty with time logs.
- Officer elections filed; sub COIs current.
- Overtime separated where state allows.
- Multi-state payroll IDs current — see Multi-State.
Pair with Payroll Guide, 1099 vs W-2, Compliance Checklist, and Insurance.
Common Overcharges
| Finding | Fix |
|---|---|
| Clerical in shop rate | Time-split memo + descriptions |
| Uninsured sub charged | Collect COI or back-charge contractually |
| Overtime included | Separate where allowed with payroll proof |
| Officer mis-included | Election form + payroll proof |
Retain packet per Record Retention and PBC.
Worked Example: $900k Payroll, Wrong Codes
| Class | Payroll | Rate/100 | Premium |
|---|---|---|---|
| Clerical 8810 (correct for 6 office staff, $420k) | $420,000 | $0.35 | $1,470 |
| Plumbing 5183 (correct for 8 field staff, $480k) | $480,000 | $4.20 | $20,160 |
| Correct total | $900,000 | $21,630 | |
| If all $900k mis-coded to 5183 | $900,000 | $4.20 | $37,800 |
One code error costs $16,170 — 75% overcharge — before experience mod. The auditor won’t find this for you; the broker might, but only if you send payroll split by duties before the audit. Multi-duty employees (estimator who also runs jobsites) need time-split logs; without them, the higher-rated code applies to all hours.
Subcontractor Certificates: The Other Leak
Uninsured subs get charged to your policy at the sub’s trade rate. A $200k uninsured framing sub at ~$9/100 adds $18,000 to your bill. Controls that work:
- No first payment without COI. Collect workers-comp (and GL) certificates before work starts, not at audit. Calendar expiry — a COI that lapsed mid-job leaves that period’s payments chargeable.
- Contractual back-charge. Prime contracts should let you back-charge premium for uninsured subs; without the clause, you absorb it.
- 1099 cross-check. Every 1099 over $600 for trade labor without a matching COI is audit exposure — reconcile the vendor file quarterly — see 1099 vs W-2.
Officer Inclusion Rules (State Traps)
| Situation | Typical treatment |
|---|---|
| Corp officers in most states | Included up to payroll cap; formal opt-out with ownership threshold |
| LLC members | Excluded in many states, included in others — confirm per state |
| Sole proprietors/partners | Excluded unless electing coverage |
| Multi-state officers | Rules follow work state — see Multi-State |
File elections before the policy year starts; mid-year changes invite disputes. Include officer payroll correctly in the Payroll Year-End tie-out so comp and comp-audit agree.
FAQ
When should we start prep?
60 days before renewal with preliminary tie-out; scrub class codes quarterly.
Who owns it?
Payroll + controller with broker review; no HR-only file.
Next Steps
- Tie payroll to 941s this month.
- Scrub class codes and sub COIs.
- Calendar audit with broker dry run.