One project proved Empact’s model. Harvestone expanded it to four.

Background

Harvestone had two kinds of compliance work running at once. On the carbon capture project, construction was continuous and the contractor chain was known in advance, so payroll could be tracked against a defined scope. At the three ethanol facilities, Alteration and Repair (A&R) work arises on its own schedule across plants that are already operating, and the first question is always which equipment and processes are in scope and whether the work qualifies as an alteration or repair. The same prevailing wage rules applied to both, but little else about them matched.

Harvestone already had a prevailing wage methodology and third-party payroll review in place. As the scope expanded across active construction and operating facilities, it wanted closer contractor coordination and a process built for both types of work.

For both Section 45Q and Section 45Z, satisfying prevailing wage and apprenticeship requirements generally supports an increased credit amount equal to five times the base amount. Compliance gaps can put that increased amount at risk and trigger correction payments and penalties.

Problem

Determining coverage at an operating facility is rarely clean. Contractors arrive for A&R work without the contract structure or site sign-in process a construction project provides, and prevailing wage can apply to part of a worker’s week while programming, calibration and routine work falls outside it. That makes the task larger than reviewing a certified payroll report: someone has to identify who is on site, determine which work triggers prevailing wage, apply the correct wage determination and separate covered hours from other work before a documentation gap becomes a tax credit problem.

The approach

Harvestone and Empact built a single management process across the four projects, designed to catch errors before checks are issued rather than after payroll is filed. Because Empact reaches the payroll team ahead of check runs, wage and fringe-benefit errors are corrected at source instead of recovered later.

The same standard applies everywhere, but the method changes by project type. On the carbon capture build, Empact uses contractor and site information from the construction team to anticipate new participants before they arrive. At the operating plants, Empact refreshes wage determinations as scope changes and reviews mixed-scope time records. Every contractor receives a kickoff meeting and the relevant wage rate information, and the two teams review work performed and upcoming activity together each week. When a contractor does not provide complete records, Harvestone escalates directly, including whether to hold payment until the required documentation arrives.

The right classification protected the entire construction record

The most consequential issue surfaced before it spread across the carbon capture project. Without independent compliance oversight, the construction labor would have been managed under a building wage classification rather than the heavy construction classification the work required, making the payroll record incorrect across the project. Empact established the correct classification and has reviewed 50 weeks of construction, preventing a project-wide error from embedding in every payroll cycle.

Deeper review settled what a payroll summary could not

On the carbon capture project, Empact questioned fringe-benefit rates reported by a nonunion contractor and requested the underlying contribution records. The supporting records did not substantiate the fringe-benefit amounts reported on payroll. NexusIQ™ now holds fringe-benefit backup requested and reviewed for each week, giving Harvestone evidence of what workers received rather than a payroll summary alone. Across the ethanol facilities, the most common issues involve incorrect fringe-benefit calculations and incorrect reporting of travel time.

Contractor discrepancies corrected at source

The payroll discrepancies below originated with contractors. Harvestone and Empact identified each one early and worked directly with the contractor to correct it before it compounded across later payroll cycles or spread to others on the same project. Individually the amounts are small, which is the point.

One standard now covers four projects and 24 active contractors

Empact currently manages payroll from 24 contractors actively reporting hours across the four Harvestone projects, and through NexusIQ has reviewed 408 contractor-weeks, including 203 on the carbon capture project and 205 across the three ethanol facilities. Harvestone has one place to coordinate contractor requirements, payroll documentation, wage determinations, fringe-benefit support, open issues and corrective action across both construction and A&R work.

A repeatable prevailing wage model for operating clean fuel facilities

Operating facilities require a different model from a conventional construction project. A&R work is intermittent, contractors change quickly and covered hours sit beside noncovered work in the same week. Empact combines AI-native NexusIQ with managed compliance services to give Harvestone one prevailing wage record across all four projects through the lifecycle of the tax credit, and stands behind its compliance work with a financial guarantee.