Abstract: Based on the supposition that the interface between sandwich and the pavement slab is smooth, the "element stiffness matrix" for sandwich is derived, and the structural stiffness equations for analysis of twin-layered rigid pavement slabs with sandwich are established, thus a complete FEM for this type of pavement is presented. Calculation results are also presented. Theoretical and practical problems such as the convergence of this method, the influence of sandwich parameters on the stress of slabs and some other problems on the basis of these results are discussed.