i think it's good to reitterate jgailla's point in a different way...high compaction in the upper couple of feet likely won't make a flip when you look at the bigger picture. however, if you have 40 feet of highly compacted fill, then that is a different story (but often is not very practical to put in such a large amount of material to higher compaction requirements due to the added difficulties, extended schedule, potentially limited amount of materials able to use, in-situ moistures, etc etc). it all depends on the loads you're dealing with, the depth of fill, the area of loading, settlement criteria, materials being used for fill, and a few other factors. consult an experienced local geotech to discuss job specifics.