The WH-347 certified payroll form: a practical guide

Land work on a federally funded project — a VA hospital, a public school with federal money, an airport — and your subcontract will require “certified payroll.” For most contractors that means the U.S. Department of Labor’s Form WH-347, submitted weekly for every week you have workers on the job. This guide covers what the form is, how to complete it, and where subs get tripped up.

Where the requirement comes from

The Davis-Bacon Act and the many “Davis-Bacon Related Acts” require contractors and subcontractors on covered federal and federally assisted construction contracts to pay laborers and mechanics at least the locally prevailing wages and fringe benefits listed in the contract’s wage determination. To prove compliance, covered contractors must submit a weekly payroll record along with a signed Statement of Compliance.

A detail worth knowing: use of the WH-347 form itself is optional — what’s mandatory is submitting the required payroll information and the signed Statement of Compliance weekly. In practice nearly everyone uses the WH-347 (or a software-generated equivalent) because it’s the format agencies expect. Note also that many states have their own “little Davis-Bacon” prevailing-wage laws with state-specific forms or electronic filing systems (California’s DIR eCPR is a prominent example) — a state job may not use the WH-347 at all, even though the data is largely the same.

Who files, and to whom

Every contractor and subcontractor with covered workers on the site files — subs don’t get to rely on the prime’s payroll. Submissions flow up the chain: subs submit to the prime (or the sub above them), and the prime submits the package to the contracting agency. Payrolls are due within seven days after the regular pay date for the pay period. Payrolls are numbered sequentially for the project (Payroll No. 1, 2, 3…), weeks with no covered work are typically reported as “no work” payrolls or noted per the agency’s practice, and the last one is marked “Final.”

The form, column by column

The header asks for your firm, address, payroll number, week ending date, project name, and project/contract number. Then, for each worker:

• Column 1 — Name and identifying number. Full name plus an identifying number, customarily the last four digits of the Social Security number. Do not put full SSNs or home addresses on the submitted form — payrolls can be subject to disclosure.
• Column 2 — Number of withholding exemptions. Optional; a payroll-convenience column, not a Davis-Bacon requirement.
• Column 3 — Work classification. The classification from the contract’s wage determination that matches what the worker actually did — e.g. “Floor Layer” or “Laborer, Group 1.” A worker performing work in two classifications can be split across rows with hours and rates for each, if your records support the split.
• Column 4 — Day and date / hours worked. Hours per day for the week, split into overtime (“O”) and straight time (“S”) rows.
• Column 5 — Total hours.
• Column 6 — Rate of pay, including fringe benefits. The straight-time rate, and where fringes are paid in cash, shown so the cash-fringe portion is identifiable (the customary notation is base rate plus fringe, e.g. “$28.50/$6.75”). Overtime is at least time-and-a-half the basic rate of pay after 40 hours in a workweek, per the Contract Work Hours and Safety Standards Act.
• Column 7 — Gross amount earned. Where the worker also worked on non-covered projects that week, the customary practice is showing gross on this project over gross for the week (e.g. “$1,140.00/$1,520.00”).
• Column 8 — Deductions. Taxes, FICA, and any other deductions; other deductions must be explained (and some require worker authorization or DOL approval).
• Column 9 — Net wages paid for week.

The Statement of Compliance — the part with teeth

Page 2 of the WH-347 is a signed certification by the contractor or an authorized officer stating, among other things, that the payroll is correct and complete, that each worker was paid not less than the applicable prevailing rate for the classification of work performed, and that no impermissible deductions or rebates (“kickbacks”) were taken. Section 4 is where you certify how fringe benefits were satisfied: 4(a) paid into approved plans, funds, or programs; 4(b) paid in cash; 4(c) exceptions/combination, with an explanation.

This signature is a federal certification. Falsification can expose the signer to civil and criminal penalties, and to debarment from federal work. That’s why the person signing should be someone who can actually stand behind the numbers — and why the underlying time records need to be real daily records, not a reconstruction on Friday.

Common mistakes that get subs flagged

1. Wrong classification. Paying a “laborer” rate for work the wage determination classifies at a higher trade rate. Classification follows the work performed, not the job title.
2. Fringe handling errors. Claiming 4(a) without a bona-fide plan, or paying cash fringes but not showing them in the rate columns.
3. Overtime computed on the wrong base. The premium is calculated on the basic hourly rate — mishandling the fringe component is a classic finding.
4. Missing weeks or broken numbering. Gaps in the sequential payroll numbers invite questions; skipped weeks should be accounted for.
5. Splitting a worker’s week without records. Split-classification reporting is fine only if daily records support it; otherwise the whole time is owed at the higher rate.
6. Late submission. Agencies and primes can withhold progress payments while certified payrolls are outstanding — which turns a paperwork lag directly into a cash-flow problem, because your pay application sits unpaid behind it.

Recordkeeping

Keep the underlying payroll records and related documents during the work and for at least three years after project completion — timecards, fringe plan documentation, apprentice registrations (apprentices may be paid below journeyman rates only when properly registered in an approved program and within ratio), and copies of every submitted payroll and Statement of Compliance. If DOL or the contracting agency audits the job, these records are your defense.

Practical advice for the office

Certified payroll is a weekly, deadline-driven byproduct of data you already have — who worked, where, doing what, at what rate. The painful version is re-keying that from your payroll system into the form every week per project. The sane version is a system where crews and classifications are set up once per project and each week’s report is generated, numbered, and archived automatically — with the pay applications for the same project alongside, since GCs on prevailing-wage work usually want both in the same package. However you produce it, treat the weekly cadence as non-negotiable: on prevailing-wage jobs, payroll paperwork and progress payments are chained together.