Certified Payroll and the WH-347, Explained
When Davis-Bacon certified payroll is required, what goes on each line of Form WH-347, and how prevailing wage, fringes, and the statement of compliance work.
When certified payroll is required
If you work on a federally funded or federally assisted construction project over $2,000, the Davis-Bacon Act requires you to pay laborers and mechanics the local prevailing wage and to submit a weekly certified payroll report. Many states have their own "little Davis-Bacon" prevailing-wage laws that apply the same idea to state-funded work.
What the WH-347 is
Form WH-347 is the U.S. Department of Labor's standard certified-payroll form. You submit one every week that covered work is performed. The form's format is optional, but the information it collects is mandatory, and the contracting agency may require a signed statement even for a week with no covered work.
What goes on each line
- Each worker's name and an individual identifying number (the last four of the SSN on the submitted form; full details stay in your own records).
- Work classification — the trade that sets the prevailing rate (Electrician, Laborer Group 1, and so on). A worker in two classifications in one week is split across two lines.
- Hours worked each day and in total, straight time and overtime.
- The base rate of pay and, separately, the fringe-benefit rate.
- Gross earned, deductions, and net paid.
The fringe-benefits question
Prevailing wage is a base hourly rate plus a fringe-benefit amount. You can satisfy the fringe portion by paying into bona fide benefit plans — health, pension, vacation — or by paying the fringe amount as additional cash wages. The WH-347 asks you to indicate which you did.
The statement of compliance
Page two of the WH-347 is the statement of compliance, signed by an owner or company officer. Signing it certifies under penalty of perjury that everyone was paid at least the prevailing rate, that no unauthorized deductions were taken, and that the classifications are correct. Falsifying it is a federal offense, so accuracy on classifications and fringe math is not optional.
Common mistakes
- Wrong or missing work classification for the labor actually performed.
- Fringe benefits left out, or double-counted.
- Overtime not paid at the correct rate on hours over 40.
- Missing weeks — the report is weekly and consecutive while covered work continues.
- Apprentices billed at journey rates without a registered apprenticeship program.