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The 21 things a reviewer looks at on your WH-347.
Walk your form against this list before you submit it. Every item comes straight from the Department of Labor instructions for the revised form. Your answers are not sent to me and there is nothing to sign up for.
The form changed in January 2025. The withholding exemptions column is gone. There is a new Wage Determination number field, a Worker Entry number, a Journeyworker and Registered Apprentice column, and fringe benefits now have their own columns, 6B and 6C.
The straight time and overtime rows also swapped places in column 4. If your process was built on the old layout, that is the first thing to check.
Page 1, the header
Every wage determination that applied is listed, with its revision number
One number is not enough if more than one determination covered the work in this pay period.
The revised form added a Wage Determination number field. The instructions say to list the wage determination numbers and revision numbers included in the contract that are relevant to this payroll, and if several applied to the work in this period, list them all. A missing revision number is a common bounce because the reviewer cannot confirm which rate sheet you priced against.
Source: DOL instructions, Wage Determination No.
The payroll number is sequential and starts at 1
Number 1 is the first week of your work on the project, not the first week of the contract.
Each weekly certified payroll a contractor or subcontractor submits for a project gets a number, beginning at 1. Gaps and repeats are the fastest way to get a whole batch questioned, because the reviewer reads a gap as a missing week.
Source: DOL instructions, Certified Payroll No.
The project location names at least the county and the state
A street address is fine. A job name on its own is not.
Enter the complete address of the project, or if there is no specific address, a description of the location that includes at a minimum the county or counties and the state. County matters because the wage determination is county specific.
Source: DOL instructions, Project Location
Prime or subcontractor box is marked, and the final payroll box is marked if this is your last week
Two checkboxes, both easy to skip, both noticed.
Mark the box that says whether you are the prime or a subcontractor on this project. Mark the final box only on the submission covering the last week of your work on the job. Agencies use that box to close your file out, so an unmarked final week leaves the file open and the reminders coming.
Source: DOL instructions, check boxes
Page 1, the workers
No full Social Security numbers anywhere on the form
Last four digits, or any number specific to that worker.
Column 1E takes an individual identifying number, for example the last four digits of the worker's Social Security number or any other number unique to that person. Full Social Security numbers must not be included. This is one of the few items a reviewer will bounce on sight without reading anything else.
Source: DOL instructions, Column 1E
Column 2 says J or RA for every worker, and apprentices carry their level of progression
New column on the revised form. Blank is not an option.
Enter J for a journeyworker or RA for a registered apprentice in a program approved by the DOL Office of Apprenticeship or a State Apprenticeship Agency. For registered apprentices, also list their level of progression within the approved program. An apprentice rate paid to someone who is not in a registered program is not an apprentice rate, it is underpayment.
Source: DOL instructions, Column 2
The classification in column 3 describes the work actually performed, not the job title
This is the single most expensive line on the form.
List the labor classification for the work actually performed by each worker. Classifications come from the wage determination in the contract. If the determination has no classification for work someone performed, do not pick the closest one, contact the contracting officer immediately. That path ends in a conformance request, not a guess.
Source: DOL instructions, Column 3
A worker who worked two classifications has two rows and one worker entry number
Same person, same entry number in column 1A, separate row per classification.
If a worker works in more than one labor classification during the week, show the hours in each classification on separate rows, and use the same worker entry number on every row belonging to that person. And here is the sting: if you did not keep an accurate breakdown of the hours by classification, the worker must be paid for all hours at the highest applicable rate, base and fringe.
Source: DOL instructions, Column 1A and Column 3
Page 1, the hours and money
Column 4 carries the day letters across the top and the dates on the row below
Your workweek, whatever days it runs, not a default Monday start.
Enter the first letter of each day of your workweek across the top row and the matching date underneath. If your week runs Tuesday to Monday, it starts with T. Straight time and overtime go in the marked rows, and on the revised form those two rows swapped places compared with the old one.
Source: DOL instructions, Column 4
Hours over 40 in the week are recorded as overtime, including hours worked off this site
The 40 hour count is the whole week, not just this job.
On contracts covered by the Contract Work Hours and Safety Standards Act, hours worked in excess of 40 total in the week are overtime, including hours worked on and off the site of the covered work. Splitting a 50 hour week across two jobs does not make either of them a 40 hour week.
Source: DOL instructions, Column 4
Column 5 equals the sum of the daily hours in column 4
Pure arithmetic. Caught on sight, every time.
Column 5 is the total of the hours entered in column 4. When the total disagrees with the days, the reviewer stops reading and returns the form, because the mismatch means one of the two is wrong and they cannot tell which.
Source: DOL instructions, Column 5
Column 6A holds the actual rate paid, with no cash fringe folded into it
Changed on the revised form. This is where old habits break.
Column 6A takes the actual hourly rate paid for straight time and for overtime, for the classification in column 3. Do not include cash payments in lieu of fringe benefits in this column. On the old form people routinely wrote the base and the cash fringe together as one number. On the revised form that number belongs in column 6C instead.
Source: DOL instructions, Column 6A
Column 6B equals hours worked times the hourly fringe credit shown on page 2
The two pages have to agree, and they are the pages nobody reads together.
Column 6B is the total fringe benefit credit for contributions to, or reasonably anticipated costs of, bona fide plans. It should equal the worker's total hours for the period multiplied by the total hourly credit listed under Hourly Credit for Fringe Benefits on page 2. If page 2 says a number and column 6B does not multiply out to it, one of them is wrong.
Source: DOL instructions, Column 6B
Column 6C equals hours worked times the cash in lieu rate
Cash instead of a plan goes here, not in 6A.
Column 6C takes the total cash provided in lieu of fringe benefits for the workweek, which should equal total hours multiplied by the hourly cash in lieu rate. If you meet the fringe obligation partly by a plan and partly by cash, the plan side goes in 6B and on page 2, the cash side goes in 6C.
Source: DOL instructions, Column 6C
If any of the week's pay came from other work, column 7B shows the gross for all work
7A is this project. 7B is everything.
Column 7A is the gross earned for hours on this federally funded project. If part of the weekly wage was earned on other projects, including projects with no Davis-Bacon coverage, column 7B carries the total gross for all work that week. Leaving 7B blank when someone split their week makes the deductions in column 8 look impossible.
Source: DOL instructions, Columns 7A and 7B
Deductions in column 8 are the real ones for all work, not prorated to this job
Prorating deductions is a very common and very visible error.
Column 8 records deductions from the total gross for all work in column 7B. If the worker had other jobs that week, do not prorate, show the actual deductions from the weekly gross across all projects. All deductions must comply with the Copeland Act rules at 29 CFR part 3, and apart from those listed at 29 CFR 3.5 every deduction needs prior DOL approval.
Source: DOL instructions, Column 8
Anything lumped under Other deductions is explained or itemized
One line, explain it in Additional Remarks. More than one, attach an addendum.
If the Other deductions amount covers a single deduction, describe it under Additional Remarks on page 2. If it covers more than one, submit an addendum itemizing each one with a description and an amount. An unexplained Other column is an open question, and open questions come back.
Source: DOL instructions, Column 8
Column 9 is the net actually paid for all work, across every project
Not the net for this job. The net on the check.
Column 9 is the actual dollar amount paid to the worker for all hours worked across all projects that week, including projects with no Davis-Bacon coverage. It ties to column 7B minus the total in column 8, not to column 7A.
Source: DOL instructions, Column 9
Page 2, the Statement of Compliance
Boxes 1, 2, 3 and 6 are checked
Those four are never optional.
The instructions are explicit: boxes 1, 2, 3 and 6, meaning the first three and the last, must always be checked to certify compliance. Box 4 is the apprenticeship box and box 5 is the fringe credit box, and those two depend on your week. The four mandatory ones do not.
Source: DOL instructions, Statement of Compliance
Box 4 is either filled in with the apprenticeship program, or marked Not Applicable
Leaving it blank reads as an unanswered question.
If any worker was paid as an apprentice in the period, check box 4, list each program the apprentices are registered in, mark whether it is registered with the DOL Office of Apprenticeship or a State Apprenticeship Agency, and give the labor classification. More than three entries need an addendum. If no apprentices worked, leave the box unchecked and write Not Applicable or N/A in the entry area rather than leaving it empty.
Source: DOL instructions, Statement of Compliance box 4
The signature is a real one, and any unfunded plan credit already has DOL approval
A scan or a photocopy of a signature does not count.
The Statement of Compliance must be signed by the contractor, the subcontractor, or the agent who paid or supervised payment, with a phone number, email and date. Legally valid electronic signatures are fine. Photocopied and scanned signatures are not. Separately, if you are claiming credit for the reasonably anticipated cost of benefits you provide directly, an unfunded plan, you need prior DOL approval under 29 CFR 5.28 before claiming it. And the statement itself is subject to 18 U.S.C. 1001: a fine, up to five years, or both.
Source: DOL instructions, Statement of Compliance and signature
Every box ticked.
The form itself holds together. That is the part a list can check.
The part a list cannot check is whether the rate in column 6A actually matches the wage determination for that classification, in that county, in that revision. That is the one that gets people debarred, and it needs a person with the determination open next to the form.
Send me the form free and I will read that part
First check free. Email the PDF to nick@wh347check.com, pay nothing.
The list stops where the wage determination starts.
Everything above is arithmetic and paperwork. You can catch all of it yourself. What you cannot catch alone is a classification paid at the wrong rate, because that needs the determination read next to the form, row by row.
I read it by hand and write back with either "clean" or the row, the reason and the number it should read. You keep signing the Statement of Compliance. I never sign anything.