WH-347: filling in the form without inviting a finding

Form WH-347 is the payroll form published by the United States Department of Labor for submitting certified payroll on covered construction contracts. Using this particular form is optional — a contractor may submit its own format — but the information it asks for is not, and neither is the statement of compliance printed on its reverse. In practice most contractors use it because a familiar layout is one fewer thing for a reviewer to object to.

The form is two pages doing two different jobs. The front is the payroll: a row per worker, classifications, hours by day, rates and deductions. The back is a certification signed by a responsible person, asserting that the payroll is complete and correct, that everyone was paid at least the applicable rate, and that no improper deductions were made.

The WH-347 fields that generate findings

• Hours worked on this project only. Putting a worker’s full week in the daily boxes when half of it was on another job is the most common single error, and it makes the gross column disagree with everything else.
• Classification, matching the wage determination for the work actually performed. "General labourer" for skilled work is a finding waiting to be made.
• The fringe columns: showing whether fringes are paid into a plan or in cash, and getting the total up to base plus fringe either way.
• Deductions: itemised, with anything unusual explained. Deductions that reduce pay below the required rate are not permitted.
• Apprentice rates, which are a percentage of the journeyworker rate and require a registered programme — an unregistered "apprentice" is paid the full rate.
• The payroll number and the week ending date, sequential and without gaps. Missing weeks are noticed.
• The signature on the statement of compliance, by someone authorised to give it.

Number every payroll, including the ones with no work

Payrolls are numbered sequentially for the project, and the sequence is what a reviewer scans first. Where no work was performed in a week, the usual practice is either to submit a no-work payroll or to note the gap on the next submission, so that the numbering reads as continuous. A sequence jumping from 6 to 9 invites a request for 7 and 8, which is an avoidable exchange when nobody was on site.

Do not backdate or re-sign an amended payroll as if it were the original. Where an error is found, submit a corrected payroll identified as a correction, with the reason. A corrected submission is routine; a rewritten history is a different category of problem.

State portals often override the federal form

Several states run their own electronic certified payroll systems for state-funded work, with their own formats, their own submission deadlines and their own definitions of what counts as filed. California’s system is the most commonly encountered, and contractors working across state lines routinely discover that a correctly completed federal form does not satisfy a state portal. Check which regime applies per project before the first payroll, not after the first rejection.

Producing and keeping the form

The practical shape is a working spreadsheet feeding a filled form each week, with the submitted copies filed against the project. Ettex Sheets holds the weekly payroll with classifications and split hours calculated rather than transcribed, Ettex PDF fills and flattens the form for submission, and Ettex Records keeps the submitted payrolls in sequence per project alongside the wage determination — the file described in certified payroll.

Plainly: this is a form and a filing system, not payroll software, and not legal advice. The current version of the form and its instructions come from the Department of Labor, and the requirements that apply to a specific contract come from the contract and the agency.