WH-347 Certified Payroll Software for Davis-Bacon Public-Works Contractors.

Form WH-347 is the U.S. Department of Labor’s optional but widely accepted format for the weekly certified payroll required of contractors and subcontractors performing work on federally-funded and federally-assisted construction projects covered by the Davis-Bacon Act and the Davis-Bacon Related Acts. The form is the visible expression of an underlying regulatory obligation: under 29 CFR 5.5(a)(3), every covered contractor must submit, once a week for each week any covered work is performed, a payroll listing each laborer and mechanic, together with a signed Statement of Compliance.

The reporting trigger is contract-level. Davis-Bacon applies to federal and federally-assisted construction contracts in excess of $2,000. Once that threshold is crossed, every prime and every tier of subcontractor working on that contract must produce a certified payroll for each work week, regardless of how many employees they have on the job or how few hours of covered work were performed that week.

The body of WH-347 is one row per employee per week. Each row identifies the worker, the work classification taken from the applicable wage determination, the hours worked by day, the total hours, the prevailing-wage hourly rate, the fringe amount and how it is being satisfied (cash versus bona fide plan contribution), gross wages earned on the project, statutory and voluntary deductions, and net pay. Apprentices and trainees registered in approved programs are identified and tied to a ratio against journeymen in the same craft.

The reverse side — the Statement of Compliance — is the legally binding certification. The authorized signer attests that the payroll is correct and complete, that the classifications and wage rates contained in the report are not less than the applicable rates contained in the wage determination incorporated into the contract, and that any fringe benefits have been or will be paid for the period covered. That signature is what makes WH-347 a document with False Claims Act consequences if it is falsified.

The form is procedural. The regime around it is not. WH-347 lives at the intersection of the Davis-Bacon Act, the Davis-Bacon Related Acts that extend prevailing-wage obligations to federally-assisted construction (highway, transit, water, airport, housing, school construction funded in whole or in part by federal money), and the contracting agency’s own audit posture. The prime contractor is responsible not only for its own weekly certified payroll but for collecting and submitting the certified payrolls of every subcontractor on the job, at every tier, and for flagging discrepancies before the package reaches the contracting officer. That collection burden — chasing subs for signed PDFs, reconciling classifications across crews that share workers between projects — is where most public-works compliance teams spend their week.

The headline penalty is debarment. Under the Davis-Bacon Act and 29 CFR 5.12, contractors and the responsible officers of those contractors who are found by the Secretary of Labor to have disregarded their obligations to employees or subcontractors may be placed on the federal debarment list, ineligible for the award of any federal contract for a period of up to three years. Debarment is not limited to the offending contract — it follows the company and the identified individuals across every federal solicitation while it is in force.

Back-wage liability is the everyday exposure. Where the Department of Labor’s Wage and Hour Division finds a covered worker was paid below the determined rate, the contractor is liable for the underpayment plus, where applicable, fringe shortfalls and liquidated damages. The contracting agency may withhold accrued payments from the contract — sometimes from later contracts of the same prime — to satisfy the back-wage computation. Cash flow on the current project takes the hit immediately, before any appeal is resolved.

Contract withholding is also a routine administrative tool short of debarment. A contracting officer who has reason to believe a violation has occurred can withhold so much of the accrued payments as may be considered necessary to pay affected workers. Weekly certified payrolls that are late, inconsistent, or unsigned are the most common trigger for that hold being imposed.

And because the Statement of Compliance is a sworn certification submitted in support of payment on a federal contract, false or materially incomplete certifications expose the contractor and the signer to civil liability under the False Claims Act. The exposure is not theoretical — certified-payroll falsification cases are a recurring category of DOL referrals to the Department of Justice.

Reputation cost compounds the regulatory cost. A debarment listing is public. A back-wage finding on a federal job is discoverable in the next prequalification questionnaire, where many agencies ask whether the bidder has been the subject of a Davis-Bacon investigation in the last three to five years. A contractor that runs clean certified payroll for years can lose the ability to bid the work that pays the most because of a single year of sloppy WH-347 submissions. Treating the weekly form as paperwork — rather than as the gating control on whether the company can continue to be in the federal market — is the underlying mistake that the exposure punishes.