WH-347 Certified Payroll: What Auditors Look At First

Why Certified Payroll Gets More Scrutiny in Q1 and Q2

Federal and state labor compliance audits tend to cluster in the first half of the year. Agencies close out the prior year's complaints, new Davis-Bacon wage determinations take effect, and owners who accepted federal funding start checking whether their GCs and subs submitted WH-347 forms correctly. If you have a prevailing wage job active right now, your certified payroll records are more likely to be reviewed in the next 90 days than at any other point in the project.

Knowing what auditors open first saves you time, fines, and the aggravation of reconstructing records you should have locked down at the time of submission.

What the WH-347 Form Actually Requires

The WH-347 is the U.S. Department of Labor's standard certified payroll form for federally funded construction projects covered under the Davis-Bacon Act. Every contractor and subcontractor on a covered project must submit it weekly. The form captures employee names, the last four digits of Social Security numbers, work classifications, hours worked each day, gross wages, deductions, and net pay. The Statement of Compliance on page two is signed under penalty of law.

That signed statement is not a formality. It is a federal compliance certification. Errors or omissions on the underlying data sheet make that signature a liability.

The Five Things Auditors Check First

1. Worker Classification

This is the first column auditors scan. They compare the classification listed on the WH-347 to the applicable wage determination. A worker listed as a Laborer who performed work that falls under Carpenter or Ironworker classifications triggers an immediate underpayment calculation. Misclassification, even unintentional, is the most common reason GCs receive back-wage assessments. Pull your wage determination before you classify anyone on a new project, and revisit it when scope changes add new work types.

2. Fringe Benefit Accounting

Davis-Bacon prevailing wages include a base rate plus a fringe benefit requirement. Auditors verify that fringes are paid either into a bona fide benefit plan or as cash in addition to the base rate. A common error: a contractor pays the full hourly rate but treats the fringe component as already included rather than adding it on top. If your certified payroll shows a $38.50 base but the wage determination requires $38.50 base plus $9.20 fringe, you are short $9.20 per hour per worker. On a 10-person crew over eight weeks, that adds up fast.

3. Overtime Calculation Under the Contract Work Hours and Safety Standards Act

Federal projects subject to the Contract Work Hours and Safety Standards Act require overtime to be paid at 1.5 times the basic rate of pay, not the regular rate as defined under the Fair Labor Standards Act. Auditors know the difference. Applying the wrong overtime multiplier to prevailing wage work is a separate violation from misclassification, and it can compound back-wage liability across every week of the project.

4. Submission Timeliness and Completeness

WH-347 forms must be submitted weekly, covering the prior week's payroll. Auditors pull the submission log and count gaps. Missing weeks are treated as unverified payroll, which triggers a records request. Incomplete forms, such as missing the number of daily hours or leaving the deduction columns blank, raise the same red flag. A blank cell is not evidence of no hours or no deductions; it is evidence of a careless submission.

Auditors also check that every subcontractor on the project submitted their own forms. The GC is responsible for collecting and forwarding sub WH-347s to the contracting agency. If a sub's forms are missing, the GC faces the compliance gap, not just the sub.

5. The Statement of Compliance

The second page of the WH-347 must be signed by an authorized company officer or payroll representative. Auditors verify the signature, the title, and whether the certifying person has authority to make that certification. An unsigned form or one signed by an administrative assistant who has no payroll authority is technically non-compliant. They also check the certification date against the payroll period date to confirm the form was not backdated.

Common Mistakes That Invite a Deeper Review

Most audits start as routine sampling. Auditors pull a few weeks, spot a pattern, and then expand the review. These are the patterns that cause that expansion:

• The same worker appears under different classifications in different weeks without a documented reason for the change.
• Deduction totals do not reconcile to actual payroll records when the auditor requests backup documentation.
• Apprentice ratios are out of compliance. Davis-Bacon allows apprentice wage rates only for registered apprentices in approved programs. Listing an unregistered worker at an apprentice rate is an automatic violation.
• Subcontractor submissions are inconsistent or late. If a sub's WH-347 shows different workers or hours than their daily sign-in sheets, auditors treat that as a falsification indicator.

How to Prepare Before an Auditor Asks

Keep a complete submission log for every covered project: date submitted, weeks covered, submitter name, and confirmation of receipt. Retain copies of all WH-347 forms, the applicable wage determination, apprenticeship program documentation for any apprentices, and fringe benefit plan documentation for the duration of the project plus three years. The DOL's records retention requirement under Davis-Bacon regulations is three years from project completion.

Train your payroll staff or your subs on the classification rules before the project starts, not after the first submission. A five-minute conversation about the wage determination is far cheaper than a back-wage assessment six months later.

One Final Point on Responsibility

As the GC, you own the certified payroll compliance picture on your project. When the owner or contracting agency receives a wage complaint, they call you first. Your subcontract agreements should require subs to submit accurate WH-347 forms on time and give you the right to audit their payroll records. That language protects you and gives subs a clear expectation from day one.

Compliance tracking is easier when lien waivers, insurance certificates, and certified payroll records live in one place. EZBilling is built for exactly that.