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For federally funded or assisted construction covered by the Davis-Bacon and Related Acts (DBRA), stop and correct the underlying payroll before anyone certifies the week. Trace every questionable figure to the project wage determination, classification, time records, fringe-benefit support, deductions, and payment record; update payroll and payment records when necessary; then have the authorized person review the corrected report and Statement of Compliance.
Form WH-347 is optional. The federal requirement is a complete weekly payroll submission with a signed Statement of Compliance, delivered through the recipient and channel specified by the contract or receiving agency. State and local prevailing-wage projects can use different forms, deadlines, and correction procedures, so confirm the funding source, contract clauses, wage decision, and agency instructions before applying this checklist.
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Not every construction payroll is subject to DBRA. Start with the prime contract, every applicable flow-down clause, the project location, the type of work, and the wage determination incorporated into the contract. The contracting agency makes the initial coverage and wage-determination decision. If coverage, the correct wage decision, or a revision date is unclear, ask the agency or the U.S. Department of Labor rather than choosing a rate based on a similar project.
Rates are tied to the project and location. There is no universal construction rate that can safely be inserted into a certified payroll. A state or local prevailing-wage law may impose separate classifications, forms, recipients, and amendment deadlines even when the work looks similar to a federal project.
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What a compliant weekly submission contains
DOL’s WH-347 instructions state: “While use of Form WH-347 itself is optional, covered contractors and subcontractors performing work on Federal or federally assisted construction contracts are required by the DBRA regulations and the contract clauses to submit payroll information on a weekly basis.” You may use another format if it contains the required information and includes an identical Statement of Compliance.
| Item | What the federal rule requires | What to verify before signing |
|---|---|---|
| Weekly payroll information | Covered contractors and subcontractors provide payroll information for each payroll week. | The report covers the correct week, project, contractor, subcontractors, and every covered worker. |
| Statement of Compliance | Each weekly submission includes a signed statement attesting to accuracy, completeness, and payment of required wages and fringes. | The signer has actually reviewed the source records and is authorized to certify the week. |
| Submission timing | DOL guidance describes delivery within seven days after the payroll period’s regular payment date. | Check the contract and receiving agency for the required portal, recipient, file format, and any stricter project deadline. |
| Signer | The contractor, subcontractor, or an agent who paid or supervised payment for workers during the week signs, following the form’s instructions. | The named person had the required payment or supervision responsibility and uses a signature method accepted for that project. |
| Worker details | Reports identify each worker, classification, hours, wages, fringe contributions or cash equivalents, deductions, and actual wages. | Use a worker identifying number such as the last four Social Security number digits on the transmittal; keep full identifying records securely in the underlying files. |
Weekly transmittals should not include full Social Security numbers, home addresses, telephone numbers, or email addresses. Privacy-safe reporting does not eliminate the obligation to retain complete basic and payroll records required for the project.
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Run the pre-submission error check
1. Match the project to the correct wage determination
Read the wage decision and its revision as incorporated into the contract, not a rate copied from a prior job. Confirm the county or other location, construction type, effective dates, and any project-specific modifications. Check that the report’s classifications and fringe requirements come from that decision.
- Compare the prime contract, funding documents, and flow-down clauses with the payroll setup.
- Confirm which agency or prime receives the report and whether the project uses an electronic portal.
- Escalate a disputed or missing wage decision instead of certifying a guessed rate.
2. Test the classification against work actually performed
A job title is not enough. Compare the employee’s tasks, daily logs, supervisor notes, and time entries with the classification in the wage decision. If a worker performed work in more than one classification during the week, the records and payroll should show the hours in each classification. Paying the worker under one title for convenience does not make that classification correct.
When the work does not fit a listed classification, use the applicable additional-classification process. Keep the request, agency response, and resulting rate with the payroll file. Do not silently substitute a nearby classification because it has a convenient rate.
3. Reconcile every hour and overtime trigger
Compare the certified payroll with employee timecards, daily reports, equipment or site logs, and the regular payroll register. Check each workday, the weekly total, the project assignment, and any split between covered and non-covered work. DOL expects accurate records for both kinds of hours when the same worker performed work on covered and non-covered jobs during one week.
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Determine whether the Contract Work Hours and Safety Standards Act applies to the contract. For covered contracts, DOL investigators check whether a worker who exceeded 40 hours in a workweek received time-and-one-half of the basic rate. Review overtime by workweek, not merely by pay period, and make sure the report reflects the rate and hours actually paid.
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4. Recalculate the wage, fringe, gross pay, deductions, and net pay
Recompute the required basic wage for the correct classification and the hours actually worked. Then document how the fringe obligation was met. Depending on the wage decision and the worker’s benefits, compliance may involve qualifying benefit contributions, allowable cost credits, cash paid in lieu, or a combination. A fringe credit needs supporting plan, invoice, contribution, or payroll records; a number typed into the report is not proof that the benefit was provided.
Reconcile the calculation to the payroll register and payment evidence:
- Basic wages multiplied by the correct regular and overtime hours.
- Fringe contributions or cash equivalents for the hours and classifications covered by the wage decision.
- Gross wages before deductions.
- Each permitted deduction, with authorization and a matching payroll record.
- Actual net wages paid to the worker, including the payment date and method in the underlying records.
Do not treat balanced arithmetic as proof of compliance. A report can add up while using the wrong wage decision, an unsupported fringe credit, omitted hours, or a deduction that leaves the worker below the required amount.
5. Validate apprentices and other worker categories
For every apprentice, verify registration in the applicable program, the program’s wage rates, and the permitted apprentice-to-journeyworker ratio. Compare the number of apprentices and laborers with the crew and work performed. DOL investigative guidance treats unusually high counts as a discrepancy worth examining, not as automatic proof of a violation.
A 1099 label does not by itself remove a laborer or mechanic from DBRA prevailing-wage or certified-payroll obligations. Look at the actual work and the contract requirements rather than relying on the tax label used in a payment system.
6. Check completeness, subcontractors, and the certification
Make a worker-by-worker list from site records and compare it with the payroll. Account for every covered employee, each subcontractor’s weekly report, and any worker who changed classification or moved between projects. Confirm that all required fields are present and that the Statement of Compliance is attached and signed by the proper person.
For a prime contractor, a subcontractor’s signed form is a starting point, not the end of the review. Compare the subcontractor’s workers, classifications, hours, wage decision, fringe support, and payment records to the contract and site evidence. Federal DBRA labor clauses flow down to subcontracts, and DOL says prime contractors may be liable for subcontractor violations.
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How to fix an error before submitting the report
Use a controlled correction sequence. It creates a defensible trail and prevents a change to one field from leaving related totals wrong.
- Pause certification. Do not sign or transmit a report while a classification, hour, rate, fringe, deduction, worker, or payment question is unresolved.
- Identify the source of truth. Gather the applicable wage determination, timecards, daily logs, payroll register, benefit records, deduction authorizations, payment evidence, and subcontractor records.
- Correct the underlying record. Fix the time entry, classification, rate, fringe calculation, deduction, or worker assignment in the payroll and payment system. If the worker was underpaid, calculate the amount owed and arrange the required corrective payment; changing the report alone does not pay anyone.
- Recalculate connected amounts. Recheck regular and overtime wages, fringe totals, gross pay, deductions, net pay, and any weekly or project totals affected by the correction.
- Check related reports. A classification or rate correction can affect another day, another worker on the same wage decision, a subcontractor transmittal, or the Statement of Compliance. Reconcile those connected documents before producing the final version.
- Preserve an audit trail. Keep the original error, the corrected entry, the reason for the change, the person who approved it, the date, and supporting records. Retain both the working history and the final certified version according to the contract and applicable recordkeeping rules.
- Obtain a genuine review and signature. The authorized contractor, subcontractor, or qualifying payment-supervision agent should review the complete corrected packet, sign the Statement of Compliance, and submit it through the project-required route.
Common correction examples
Wrong classification: Reconstruct the worker’s tasks and hours by classification, obtain an approved additional classification if required, apply the corresponding wage determination, and recalculate wages and fringes for every affected hour.
Missing hours: Compare timecards and site logs with the payroll. Add the hours to the correct workday and classification, recalculate overtime if the workweek passes 40 hours, and pay any shortfall before certification.
Unsupported fringe credit: Remove the unsupported credit, determine the qualifying contribution or cash equivalent, update the payroll, and preserve the benefit documentation.
Incorrect deduction: Verify authorization and legality, restore any amount that reduced required wages, and reconcile the resulting net payment with the bank or check record.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What to do when the error is found after submission
There is no single federal amendment workflow for every previously filed WH-347 or agency-system report. Portals, recipients, correction buttons, file naming rules, and deadlines vary by contracting agency and contract. Treat an already-submitted report as a record that must be preserved, not silently overwritten.
- Save the submitted file, transmission receipt, and portal confirmation.
- Establish the correct facts from the source records and determine whether any wage, fringe, overtime, or deduction amount is owed.
- Correct the payroll and payment records when the underlying figures are wrong. Issue the required back wages or benefit correction; an amended form by itself does not remedy underpayment.
- Contact the receiving agency or prime contractor promptly and ask for its project-specific amended-report process, recipient, format, and deadline.
- Submit the amendment or explanatory package through the instructed channel, preserving the original and corrected versions together.
- If the issue concerns a disputed wage determination, classification ambiguity, apprentice compliance, possible underpayment, or an investigation notice, involve the agency and a qualified prevailing-wage attorney or payroll professional.
DOL materials establish accuracy and recordkeeping obligations, but they do not prescribe one universal correction method for every agency portal. Follow the instructions attached to the particular contract instead of assuming that a federal project uses the same process as another project.
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Controls for prime contractors and subcontractors
What a prime should collect each week
- Every subcontractor’s certified payroll and signed Statement of Compliance.
- The subcontractor’s worker list, classifications, hours, wage decision, fringe support, deductions, and payment evidence.
- Site attendance, daily reports, and supervisor information that can confirm the people and hours reported.
- A record of questions raised, answers received, corrections made, and approval dates.
Reconcile those materials to the contract classifications and project wage decision. Review should be operational, not merely a check that a PDF exists. Because prime contractors may be liable for subcontractor violations, unresolved discrepancies should be stopped and escalated before the prime certifies its own submission.
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What subcontractors should control internally
Assign one person to gather time records, one review point for wage and fringe calculations, and an authorized signer who understands what the Statement of Compliance certifies. Keep payroll, benefit, deduction, and payment records organized by project and week so an apparent report error can be traced without recreating the payroll from memory.
Choosing a manual process, software, or outside service
A spreadsheet, payroll system, certified-payroll platform, or outside service is only useful if it supports the project’s actual obligations. Evaluate the workflow against these criteria rather than assuming that a product’s ability to print WH-347 proves compliance.
| Capability | Questions to ask |
|---|---|
| Submission route | Can it produce the format and signature method required by the receiving agency or prime, and can staff retain the transmission receipt? |
| Wage determinations and classifications | Can users attach the project’s wage decision and revision, document classification changes, and handle an additional-classification approval? |
| Hours and overtime | Can the process track hours by worker, day, classification, contract, and covered versus non-covered project, then test the 40-hour workweek rule where applicable? |
| Fringes and deductions | Can it distinguish qualifying benefit contributions from cash equivalents, retain support, and reconcile gross, deductions, and net pay to actual payments? |
| Subcontractor review | Can a prime collect reports, compare worker and hour data with site records, and document questions and resolutions? |
| Amendments and audit history | Does it preserve the submitted version, corrected version, approval trail, and reason for each change? |
| Access and retention | Can the organization restrict sensitive data, exclude full identifiers from transmittals, and retrieve complete records for the required retention period? |
An employee time-sheet book can supplement hour capture, but it is not a certified-payroll compliance system. Electronic tools must still satisfy the contract’s signature, access, retention, and submission requirements.
When a payroll error becomes a compliance issue
Escalate promptly when the error could mean a worker received less than the required wage or fringe, the correct classification is disputed, the wage determination is unclear, apprentice ratios or registration are questionable, or an agency has opened an investigation. Ask the contracting agency for direction and obtain qualified prevailing-wage legal or payroll advice. Keep communications and calculations with the project file.
Underpayment can lead to back-wage recovery, withholding, and other enforcement consequences. A corrected report does not automatically erase those consequences, and resolving one week’s report does not establish that other weeks or subcontractors are accurate.
Why accurate source records matter
In 2024, the U.S. Department of Labor reported recovering $518,446 in back wages for 54 workers in a prevailing-wage case involving underpayment, fringe-benefit issues, falsified certified payroll, and inaccurate or missing payroll records. That is a case result, not a typical exposure figure. It demonstrates why a signed form cannot substitute for reliable time, wage, fringe, and payment records.
The safest point to find and fix an error is before certification: use the project wage decision, reconcile the underlying records, correct any payment shortfall, preserve the audit trail, and submit only after the authorized signer can truthfully attest that the weekly payroll is complete and accurate.
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