The 12 weekly checks every prime contractor must run on every sub’s WH-347 to stay Davis-Bacon compliant.
Why federal primes need a WH-347 review checklist
If you’re a prime on a Davis-Bacon job, every Friday afternoon looks the same. Your subs send WH-347s by email, fax, Dropbox link, or, when they’re really committed to your suffering, a flat scan of a fax of a printout. Half are scanned at an angle. One has the wrong week ending. Two have classifications you’ve never seen on the wage decision. By Monday morning, the contracting officer wants confirmation that everyone’s in compliance.
The DOL doesn’t care that your sub’s payroll clerk made a typo. They don’t care that the fringe-benefit number is off by $0.83. They care whether the prime, you, caught it before pay went out. When something’s wrong, your name is on the withholding letter.
That’s not new. What is new: the 2023 Davis-Bacon rule update made primes strictly liable for subcontractor violations, even ones the prime had no knowledge of. The DOL spelled it out: “the prime contractor is liable for the back-wage liability of all the contractors and subcontractors below it.” Add the upcoming September 30, 2026 deadline to switch to the new WH-347 form, and the volume of detail you have to track every week just went up.
We built this checklist from years of experience inside federal construction. Reviewing certified payrolls every Friday, every project, every sub. Not in a clean spreadsheet. In a stack of PDFs with red pen and a coffee. The 12 things on this list are the things that actually trip up primes during a DOL audit. Not the textbook items. The real ones.
You can use this manually for the next 200 weeks of your career. Or, when you’re ready, Contracts Connected’s Certified Payroll Analyzer runs the same 12 checks automatically the moment a sub’s WH-347 lands in your inbox. Your call.
Who this checklist is for
- Federal general contractors managing Davis-Bacon projects over $2,000
- Prime contractors required to certify weekly payroll compliance for downstream subs
- 8(a) federal subs acting as primes on set-aside contracts
- Compliance officers preparing for a DOL audit or contracting-officer review
- Project administrators chasing late or incomplete WH-347 submissions every Friday
If you’re not the prime, if you’re the sub filling out a WH-347, this isn’t your checklist. You want our WH-347 line-by-line annotated example instead.
The 12-point weekly review
The checklist covers 12 things every prime must verify on every WH-347, every week, before approving a sub’s payroll for that period.
- Verify worker name, address, and last-4 SSN are populated. Missing last-4 SSN is the #1 reason DOL kicks back a WH-347. Don’t trust the sub’s payroll software default, review every line. Flag any blank field before the form leaves your office.
- Confirm work classification matches the Davis-Bacon wage decision. Pull the wage decision attached to the contract (not the sub’s general WD). Match every classification on the WH-347 line-by-line. Unfamiliar titles like “Carpenter Helper” or “Pipefitter Trainee” are red flags. They require formal conformance through the contracting officer.
- Reconcile hourly rate against posted prevailing wage. The base hourly rate must equal or exceed the wage decision rate for that classification on that day. Round-down errors are common. If the sub paid less, the back-wage liability flows to you.
- Validate fringe-benefit cash vs. plan contributions. Fringes can be paid in cash, contributed to a bona fide plan, or split. Whatever the method, it must be documented. Cash fringes show on the WH-347 face; plan contributions need backup in a separate ledger that you should also have on file.
- Check overtime hours are computed at 1.5x base. Overtime under Davis-Bacon means 1.5x the base prevailing wage rate, not 1.5x the actual rate paid. If the sub’s rate already exceeds prevailing, OT calculation gets nuanced, verify by hand.
- Spot-check apprentice ratio against journeyman count. Registered apprentices can be paid at a percentage of journeyman wage, but only at the ratio specified by the registered apprenticeship program. Two apprentices to one journeyman is a common cap. Unregistered “apprentices” owe full journeyman wage, no exceptions.
- Confirm gross earnings tie to project hours. Gross on the WH-347 should reconcile to (hours × rate) + (OT × 1.5 × rate) + fringes-if-cash. Off-project hours don’t appear here. Look for inflated grosses that suggest off-project labor was rolled in.
- Verify deductions are documented and lawfully authorized. Health insurance, retirement, garnishments, advances. Every deduction must be authorized in writing by the employee per the Copeland Anti-Kickback Act. Cash advances and tool/equipment deductions get scrutinized hardest.
- Match net pay to direct-deposit or check register. The net pay column on the WH-347 should match what actually hit the employee’s bank account or paper check. Discrepancies between WH-347 net and the payroll register are audit findings.
- Confirm the Statement of Compliance is signed weekly. The Statement of Compliance on page 2 of the WH-347 must be signed by an owner, officer, or supervisor with payroll authority. Boxes 1, 2, 3, and 6 must be checked. Stamped signatures don’t count. Missing signature equals invalid form.
- Flag missing weeks across your active subcontractor list. Every active sub working covered hours owes one WH-347 per week, even on weeks with zero covered hours (the “no-work” form or a separate Statement of Non-Performance, depending on the agency). Track submissions against your active-sub list. Gaps trigger withholding.
- Archive WH-347s with consistent project-week filing. DOL requires 3-year retention post-completion. File by project, then by week ending, then by sub name. A messy filing system is a common audit-finding accelerator, and the auditor will dig harder when they sense disorganization.
How to run the checklist weekly
Run this every Friday afternoon before close-of-business. For each WH-347 received that week:
- Open the printed PDF version (or use the working Excel version with built-in checkboxes).
- Work down the 12 items in order for one sub at a time. Don’t multitask across subs. You’ll miss things.
- Mark each item: OK, Flag, or Reject and resubmit.
- Anything Flagged needs sub follow-up by Monday end-of-day.
- Anything Rejected stops sub payment until corrected.
- File the completed checklist alongside the sub’s WH-347 in the project’s Davis-Bacon binder. If a DOL auditor shows up, this is the artifact that proves the prime exercised oversight.
The full PDF download includes a printable cover sheet so you can clip it to the front of each sub’s weekly packet.
Stop running this manually every Friday
The 12 checks on this list take 15 minutes per WH-347 if you’re fast. Multiply by 30 active subs across 4 projects and you’ve burned a Friday. Contracts Connected’s Certified Payroll Analyzer runs all 12 checks the moment a sub’s WH-347 lands in your inbox. No Friday tax, same depth, runs itself. Between us, that’s the part of the job nobody wanted anyway.
Frequently asked questions about the certified payroll review checklist for primes
What is the WH-347 form and who must use it?
The WH-347 is the Department of Labor’s standardized weekly certified payroll form for federal-construction projects covered by the Davis-Bacon and Related Acts (any contract over $2,000 for federal or federally-assisted construction). Every contractor and subcontractor performing covered work, including the prime, must submit one each week. The prime is responsible for collecting all sub WH-347s, reviewing them for compliance, and forwarding them to the contracting officer.
How often must certified payroll be submitted?
Weekly. For every active subcontractor performing covered work, due within 7 days of the regular payday. Even on weeks with zero covered hours, a sub must submit a “no-work” WH-347 confirming no covered labor was performed. Some agencies will accept a separate Statement of Non-Performance instead. Confirm what your contracting officer requires.
Is the prime contractor liable if a subcontractor’s WH-347 is wrong or late?
Yes. Under the Department of Labor’s 2023 Davis-Bacon rule update, the prime is now explicitly strictly liable for subcontractor violations. Even if the prime had no knowledge of them. If a sub misclassifies a worker, misses a payroll, or underpays fringes, the prime carries the back-wage and debarment exposure. Withheld payments, DOL investigations, and contractor-debarment actions all attach to the prime first.
What changed about the WH-347 form in 2026?
The Department of Labor revised the WH-347 form. After September 30, 2026, the previous version of the WH-347 will no longer be accepted. Contractors should switch to the updated form before that date to avoid rejected submissions. The core fields are largely unchanged, but the Statement of Compliance language and certain field formats are updated.
Are fringe benefits required to be paid in cash on the WH-347?
No. Fringes can be paid in cash, contributed to bona fide plans (health, retirement, training), or split between the two. But however they’re paid, the method must be documented and the dollar value must equal or exceed the fringe amount listed on the wage decision. Cash fringes show on the WH-347 face under “Payment in Lieu of Fringe Benefits.” Plan contributions are tracked under “Total Fringe Benefit Credit” and need backup in a separate ledger.
Who signs the Statement of Compliance on a WH-347?
An owner, officer, or supervisor with payroll authority. The signature certifies wage compliance under penalty of perjury. Boxes 1, 2, 3, and 6 of the Statement of Compliance must be checked. Stamped signatures, signatures by unauthorized clerks, and missing signatures all invalidate the form and trigger withholding.
Does a prime contractor have to review every subcontractor’s WH-347?
Yes. The prime’s review responsibility is part of the Davis-Bacon obligation, not optional. Primes are expected to review and retain all sub WH-347s for 3 years post-completion. A pattern of “rubber-stamping” sub submissions without substantive review is itself a DOL audit finding, and given the 2023 strict-liability rule, primes who don’t review face the back-wage exposure when (not if) a sub gets it wrong.