Certified payroll is the paperwork government contractors file every week to prove they're paying workers at or above the prevailing wage. On a Davis-Bacon job, you file WH-347 (or your state's equivalent) within seven days of the end of each pay period, for every worker on the covered contract.
If your crews are on piece rate, the form fills out the same way — you just do a conversion step first. Piece rate earnings get converted into an effective hourly rate, and that's what shows up in the rate column. Get the conversion wrong and the government withholds contract funds until you fix it.
This article walks through how to fill out WH-347 for piece rate crews, line by line, plus the common mistakes that trigger withholding.
My background
I'm Tyson Faulkner. My background is in roofing, not federal contracting, but the math I'm walking through here is the same math you'd run for any piece rate compliance check — just filed on a government form with a federal deadline attached.
The WH-347 form in one paragraph
WH-347 is a single-page weekly payroll report. You list every worker on the covered contract. For each worker, you show: name, classification (roofer, carpenter, laborer, etc.), hours worked each day on the covered contract, total hours, rate of pay, gross amount earned, deductions, and net wages. You also sign a Statement of Compliance on page two attesting that the payroll is accurate and that no worker was paid below the prevailing wage.
The form is on the DOL website. You can file it electronically through the agency's certified payroll system (many use LCPtracker, Elation, or similar), or as a PDF.
Hour tracking is step one
Before you can fill out WH-347, you need clean hour records. Every worker on the covered contract needs:
- Total hours worked each day
- How many of those hours were on the covered contract vs. other work
- Classification worked during those hours (some workers may shift classifications during the week)
Piece rate doesn't exempt you from hour tracking. It never has — see do you have to track hours for piece rate workers — but on Davis-Bacon jobs the bar is higher. You need daily, accurate, per-job hour records for every worker. Weekly totals won't cut it.
What counts as hours on the covered contract
Any hour spent performing work on the Davis-Bacon site, including:
- Productive piece rate work (installing, tearing off, etc.)
- Safety meetings held on the covered job
- Travel from staging to the covered site when required by the employer
- Standby time on the covered job (waiting on material, waiting on inspection)
- Cleanup at the end of the day
What doesn't count:
- Commute from home to the first job site
- Lunch breaks (unpaid and uninterrupted)
- Work on other jobs that aren't Davis-Bacon covered
Converting piece rate to an effective hourly rate
This is the key step. You're not reporting "piece rate" on the form. You're reporting an hourly rate that reflects what the worker actually earned per hour on the covered contract.
The formula:
Effective hourly rate = total piece rate earnings on the covered contract ÷ hours worked on the covered contract
Worked example
A roofer works on a Davis-Bacon job Monday through Thursday. He also works Friday on a private job that isn't covered.
- Monday: 10 hours on the covered job
- Tuesday: 9 hours on the covered job
- Wednesday: 10 hours on the covered job
- Thursday: 8 hours on the covered job
- Friday: 8 hours on a private job (not reported on WH-347)
Total hours on the covered contract: 37 hours
He earned $1,480 in piece rate pay for the squares he installed on the covered job that week.
Effective hourly rate: $1,480 ÷ 37 hours = $40/hr
If the prevailing wage for roofer in that county is $38/hr, he's above the floor. You report $40/hr as the rate on WH-347, $1,480 as the gross, 37 as the total hours, and distribute those hours across Monday-Thursday in the daily columns.
If the effective rate is below the prevailing wage
Same roofer, bad week. Steep tear-off, slow production, same 37 hours but only $1,258 in piece rate earnings.
Effective rate: $1,258 ÷ 37 = $34/hr
That's $4/hr below the $38/hr prevailing rate. You owe makeup pay:
$4/hr × 37 hours = $148 in makeup pay
Add $148 to his check. On WH-347, report:
- Total hours: 37
- Rate: $38/hr (after makeup, the effective rate now meets the prevailing)
- Gross: $1,406 ($1,258 piece rate + $148 makeup)
Some payroll folks prefer to show the piece rate as $34/hr with a separate line for makeup. Either presentation is acceptable as long as the total gross and final effective rate are clear. Check with the contracting agency for their preferred format.
The same makeup-pay logic applies on non-government jobs too — see piece rate minimum wage compliance for the general FLSA version.
Fringe benefits on the form
Wage determinations usually list a basic hourly rate and a fringe benefit rate. Example: $38/hr basic + $12/hr fringe = $50/hr total prevailing wage.
WH-347 handles fringe in one of two ways:
Option 1: Pay fringe in cash
Easier. You add $12/hr × hours worked to the worker's gross pay. On the form, you check the box indicating fringe is paid as cash in wages, and the gross amount you report includes both the piece rate earnings (converted to effective rate) and the fringe.
Using the worker above with a clean week:
- Base: $1,480 (piece rate, $40/hr effective)
- Fringe: $12/hr × 37 hours = $444
- Gross on WH-347: $1,924
- Rate column: you can show the composite or show base and fringe separately depending on the form version
Option 2: Provide actual benefits
You check the box indicating benefits are paid to approved plans. You document which benefits are provided (health insurance, retirement, apprenticeship training, paid vacation) and the hourly equivalent of each. The gross on the form includes only the base pay (piece rate converted to effective rate), not the fringe dollars.
If you do it this way, keep benefit cost documentation on file. The DOL can audit.
Most small contractors just pay fringe in cash. It's cleaner.
Overtime on WH-347
Any hour over 40 in the workweek is overtime under the FLSA. On federal contracts over $100,000 the CWHSSA also requires 1.5× for hours over 40 on the covered contract.
For piece rate, overtime is calculated as:
OT premium = 0.5 × regular rate × OT hours
Where the regular rate is the effective hourly rate (total earnings divided by total hours).
For step-by-step OT math across mixed covered and private hours, see how to calculate overtime for piece rate workers and check your numbers with the overtime calculator. The short version: regular rate = total weekly earnings ÷ total hours, then OT premium = 0.5 × regular rate × OT hours.
On WH-347, OT hours worked on the covered contract go in their own column, and the rate column shows the OT rate.
Walking through a sample WH-347 line
Let's say your crew has one roofer — classification "Roofer," prevailing wage $38/hr base + $12/hr fringe — who worked 37 hours on a covered Davis-Bacon job Monday-Thursday. He earned $1,480 in piece rate pay on that job. He had no private work that week, so total weekly hours are 37, no overtime. You pay fringe in cash.
Line on WH-347:
- Name: John Doe
- Classification: Roofer
- Day/hours: M-10, T-9, W-10, Th-8, F-0, S-0, Su-0
- Total hours: 37
- Rate of pay: $40.00 straight time (base effective, which beats $38), $12.00 fringe as cash = $52.00 total hourly
- Gross amount earned: $1,924.00 (($40 × 37) + ($12 × 37))
- Deductions: FICA, Medicare, federal income tax, state income tax
- Net wages: whatever lands after deductions
Statement of Compliance (page 2):
You sign attesting:
- The payroll is correct and complete
- The wages paid are not less than the applicable wage determination
- No rebates or kickbacks have been made
- Fringe benefits have been paid as indicated
Common mistakes that trigger withholding
These are the errors most commonly flagged on piece rate certified payrolls:
1. Missing hours
If hour tracking is sloppy, the effective rate is garbage. Some contractors try to back into it by dividing total earnings by a guessed hour number. Auditors compare to timecards and foreman logs. If the numbers don't match, the whole payroll gets flagged.
2. Not paying for nonproductive time
Safety meetings, standby, travel on the covered job — all payable hours. Miss those and your effective rate math inflates. See how to pay piece rate for nonproductive time.
3. Reporting piece rate as the rate
The rate column on WH-347 is a dollar-per-hour rate. If you write in "$50 per square" because that's what you actually pay, the form is wrong. Convert to effective hourly and report that.
4. Skipping overtime on piece rate
"Piece rate workers don't get overtime" is a myth that will cost you the job. Non-exempt piece rate workers get overtime under FLSA, period. Skipping it is the biggest mistake roofers make on piece rate and overtime. On certified payroll, missing OT is an instant flag.
5. Misclassifying workers
Classification determines the prevailing wage. If your worker is really doing carpenter work and you classify him as laborer because the laborer rate is lower, that's a federal offense. Classifications should match the actual work performed.
6. Misusing 1099 status
Piece rate does not automatically mean 1099. On Davis-Bacon jobs, most piece rate crews are W-2 employees because they work exclusively for you, use your equipment, and follow your direction. Use the 1099 vs W-2 calculator to stress-test classification before you put someone on a covered contract as 1099. Misclassification gets expensive fast on government work.
7. Late or missed filings
Weekly filing is not optional. Miss a week and the agency can withhold. Miss multiple weeks and you're looking at serious compliance problems.
Consequences
If certified payroll is wrong:
- Withholding. The contracting agency holds contract payments until corrected.
- Back wages and interest. Workers get paid what they should have been paid plus interest.
- Debarment. Repeat or willful violations can bar your company from federal contracts for up to three years.
- Criminal charges. Willful falsification of WH-347 is a federal offense. This is where contractors go from "compliance headache" to "legal problem."
I'm not going to throw specific penalty numbers at you — those vary by case and by agency. The point is: the downside is worse than the cost of doing the payroll right.
Weekly workflow for piece rate certified payroll
Here's the cadence that works:
Monday through Saturday:
- Crew logs hours daily — every hour on the covered job, productive and nonproductive
- Production gets logged (squares, linear feet, units) so piece rate earnings are trackable
Sunday or Monday morning:
- Pull total hours per worker for the week
- Pull piece rate earnings per worker for the covered contract
- Calculate effective hourly rate
- Compare to prevailing wage — if below, calculate makeup pay
- Calculate overtime using the FLSA method (total earnings ÷ total hours = regular rate; OT premium = 0.5 × regular rate × OT hours)
- Add cash fringe if that's your method
- Build deductions, run payroll
By Monday of the following week:
- Complete WH-347 for the prior week
- Sign the Statement of Compliance
- Submit to the contracting agency (or via their certified payroll portal)
If you're doing this in a spreadsheet, you will eventually miss something. Running the piece rate calculator alongside a labor burden calculator for bids is fine for estimating, but for weekly certified payroll you want a system that tracks hours, piece rate earnings, and effective rates per worker per job automatically.
Disclaimer: This article is for informational purposes only and is not legal, tax, or insurance advice. Consult a qualified professional before making decisions for your business.
Closing
Certified payroll on piece rate jobs is not hard. It's detail-heavy. Every hour matters, every piece of pay has to be accounted for, and the form has to be filed on time every week. If you have that habit down, Davis-Bacon is just more paperwork. If you don't, you'll bleed cash on withholding and corrections.
Piece Work Pro tracks hours, piece rate earnings, and effective hourly rates per worker per job — the inputs you need for WH-347 without building a spreadsheet from scratch every week.
For more on the prevailing wage floor itself, see piece rate and prevailing wage for government work. For the general FLSA foundation certified payroll sits on top of, see FLSA requirements for piece rate employers.