Compliance WH-347
Validation Checks by Instafill.ai
1
Contractor Type Selection is Mutually Exclusive
Validates that exactly one of 'Prime Contractor' or 'Subcontractor' checkboxes is selected, but not both and not neither. This distinction is critical for compliance tracking under the Davis-Bacon and Related Acts, as prime contractors and subcontractors have different reporting obligations. If neither or both are selected, the form cannot be properly attributed to the correct entity type, which may result in rejection by the contracting agency.
2
Week Ending Date Format and Validity
Validates that the Week Ending Date fields on both pages of the form contain a valid calendar date in MM/DD/YYYY format and that the dates on both pages match each other exactly. The week ending date establishes the specific payroll period being certified, and inconsistencies between pages could indicate data entry errors or fraudulent alterations. An invalid or mismatched date will cause the certified payroll to be rejected as it cannot be reconciled with the project timeline.
3
Required Project Header Fields Are Populated
Validates that all mandatory project identification fields are completed, including Project Name, Project or Contract Number, Certified Payroll Number, Contractor's Business Name, Project Location, and Wage Determination Number. These fields are required by 29 C.F.R. § 5.5(a)(3)(ii) to properly identify the contract and payroll period being reported. Missing any of these fields renders the certified payroll incomplete and non-compliant with DBRA regulations, potentially exposing the contractor to penalties.
4
Worker Name Fields Are Not Left Blank for Populated Rows
Validates that for every worker row where any payroll data (hours, wages, deductions) has been entered, the Worker Last Name and Worker First Name fields are also populated. Worker identification is a fundamental requirement of the certified payroll under the Copeland Act, as the form must document wages paid to each named employee. A row with payroll data but no worker name is incomplete and may suggest an attempt to obscure worker identities.
5
Worker Identifying Number Format Validation
Validates that the Worker Identifying Number field for each worker entry contains a value in an acceptable format, typically the last four digits of a Social Security Number or another approved identifier, and is not left blank for any row containing payroll data. Per DOL instructions, contractors must include a worker identifying number to distinguish workers with similar names and to facilitate wage compliance audits. An improperly formatted or missing identifying number may prevent the DOL or contracting agency from verifying that the correct worker was paid.
6
Journeyworker or Apprentice Status is Specified for Each Worker
Validates that the worker status field for each populated worker row contains either 'J' (Journeyworker) or 'RA' (Registered Apprentice), and that no other values are entered. This classification determines the applicable prevailing wage rate under the Davis-Bacon Act, as apprentices may be paid at a lower rate only if they are duly registered in an approved program. An invalid or missing status code makes it impossible to verify wage compliance and may trigger a compliance investigation.
7
Apprentice Workers Have Corresponding Apprenticeship Program Information
Validates that for every worker identified with 'RA' (Registered Apprentice) status on page 1, a corresponding entry exists in the Apprenticeship Program section on page 2, including the program name, labor classification, and a selection of either OA or SAA registration. The certifying official must verify and attest to the registered apprenticeship program details for all apprentices, as required by the Statement of Compliance. Failure to provide this information invalidates the certification for those workers and may constitute a false statement under 18 U.S.C. § 1001.
8
Total Deductions Equal Sum of Individual Deduction Components
Validates that for each worker, the Total Deductions field equals the arithmetic sum of Tax Withholdings, FICA Deductions, and Other Deductions. This mathematical consistency check ensures the accuracy of the payroll records being certified under penalty of law. A discrepancy between the sum of individual deductions and the total deductions field indicates a data entry error or potential manipulation of payroll figures, which could result in underpayment of net wages to workers.
9
Net Pay Equals Gross Amount Earned Minus Total Deductions
Validates that for each worker, the Net Pay field equals the Gross Amount Earned for All Work minus the Total Deductions. This fundamental payroll arithmetic check ensures that workers are receiving the correct take-home pay as reported on the certified payroll. If net pay does not reconcile with gross earnings and deductions, it may indicate an error in reporting or an impermissible deduction under 29 C.F.R. Part 3, which prohibits kickbacks from wages.
10
Overtime Hourly Wage Rate is at Least 1.5 Times the Straight Time Rate
Validates that for each worker where overtime hours are recorded, the Overtime Hourly Wage Rate is at least 1.5 times the Straight Time Hourly Wage Rate for that worker. Under the Contract Work Hours and Safety Standards Act (CWHSSA), laborers and mechanics on covered contracts must receive overtime compensation at no less than one and one-half times their basic rate of pay for hours worked over 40 in a workweek. A failure of this check indicates a potential wage violation that must be corrected before the certified payroll can be submitted.
11
Fringe Benefit Credit Total Matches Sum of Individual Plan Credits
Validates that for each worker listed in the Hourly Credit for Fringe Benefits section on page 2, the Total Hourly Credit field equals the sum of all individual fringe benefit plan hourly credit amounts entered for that worker. Accurate fringe benefit credit reporting is required to verify that workers are receiving the full prevailing wage, which includes both the basic hourly rate and applicable fringe benefits. A mismatch in these totals suggests a calculation error that could result in underpayment of the prevailing wage.
12
Fringe Benefit Plan Funded or Unfunded Status is Selected
Validates that for each fringe benefit plan listed in the Hourly Credit for Fringe Benefits section, exactly one of the 'Funded' or 'Unfunded' checkboxes is selected, and that neither both nor neither are checked. The funded or unfunded status of a fringe benefit plan affects how the DOL evaluates the legitimacy of the fringe benefit credit claimed by the contractor. Leaving this field blank or selecting both options makes the fringe benefit claim ambiguous and non-compliant with reporting requirements.
13
Certified Payroll Number is Sequential and Numeric
Validates that the Certified Payroll Number is a positive integer and that it is consistent with the expected sequential numbering for the project (i.e., it should be one greater than the previously submitted payroll number for the same project and contractor). Sequential payroll numbering is required to ensure a complete and unbroken record of weekly payroll submissions for the duration of the project. A non-numeric value, a duplicate number, or a gap in the sequence may indicate missing payroll submissions, which is a violation of the weekly reporting requirement under the Copeland Act.
14
Certifying Official Signature, Date, and Contact Information Are Present
Validates that the Signature of Certifying Official, Certification Date, Telephone Number, and Email Address fields on page 2 are all populated and that the telephone number matches the format (XXX) XXX-XXXX. The Statement of Compliance must be signed by a person who supervised or paid the workers, and the contact information is required for the contracting agency to follow up on any discrepancies. An unsigned or incomplete Statement of Compliance renders the entire certified payroll submission invalid under 29 C.F.R. § 5.5(a)(3)(ii).
15
Project Header Information is Consistent Across Both Pages
Validates that the Project Name, Project or Contract Number, Payroll Number, Contractor's Business Name, Project Location, and Week Ending Date entered on page 2 (Statement of Compliance) exactly match the corresponding fields entered on page 1 of the form. Both pages constitute a single certified payroll submission, and any discrepancy between the identifying information on the two pages suggests a data entry error or that the pages may have been mismatched from different submissions. Inconsistent header information will cause the submission to be rejected as it cannot be verified as a complete and accurate record.
16
Other Deductions Must Have a Specified Description
Validates that for any worker where an amount greater than zero is entered in the 'Other Deductions' field, a corresponding description or specification of the deduction type is also provided, as required by the form instructions. Under 29 C.F.R. Part 3, only permissible deductions may be taken from workers' wages, and unspecified deductions cannot be evaluated for compliance. Failing to describe other deductions prevents the DOL and contracting agencies from determining whether the deductions are lawful, which may constitute a violation of the Copeland Anti-Kickback Act.