01-04-2012 My WH-347 Certified Payroll Reports Expired 12/31/11 - Now What?

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The current U.S. Department of Labor WH-347 Certified Payroll Report expired on 12/31/2011.  Don't worry - you can continue to use that form until the new one is released!

Everyone who has to submit the U.S. Department of Labor WH-347 Certified Payroll Report is certainly getting nervous as the form expired on 12/31/2011, we are getting a LOT of calls from customers and non-customers alike asking us when they can expect the new form to be available.

We've been watching the U.S. Department of Labor website since the middle of December and even though the form has officially expired now, an updated form has not been made available.

On January 3rd the following statement appeared on the DOL website:

This form has been submitted for renewal to the Office of Management and Budget (OMB). According to law [5 CFR 1320.10(e)(2)], the agency may continue to use the form while its renewal is pending at OMB.

We will continue to monitor the DOL website on a daily basis and as soon as the form is released we will make the changes necessary to our Certified Payroll Solution software in order for it to produce the new form and any new reporting requirements that may also be implemented along with the new form.

In the meantime you may continue to submit the form with the 12/31/2011 date on it without issue.

Your patience is appreciated while we all play the waiting game.

Update:

The U.S. Department of Labor released the new Federal WH-347 form on 1/31/2012 - we are making the necessary adjustments to our software. 

Very little has changed, the reporting requirements are still the same as with the previous form. 

There is a new OMB number and the form is now set to expire on 1/31/2015. 

A new partial sentence on the Statement of Compliance; "and that no deductions have been made either directly or indirectly from the full wages earned by any person."

The instructions do indicate that "a space has been left at the bottom of the columns so that total may be shown if the contractor so desires."  There is, however, no indication of exactly WHAT totals are to be displayed, and the actual fillable .pdf version from the U.S. DOL website doesn't even have that "space" for the totals that they indicate is available - for example do they want total hours by day for Straight Time, Overtime, perhaps Double Time, Shift Time, Down Time {or any other type of paid time}.  Do they want the Total of Wages Paid on This Job/All Jobs, total of each type of withholding and/or deduction?  

We are attempting to get the specifics of the "totals" so that we can properly update the form, your patience is appreciated while we investigate this.

The trouble with totals and the fact that there currently are no clear guideline:

• Someone might want total hours by displayed as the grand total of ALL hours worked each day
• Someone else might want total hours displayed as the total Straight time hours and the total Overtime hours worked each day
• Someone else might want the total Straight Time Hours for the day and the total Overtime hours for the day PLUS a grand total of all hours worked for the day

See where I'm going with this?  Not quite as easy as any of us thought now is it?