PayrollHow to report fringe benefits on certified payroll
Fringe benefits are where most WH-347 errors happen. The form asks for a dollar amount per hour, but the underlying obligation is more nuanced. This page explains how to get it right.
Last reviewed: October 2026, against 29 CFR 5.5(a)(1)(i).
What "fringe benefits" means on a Davis-Bacon job
Under the Davis-Bacon Act, the wage determination for each classification sets two numbers: a base cash wage and a fringe benefit rate. You can satisfy the total obligation by paying the base wage in cash and the fringe in one of two ways — the wage determination itself is the rule, and 29 CFR 5.5(a)(1)(i) is where the fringe-as-wages treatment comes from:
- Cash in lieu of benefits — you pay the fringe amount directly to the worker as additional cash wages.
- Bona fide plan contributions — you pay into a qualified health, pension, or other benefit plan on the worker's behalf.
You can also mix the two. For example, you might pay $2/hour in cash and $3/hour into a health plan. The total must meet or exceed the fringe rate in the wage determination.
Columns 6B and 6C on the 2025 form
The January 2025 revision split the old single fringe column into two:
- Column 6B — Fringe benefits paid as cash in lieu of benefits.
- Column 6C — Fringe benefits paid into a bona fide plan.
Both columns ask for an hourly rate, not a weekly total. If the worker's fringe obligation is $5.00 per hour and you pay all of it in cash, enter 5.00 in Column 6B and leave 6C blank. If you split it, enter the cash portion in 6B and the plan portion in 6C.
The per-hour math
The fringe amount on the form is always an hourly rate. To calculate it from a weekly contribution:
Hourly fringe = Weekly contribution ÷ Total hours worked
If a worker earns $25/hour base wage and the wage determination requires $5/hour in fringe benefits, and you contribute $200/week into a health plan for 40 hours worked:
- Weekly contribution: $200
- Hours worked: 40
- Hourly fringe: $200 ÷ 40 = $5.00/hour
In this case, you enter 5.00 in Column 6C and leave 6B blank.
Worked example: mixed cash and plan
Worker: Maria Delgado. Classification: Carpenter. Base wage: $28.00/hour. Fringe rate: $6.00/hour. Hours worked: 40.
You pay $3.00/hour in cash in lieu and contribute $120/week to a pension plan.
- Cash in lieu: $3.00/hour → Column 6B =
3.00 - Plan contribution: $120 ÷ 40 hours = $3.00/hour → Column 6C =
3.00 - Total fringe: $3.00 + $3.00 = $6.00/hour → meets the $6.00 requirement
- Gross wage (Column 7A): 40 hours × $28.00 = $1,120.00
- Total wage (Column 7B): $1,120.00 + (40 × $6.00) = $1,360.00
This is the exact row from the Delgado sample that ships with PayrollWarden's free tool.
Why overtime premium applies to the base cash rate only
This is the most common mistake on certified payroll. The overtime premium (the "half" in time-and-a-half) applies only to the base cash wage, not to the fringe benefit portion.
If a worker's base rate is $28.00/hour and the fringe rate is $6.00/hour, the overtime rate is:
- Base cash wage: $28.00/hour
- Overtime premium: $28.00 × 0.5 = $14.00/hour
- Overtime rate: $28.00 + $14.00 = $42.00/hour
The fringe benefit is still paid at the straight-time rate ($6.00/hour) for the overtime hours. The total compensation for an overtime hour is $42.00 + $6.00 = $48.00.
If you calculate overtime on the total wage ($28.00 + $6.00 = $34.00 base), you will overpay the premium and the form will not match the wage determination.
What the form does not ask for
The WH-347 does not ask you to itemize which benefits you provide. It only asks for the dollar amount per hour in Columns 6B and 6C. However, you must keep records of the underlying contributions in case of a DOL audit. The form is a summary, not a substitute for your books.
What to do next
If you are unsure whether your fringe calculation is correct, use the free WH-347 filler. It calculates Columns 6B, 6C, 7A, and 7B from your inputs and flags common errors before you download.
Calculate fringe benefits free
The boxes themselves: field-by-field WH-347 guide. What the January 2025 revision changed about these columns: 2025 form changes.
Sources
- 29 CFR 5.5 — Records to be kept and furnishing of weekly information — paragraph (a)(1)(v): the wage determination total owed, and fringe contributions treated as wages (verified from the current eCFR text, October 2026).
- WH-347 Annotated Guide, U.S. Department of Labor — the DOL's own instructions for the fringe columns.
Frequently asked questions
Can I pay all fringe benefits as cash?
Yes. Paying the full fringe rate as cash in lieu of benefits satisfies the Davis-Bacon obligation. Enter the full hourly amount in Column 6B and leave 6C blank.
Do I have to use a bona fide plan?
No. Cash in lieu is allowed. But if you do use a plan, the contributions must be to a bona fide plan (health insurance, pension, etc.) and you must keep records of the contributions.
Does overtime apply to fringe benefits?
No. The overtime premium applies only to the base cash wage. Fringe benefits are paid at the straight-time rate for all hours worked, including overtime hours.
What if my fringe contribution exceeds the required rate?
You only need to report up to the required rate on the form. Excess contributions are not required to be reported, but you should keep records of them.