WH-347 No Work Week: Certified Payroll with No Hours

— WH347.io Team

A week with no work on your federal project still requires a decision — submit a no-work report, or skip it? The answer depends on your contract, and getting it wrong can hold up payments. Here's exactly what to do.

Every federal construction project has weeks where nothing happens on site — a holiday, a weather delay, a waiting period for materials, or a gap between phases. The question contractors ask is: do I need to submit a WH-347 for a week where none of my workers worked on this project?

The short answer is: it depends on your contract, but erring on the side of submitting is almost always the safer choice.

Is a No-Work Submission Actually Required?

The Davis-Bacon regulations require certified payroll to be submitted for every week that work is performed on the project. They do not explicitly require a submission for weeks with no work. However, most federal construction contracts include a specific clause addressing non-work weeks — and many require a 'no work' or negative payroll certification for every week during the active period of the contract, even if no hours were logged.

Read your contract. Specifically, look for language in the certified payroll clauses or the Davis-Bacon wage provisions section that addresses 'no work performed' weeks. If the contract is silent, ask the contracting officer directly — get the answer in writing.

Why Agencies Require No-Work Submissions

Contracting agencies track certified payroll submissions week by week. A gap in the record — even for a legitimate non-work week — creates uncertainty about whether work happened that wasn't reported. A no-work submission closes that gap explicitly. It tells the agency: we were not on site this week, no workers were employed on this project, and we are certifying that fact.

For the agency, it's cleaner to have a continuous record than to have to follow up on every gap. For the contractor, a no-work submission is much easier to explain than a missing week during an audit.

How to Fill Out the WH-347 for a No-Work Week

The form itself is straightforward for a no-work week:

  • Header: Complete all project identification fields normally — contractor name, project name, contract number, and the week-ending date for the week in question.
  • Payroll number: Use the next sequential payroll number, as if it were a normal submission.
  • Worker rows: Leave the worker rows blank, or write 'No Work Performed This Week' across the rows. Do not fabricate entries.
  • Totals: All dollar and hour totals should be zero or left blank.
  • Statement of Compliance (page 2): Sign the Statement of Compliance and note in writing — either on the form or in a cover letter — that no work was performed on this project during the referenced week.

The Statement of Compliance for a No-Work Week

You still need to sign the Statement of Compliance for a no-work submission. The certification in this context is simply that no work was performed — you are not certifying wages paid because none were. Some contracting agencies have a specific no-work certification form or an addendum; check with your contracting officer if you are not sure which document to submit.

The person signing a no-work Statement of Compliance must be the same class of authorized signatory as a normal WH-347 — an owner, officer, or someone with written delegation authority. The reduced informality of a no-work week does not relax the signature requirement.

How Different Agencies Handle No-Work Weeks

Practice varies across contracting agencies. Some agencies require a formal no-work WH-347 every week the contract is active. Others accept a simple written statement or email from the contractor confirming no work was performed. A few agencies are silent on the issue and rely on the contractor to inform them of gaps proactively.

  • Federal agencies (HUD, DOT, Army Corps, etc.): Most require a no-work submission covering every week of the contract period.
  • State agencies using Davis-Bacon requirements: Requirements vary by state and by the specific grant program funding the project. Some states have their own no-work forms.
  • Local agencies (cities, counties): Practice is inconsistent — always check the specific contract language and ask the contracting officer if it is not clear.

What Happens If You Skip a No-Work Submission

If your contract requires no-work submissions and you don't file one, you have a gap in your certified payroll record. During a routine audit, the auditor will flag the missing week and ask for an explanation. If you can document clearly that no work occurred (site logs, photographs, subcontractor communications), most auditors will accept that explanation and note the record is now complete.

If you cannot document the no-work status convincingly, the auditor may treat the missing submission as unverified work — potentially triggering a broader payroll review for that period. The cost of a missed no-work submission is much higher than the two minutes it takes to file one.

How WH347.io Handles No-Work Weeks

In WH347.io, you can mark any project week as a no-work week directly in the dashboard. The platform generates a properly formatted WH-347 with zero hours and wages, the sequential payroll number, and a completed Statement of Compliance page noting no work was performed. The report is added to your project's payroll history, maintaining an unbroken record from project start to finish.

Frequently Asked Questions

Do I have to submit a WH-347 for weeks with no work on the project?

It depends on your contract. Many federal construction contracts require a no-work certified payroll submission for every week during the active contract period, even when no workers were on site. Read your contract's certified payroll clauses carefully. If the contract is silent, ask the contracting officer in writing. Erring on the side of submitting is almost always the safer choice.

How do I fill out the WH-347 for a no-work week?

Complete all header fields normally (project name, contract number, week-ending date, sequential payroll number). Leave the worker rows blank or write 'No Work Performed This Week' across them. All totals should be zero. Sign the Statement of Compliance on page 2, noting in writing that no work was performed during the referenced week.

Do I still need to sign the Statement of Compliance for a no-work week?

Yes. The Statement of Compliance is still required for no-work submissions. In this context, you are certifying that no work was performed on the project during the referenced week. The signature requirements are the same — it must be signed by an owner, officer, or someone with written delegation authority.

What happens if I miss a no-work week submission?

A missing no-work submission creates a gap in your certified payroll record. During a DOL audit, the auditor will flag it and ask for documentation showing no work occurred. If you can provide site logs, photographs, or other evidence, the gap is typically resolved administratively. If you cannot document the no-work status convincingly, the auditor may treat the week as potentially unverified work and expand the review.

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