What You'll Learn
- What Column 6B is on the January 2025 WH-347 (it is not gross wages)
- How to turn monthly plan contributions into an hourly credit
- How 6B differs from 6C, and why both exist
- The page 2 table that any amount in 6B triggers
- The annualization rule that disqualifies most miscalculated credits
If you learned the old form, read this first
The DOL revised the WH-347 in January 2025 and relettered the columns. On the old form, 6B held the gross amount earned on the project. On the current form that figure moved to Column 7A, and Column 6B is now the Total Fringe Benefit Credit. Putting gross wages in 6B on a current form overstates your fringe credit on every line, which is exactly the kind of discrepancy a wage investigator looks for. See our Column 7A and 7B guide for the gross figures.
What Column 6B Means
Column 6B on the January 2025 WH-347 is titled Total Fringe Benefit Credit. It reports the hourly value of the fringe benefits you provide through bona fide plans, funds, or programs, expressed as dollars per hour for that worker.
A Davis-Bacon prevailing wage has two parts: a basic hourly rate and a fringe benefit rate (40 U.S.C. 3141(2)). You may satisfy the fringe portion by contributing to bona fide benefit plans, by paying cash instead, or by any combination. Column 6B is where the plan side is reported. The cash side goes in Column 6C, Payment in Lieu of Fringe Benefits.
6B (plan credit per hour) + 6C (cash per hour) must be at least the fringe rate on your wage determination
Turning Plan Contributions Into an Hourly Credit
Benefit plans are usually billed monthly, but the WH-347 wants an hourly number. Divide the contribution by the hours it covers:
Hourly credit = monthly contribution per employee / hours worked that month
DOL's formal computation is annual: total annual contributions divided by total annual hours worked (29 CFR 5.25(c)(1)). A monthly figure divided by roughly 173 hours approximates it for a full-time worker, but the annual method is what gets tested in an investigation.
Annualization: the rule that voids most bad credits
Contributions for continuous benefits such as health insurance generally must be spread across all hours the employee works in the year, including hours on private, non-covered jobs. You cannot fund a year of premiums out of a few Davis-Bacon weeks and claim the whole cost against covered hours. That inflates the hourly credit and understates the wages owed.
One exception: defined-contribution pension plans that provide immediate participation and immediate or essentially immediate vesting (full vesting within 500 hours of work) are exempt from annualization under 29 CFR 5.25(c)(2), provided the plan also meets the other conditions in 29 CFR 5.25(c)(3).
What Counts as a Bona Fide Fringe
Creditable fringes include health and life insurance, pension or retirement contributions, vacation and holiday pay, and apprenticeship training funds, paid to a third-party plan, fund, or program (29 CFR 5.29). An unfunded plan, where you pay benefits out of general assets rather than an irrevocable third-party fund, may be credited only if it meets 29 CFR 5.28 and has been approved by DOL (40 U.S.C. 3141(2)(B)(ii)).
Payments you are required by law to make are never creditable fringes. Employer FICA, workers compensation premiums, and unemployment insurance are costs of doing business, not fringe benefits. Crediting them in 6B is one of the most common ways contractors end up owing back wages.
Worked Example
A Laborer's wage determination reads $38.00 base + $9.50 fringe. You pay $450/month toward health insurance and $120/month as a 401(k) match. The worker logs 173 hours that month.
- Plan contributions: $450 + $120 = $570/month
- Hourly credit: $570 / 173 hours = $3.29/hr to Column 6B
- Fringe still owed: $9.50 - $3.29 = $6.21/hr to Column 6C as cash
- Column 6A shows the $38.00 base hourly rate
Our free fringe benefit calculator runs this worksheet for you and shows the exact 6C shortfall each week.
Fringe Is Owed on Every Hour, at Straight Time
Overtime multiplies the basic hourly rate, not the fringe. Under CWHSSA and the FLSA, overtime is 1.5x the basic rate, while the fringe portion is owed at straight time on every hour worked, including overtime hours (29 CFR 5.32(a)). Your 6B credit therefore applies to all hours on the line, not just the first 40.
Any Amount in 6B Triggers a Page 2 Table
If you report a credit in Column 6B, page 2 of the WH-347 requires the Hourly Credit for Fringe Benefits table: each plan listed by name, whether it is funded or unfunded, and the hourly credit per worker. The fifth blanket certification checkbox on page 2 covers fringe benefits. Leaving 6B filled but the table blank is an incomplete certification, and it is a routine audit finding.
Common Column 6B Mistakes
Reporting gross wages in 6B
The single most common error since the January 2025 revision, usually from muscle memory or from guidance written for the old form. Gross earned on this project is 7A; gross for all work is 7B.
Crediting legally required payments
Employer FICA, workers comp, and unemployment insurance are not fringe benefits and cannot appear in 6B.
Skipping annualization
Dividing an annual premium by covered hours only, rather than all hours worked, inflates the credit. Under-crediting the cash in 6C then produces a back-wage liability on every hour.
Filling 6B and 6C for the same dollars
A dollar is credited once. Plan contributions go in 6B; cash paid instead of benefits goes in 6C. Reporting the same amount in both overstates what the worker received.
Related Columns
Column 6B sits beside Column 6A (Hourly Wage Rate) and feeds the totals in Columns 7A and 7B. For the whole form field by field, see our line-by-line WH-347 instructions and the fringe benefit calculation guide.
Automate Your WH-347 Math
Enter hours, rates, and plan contributions once. CertifiedPayrollPro computes the 6B credit, the 6C shortfall, and the page 2 fringe table automatically.
