In the previous two articles in this series we looked at what is required for a DCAA timekeeping system and what types of systems will meet these requirements. Today I want to look at how the DCAA monitors these systems and what you, as a government contractor, might expect to be compliant. I think you can fairly assume that any time the government comes to your facility to do an audit (pre-award audit, system audit, or other) that they will be interested in looking at your timekeeping system. But there are also other types of ways that they will check up on contractors timekeeping systems. This is usually called a Labor Floor Check. This is where a DCAA auditor shows up at your facility unannounced and randomly samples a few employees and checks for their understanding of the system and how they fill out their timesheets. They have a detailed audit program that they follow from their Contract Audit Manual and it could be worth while to familiarize yourself with exactly what they might be looking for. They will be looking for standard stuff like is the employee actually at work, do they know what to charge their labor to, are they recording their labor times daily, do they know the company procedure for timekeeping and are they following it. There are also guidelines for the auditor to follow if you have remote employees or "work at home" employees. These two areas are possible areas of misuse and of keen interest to the auditor. You can be certain that if the auditor finds dicrepancies that your contracting officer will hear about it. If you cannot resolve these findings with the auditor and/or contracting officer, there can be serious consequences. All the more reason to make sure your timekeeping system is a good system and you have trained employees to use it properly.
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