What to Expect from a DCAA Floor Check

The objectives of a timekeeping system are to ensure that labor costs are accurately and timely identified as either direct or indirect in the accounting system.  For certain contract types (e.g. cost-type), these accumulated labor costs are reported and billed to the customer.  It is the contractor’s responsibility to ensure that the labor costs posted in the timekeeping system are proper and reliable. 

Timekeeping Policies

Timekeeping policies should be in place to ensure employees are informed of their responsibility when it comes to entering time each day.  The individual employee is the critical element for proper labor charging.  Internal controls should be in place to mitigate risk of fraud and waste in labor charging.  Audit of a company timekeeping procedures and practices is essential, whether the audit is performed internally or externally by DCAA.  Other elements such as materials, other direct costs, and subcontracts are supported by external “third party” documentation to determine and to support the billed amount to customers.  In contrast, contractor labor is only supported by internally (contractor) generated records.  Since there is a risk to the customer, timekeeping is a focus of DCAA.  Floor checks are DCAA’s method for “real-time” audit testing.  The purpose is to ensure employees are at work, employees perform the assigned job classification, and time (labor) is charged to the proper cost objective.   

The Floor Check

Before DCAA begins the Floor Check, the contractor’s timekeeping policy will be reviewed by the auditor.  A contractor’s timekeeping policy should have proper segregation of responsibilities for labor-related activities.  Clear instructions for timesheet preparation should be included in the policy.  Once the policy is reviewed, the auditor performs an analysis to determine risk indicators for potential mischarging.  An evaluation of the contractor’s government contract mix and recent labor distribution/payrolls are analyzed to determine high risk indicators.  DCAA expectations for a timekeeping system provided in the Information for Contractors are the following:

• Identifies employees’ labor by intermediate or final cost objectives – the timekeeping system should have the ability to track employees’ time spent on each work activity;
• A labor distribution system that charges direct and indirect labor to the appropriate cost objective – once an employee’s time is segregated the cost must be allocated to the appropriate cost objective.

DCAA will perform unannounced floor checks to determine the accuracy of the timekeeping system for reimbursement of labor under flexibly priced contracts such as cost reimbursable, time and material (T&M), and labor hour contracts.  Generally during a labor floor check the auditor will interview a randomly selected employee.  This employee will be asked a series of questions regarding timekeeping charging, such as:

• What is your job title? 
• What contract or task do you work on? 
• How do you charge your time?
• Were you given policies and procedures?  Do you have instructions on how to input time/fill out a timesheet?  Can I see your procedure?
• Do you prepare your own timesheet?
• Does anyone ever prepare your timesheet for you?
• How often do you prepare your timesheet?
• Have you been given timekeeping training?
• Who approves your time cards?  Does your supervisor sign your timecard?
• When are timecards submitted?
• Are you an exempt or hourly employee? Do you work on salary?
• Are you paid overtime?
• Do you record your time in excess of 40 hours?
• Do you record all your time?

Post Floor Check

After the floor-check interviews are complete, the auditor will compare their notes from the interview to the employee’s timesheet on the following payroll records to ensure labor costs were recorded accurately.  It is critical that employees are aware of the timekeeping policy and procedures to be prepared for DCAA floor check.  Mischarging time is illegal and could be considered fraud (violation of the False Claims Act).  The penalties for labor mischarging are fines and jail time.  Examples of mischarging are the following:

• Employees who fill in and sign the timesheets with false information;
• Supervisors who approve any timesheets with the knowledge that they contain false information;
• Managers and officers who know those facts and make the claim anyway by submitting the invoice based on the false timesheet;
• The company, in a case where the falsification is known by individuals who submit, or who have authority to submit, or disapprove the submission of invoices, or who are of a sufficiently high enough level in the company that the court will impute their knowledge to the corporation.

The manipulation of charges to a contract may be subject to criminal charges under 18 United States Code (USC) 1001.