DCAA Compliance for Timesheet

What is DCAA Compliance?

DCAA compliance is the process of following the DCAA recommendations and guidelines to remain compliant with federal law regarding government contracts. DCAA audits are driven by the rules outlined in FAR, CAS and GAGAS.

For timekeeping and accounting DCAA requirements need to be implemented in the organization to ensure prevention of fraudulent billing to the government. This means that the submitted timesheets become legal documents of the company and they must be accurate and complete with properly maintained accounting records.

The primary area of emphasis includes:

1. Internal control systems
2. Management policies
3. Accuracy and reasonableness of cost representations
4. Adequacy and reliability of records and accounting systems
5. Financial capability, and
6. Contractor compliance with contractual provisions having accounting or economic significance such as the cost principles

Timesheet is an important part of DCAA compliance because information generated from timesheets is also used for payroll, billing, project planning, cost accounting and pricing purposes.

DCAA Audits: What you need to know

• DCAA audits are conducted in accordance with generally accepted government auditing standards (GAGAS).
• GAGAS are a set of professional standards that govern the conduct of audits by independent auditors.
• DCAA audits are designed to provide reasonable assurance that contractor financial records are accurate and that contractor costs are allowable, allocable, and reasonable.
• DCAA has set up a goal of doing unannounced floor checks yearly (and sometimes as often as twice a year) at the government contractor site or the vendor work site. To comply with these audits, various guidelines are provided by the DCAA.
• During these checks, DCAA may talk to the employees and look at whether the timesheets are completed daily (and not done backdated or in the future).
• If there is a change made to the timesheet, they will like to see the reason for the change.
• There are also other contractor specific audits that may occur either in the proposal stage (generally for fixed-price contracts) or in project execution stage (for variable price contracts and Time and Labor contracts).
• These audits may cover accounting procedures, adequacy of the accounting systems etc.
• The DCAA's audits can result in a number of findings, including:
  1. Overpayments to contractors
  2. Unallowable costs
  3. Mismanagement
  4. Fraud
• The DCAA's findings are communicated to the DoD and to the contractors involved. The DoD and the contractors are then responsible for taking action to correct any problems identified by the DCAA.

The DCAA plays an important role in ensuring that the DoD receives the best possible value for its taxpayer dollars. By conducting audits of contractors, DCAA helps to protect the interests of the DoD and the American taxpayer.

More information on DCAA Real Time Labor Evaluations .

What should be the DCAA Compliance Criteria?

According to research done by Microsoft, no silver bullet solution guarantees compliance with the DCAA. Instead, contractors need to:

1. Invest in proper procedures that follow DCAA and FAR guidelines.
2. A well-designed procedure is more important than buying an expensive system that claims to do most of the things for you.
3. DCAA does not mandate the use of any timekeeping system for compliance.
4. Paper-based or Excel-based timesheets are equally good as long as they comply with the guidelines.
5. The only problem with paper-based or Excel-based timesheets is that they are difficult to maintain and become more expensive in the long run.

What happens when Contractors don't comply with the DCAA regulations?

There are several consequences for non-compliance with DCAA regulations which includes:

1. Civil penalties: The amount of penaltly will depend on the severity of the violation. Civil penalties can sometimes be as high as three times the government's loss.
2. Criminal penalties: are imposed for cases involving fraud or intentional misrepresentation. Criminal penalties can include fines, imprisonment, or both.
3. Debarment: means that the contractor is prohibited from doing business with the government for a period of time or even permanently.
4. Voided or terminated contracts: In some cases, non-compliance with DCAA regulations can result in the government voiding or terminating a contract leading to a damaged organizational reputation. This can happen if the contractor has committed fraud, misrepresentation, or other serious violations.

What are the Guidelines for DCAA Timekeeping requirements?

Following are the general guidelines (but not limited to) for an accurate time tracking system to comply with the DCAA audits

1. Create a clear and concise timekeeping policy document

   The formal document should outline the following regulations and guidelines. The policy should be easy to understand and should be distributed to all supervisors and employees.

2. Ensure that all supervisors and employees are familiar with the policy

   During audits, supervisors and employees may be asked to explain the guidelines they follow to test their knowledge of the policy. Employees should also be kept informed of any changes to the policy.

3. Timesheet must be filled in each day

   To ensure compliance with DCAA regulations, all work hours must be filled in and saved by the end of each working day. Managers can also generate reports of all time recorded.

4. Any change in already saved timesheet should also contain a reason

   When an employee changes their recorded time, they should be prompted to enter a reason code. This reason code will be recorded in the timekeeping history.

5. Clearly defined procedures and instructions for accurately recording work hours

   The DCAA mandates that organizations have clearly defined procedures and instructions for accurately recording regular and overtime hours. These procedures should include checks and balances to catch mistakes and fraudulent time entries.

6. Employees should only record time on assigned projects

   Organizations are responsible for assigning work items to employees and ensuring that they only bill time for work that is related to their assigned tasks.

7. The supervisor must approve all timesheet and log all changes

   When DCAA mode is enabled, all changes to the timesheet are logged. The log includes the previous value (before the change) and the new value (after the change).

8. Ability to create reports for auditor and managers

   An auditor can view the history of all changes made to the timesheet. The system should be able to generate reports on employee timesheets to ensure that they are completed in a timely manner.

9. All timesheet must be signed (manually or electronically) and a trail is kept

   In an adequately audited electronic system, a signature is equivalent to a user signing into the system using their password and the system storing all events in a non-editable format. Timesheets can also be printed out and physically signed by the supervisor if necessary.

10. Supplemental documents must be saved and can be produced to the auditors

    The system should allow users to scan and store additional documents along with the timesheet for future reference.

Choose OfficeClip DCAA Compliant Timesheet Software