DCAA compliance is about following its recommendations and guidance 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. Note that this means that the submitted timesheets become legal documents of the company.
The primary area of emphasis includes:
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 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.
Also, there is 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.
More information on DCAA Small Business Labor Evaluation .
According to research done by Microsoft, no silver bullet solution guarantees compliance with the DCAA. Instead, contractors need to:
Following are the general guidelines (but not limited to) for an accurate time tracking system to comply with the DCAA audits
All work hours should be filled in and saved by the end of each working day. OfficeClip Timesheet has a DCAA option and when enabled creates a prompt for the user to save time daily. Manager can also create a report of all time recorded.
Changes to the recorded time should automatically prompt the employee to write a reason code. This reason code is then recorded in the timekeeping history.
DCAA mandates clearly defined procedures and instructions for accurately reporting regular and overtime hours. Organization must put checks and balances in place to catch mistakes and fraudulent time entries.
Organization has responsibity to assign work items to employees and make sure that they only bill time on their assigned items.
Rules can be set in OfficeClip timesheet to keep track of daily and weekly limits employee can work.
When the DCAA mode is switched on, all changes to the timesheet are recorded. The recording shows the previous value (before change) and the new value (after change).
An auditor may be able to see the history of all changes made to the timesheet. The system should be able to create reports regarding the employee timesheet to make sure that they are filled in a timely fashion.
In an adequately audited electronic system, the signature is equivalent to user signing into the system using password and system storing all events in a non-editable format. OfficeClip follows this principle. Also, timesheets can be printed out and physically signed by the supervisor if needed.
OfficeClip allows additional documents to be scanned and stored along with the timesheet for future reference.