The term ‘DCAA compliance’ when referring to your timekeeping procedures is often just thrown around. But what is DCAA compliance, and what does it mean for your business? If you don’t understand what that means, Keep reading this blog post for assistance for keys to understanding DCAA Compliant Timekeeping
What Is the DCAA?
What does DCAA stand for? Simply put, DCAA stands for Defense Contract Audit Agency. This is the federal government agency responsible for conducting DCAA audits of the Department of Defense (DoD) contracts. Its purpose is to review all contracts with outside vendors and suppliers to ensure that taxpayer money is being spent in the most appropriate manner. With approximately 7,500 contractors being reviewed and audited every year, the agency’s responsibilities are substantial making Understanding DCAA Compliance critical for government contractors.
As imagined, the DoD is very strict about its rules and regulations surrounding DCAA compliance and timekeeping. The DoD will award government contracts to businesses that use web-based timekeeping if they meet all requirements.
For companies seeking government contracts, adhering to the DCAA requirements is imperative. Those that are found to be noncompliant with the agency’s standards run the risk of being hit with significant penalties. These run the gamut from termination of contracts to fines to prison time depending on the severity of the infractions. One of the most severe consequences of noncompliance is debarment, which means the contractor in question is no longer allowed to be considered for future federal contracts.
What Is an Audit and How does it Relate to Understanding DCAA Compliance?
Audits and reviews are the primary method the DCAA uses to determine whether or not a contractor is complying with the appropriate standards. What is a DCAA review? These typically examine a wide range of items, including direct costs, indirect cost pools, allowable costs and more.
There are a wide range of audits that a contractor may be subjected to, depending on the nature of the standards being looked at and the possible infraction. For example, audits may include:
- Pre-award surveys — These reviews are conducted primarily to determine whether or not the contractor’s accounting system is up to DCAA standards. They typically involve the contractor demonstrating the system for an auditor.
- Forward pricing — Under this type of audit, the DCAA evaluates the contractor’s estimate of the project’s cost. They are usually performed before the contract is awarded.
- Incurred costs — These audits determine how accurate a contractor’s annual allowable cost representations are. This is performed after the awarding of the contract to ensure what the contractor has estimated the costs to be is truly what was quoted.
Keys to Understanding DCAA Compliance
Referring to Federal Acquisition Regulation and Cost Accounting Standards, respectively, FAR and CAS are rule sets used by the DCAA to establish its standards. FAR represents the guidelines for government procurement and is used by all federal agencies whenever purchasing goods or services. On the other hand, CAS refers to the rules used to establish consistency for government contractors’ cost accounting practices. This includes outlining how charges to contracts can be made and exactly what can be charged to them. Both of these frameworks inform and influence the DCAA regulations. Keys to Understanding DCAA Compliance are below.
1. The company must document all timekeeping procedures in a policy or procedure handbook.
The employee handbook must address all critical elements of an adequate timekeeping system. Companies must provide all employees with an up-to-date policy or procedure handbook regarding time entry procedures.
2. Every employee must record all of his/her time daily.
Attempting to track time worked in advance or days after the fact is not acceptable. Hour Timesheet comes equipped with reminders and alerts to ensure employee time is entered daily. This means that no matter the size of the company, Hour Timesheet is equipped for every employee to track time. This DCAA timekeeping feature is especially useful for any companies participating in SBIR and STTR programs. They may be smaller businesses, but they must ensure they remain DCAA compliant to qualify for their funding.
3. All employees must record 100% of the time worked.
Whether working on a government contract or commercial work, all time worked must be accounted for. With the Hour Timesheet mobile app the employees and 1099’s can add time from anywhere, whether they’re working from home or the office.
4. Employees must record all indirect time not identifiable to a given project to proper indirect cost accounts (Overhead, G&A, B&P, R&D, etc.)
One example of an indirect cost is overhead. This usually includes the indirect costs involved in support operations or direct production. These costs are directly related to a project or projects. However, they cannot be allocated to one specific contract. This is because they overlap across many different projects.
5. Employees must record all PTO, vacation, sick, holiday, and other leave time to the proper leave accounts.
Hour Timesheet allows for leave tracking any kind
6. The system administrator(s) should initiate all job codes that appear in the timekeeping system.
Charge codes must be provided to employees authorized to work on a given project.
7. All timesheet entries must be recorded by the employee.
An employee must record their time based on work completed. They should track all time entries, irrespective of whether the time is billable or non-billable. This must happen daily.
8. Employees must charge to the appropriate project
Whenever the employee completes work or tasks, they must charge it accurately and directly to that project. Hour Timesheet can be setup to restrict which codes an employee can charge their time; therefore, an employee cannot charge to a project they have not been assigned.
9. Employees may not work on indirect tasks and record time as direct costs
An indirect task is work that is not explicitly tied to a project. To remain DCAA, compliant employees must never charge the time it takes to complete these tasks to any project. This would violate DCAA compliance and regulations.
10. The employee is required to initiate all correction timesheet entries.
The employee must record all corrected timesheet data that includes a detailed audit trail. An audit trail is critical to remaining DCAA compliant.
The employee’s supervisor must approve every correction time entry in a detailed report, in the event of a DCAA audit.
In the unusual circumstances where the employee cannot make the changes to timesheets, then the HTS administrator may make such changes with the employee’s consent. The DCAA may analyze each entry on an employee’s timesheet. Thanks to your detailed audit trail, the DCAA will see who edited a time card after it was submitted. They will also be able to see when the changes were made, and why. Hour Timesheet creates an un-editable audit log that proper documentation. This activity log will include all of all the additions, deletions, approvals, and modifications made to your employees’ timesheets.
11. The employee’s supervisor must approve all employee timesheet data.
Each timesheet requires two signatures, in order to comply with DCAA compliance regulations. Hour Timesheet allows for online signatures at both the employee and manager levels.
12. All employees should be provided documented timekeeping training.
The company’s employee handbook or new-hire orientation program typically includes this training. Either way the employee should become familiar with the company’s timekeeping policy before they begin working.
13. In order to be DCAA compliant, the company must retain timesheet data for at least two years.
That means the company must be keep their files in a secure and easily accessible location. Should the DCAA require you to produce copies of your timesheets, they should be available. Hour Timesheet keeps the timesheets indefinitely for all employees, current, and past.
14. The company must conduct audit or floor checks randomly throughout the year to monitor employee timekeeping compliance.
Unfortunately, not knowing the keys to understand DCAA timekeeping compliance is one of the primary reasons government contractors fail an audit. Hour Timesheet can help. We have the employee and contractor time tracking experience to ensure total compliance. Sign up for Hour Timesheet today and work with an experienced implementation rep to review your account for total compliance. All for FREE.
We Can Help
What is DCAA accounting, and how can you ensure your organization is in compliance? Choosing Hour Timesheet’s solutions for your timekeeping provides you with a DCAA-compliant answer that is easy for you and your employees to use. Our simple, real-time time-tracking platform gives you the tools and resources needed to stay compliant and prepared for any audits that might come your way. To learn more about our software the Keys to Understanding DCAA Compliance and what it can do for you, reach out and speak with one of our representatives today.