A useful policy tells people exactly what to do
DCAA Manual 7641.90 says detailed timesheet-preparation instructions should be established through a timekeeping manual or company procedure. The policy should translate the contractor's accounting and labor-charging design into actions an employee, manager, and administrator can perform consistently.
Avoid a policy assembled from compliance phrases with no operational meaning. ‘Employees shall maintain accurate time’ does not define the daily deadline, authorized codes, correction route, certification, approval, absence exception, or consequences of repeated failure.
The 14 sections to include in the policy
The final structure should match the company, contracts, workforce, payroll schedule, and accounting system. These topics provide a practical baseline for a labor-heavy services contractor.
- Purpose, scope, effective date, policy owner, and covered workers
- Employee responsibility for personally recording complete time
- Daily entry deadline, time zone, and approved method
- Direct, indirect, leave, travel, and uncompensated-overtime treatment
- Work authorization and charge-code descriptions
- Rule that work performed—not funding—determines the charge
- Procedure for missing, unavailable, or incorrect codes
- Secure-site, outage, travel, and prolonged-absence exceptions
- Timesheet correction and employee-concurrence process
- Employee certification and supervisor approval
- Submission, approval, payroll, and period-lock calendar
- Segregation of duties and administrator access
- Training, acknowledgment, monitoring, and refresher requirements
- Escalation, corrective action, and disciplinary-policy references
State the daily-entry rule without ambiguity
Specify when employees enter time, what counts as the end of the workday, and how nonstandard schedules operate. Define whether an employee records time as work occurs or completes the day by a stated cutoff. Include remote workers and time zones.
Explain that the employee records all hours worked, whether paid or unpaid, against appropriate direct and indirect objectives. Coordinate uncompensated-overtime language with FAR 52.237-10 and qualified accounting or legal guidance when that provision or related practices apply.
Describe corrections as a workflow
The policy should distinguish an open-period edit, late entry, post-submission correction, and post-approval correction. State what reason is required, how the original remains visible, how employee concurrence occurs, and when certification and approval repeat.
Define period locks and the authorized exception path. Never make the practical instruction ‘ask payroll to fix it,’ because that moves employee labor without a consistent evidentiary trail.
Train employees, supervisors, finance, and administrators differently
Every person needs the common policy, but each role operates different controls. Employee training focuses on daily entry, complete time, authorization, corrections, and certification. Supervisor training adds review, rejection, delegation, funding-versus-charging boundaries, and reapproval after change.
Finance training covers labor distribution, payroll and ledger reconciliation, close, adjustments, and evidence retrieval. Administrator training covers privileged access, code configuration, effective dates, locks, audit history, and the prohibition on silent data repair.
Use scenarios instead of a slide-only acknowledgment
A signed acknowledgment proves attendance, not understanding. Ask each role to complete realistic cases in a training environment or controlled period.
- An employee splits one day between two authorized direct objectives and an indirect meeting.
- The expected project code is missing from the employee's list.
- A CLIN is near its funding limit, but the employee performed work for it.
- An employee discovers yesterday's wrong code before submission.
- Finance discovers a wrong code after approval and period lock.
- A manager is absent and a temporary delegate must approve.
- An employee works at a secure site without daily system access.
- A salaried employee works hours beyond the normal schedule.
Retain training evidence that can be tested
Keep the policy version, training material, date, instructor, attendees, role, assessment or scenario results, acknowledgment, and assigned remediation. When the policy changes, identify who requires refresher training and by when.
Connect the record to the employee lifecycle. New hires should complete training before charging live contract time. Newly promoted managers need supervisor training before receiving an approval queue. Contractors and temporary workers should be included when the company process applies to them.
Measure the policy in operation
Review late days, missing hours, unauthorized-code attempts, corrections, approval overrides, post-close adjustments, and repeated exceptions. Use trends to improve policy language, code design, deadlines, system configuration, and training.
A policy can be well written and poorly operated. Run periodic employee interviews and sample traces before an external floor check tests the same connection between procedure, work, time, payroll, and contract records.
Policy approval checklist
Before issue, have the people responsible for accounting, contracts, payroll, HR, security, and operations review the sections relevant to them. Obtain qualified legal or GovCon accounting advice where the policy touches wage law, uncompensated overtime, cost treatment, or contract interpretation.
- Every instruction names a responsible role and observable action.
- System settings match the deadlines, statuses, and permissions in the policy.
- Direct and indirect code descriptions match the accounting design.
- Exception procedures work for remote and secure-site employees.
- Correction, certification, approval, and lock scenarios have been tested.
- Training is scheduled by role and tied to onboarding and policy changes.
- Monitoring reports and corrective-action ownership are defined.
- The approved version is easy for employees to find.