Paper 03 of 13

Timekeeping deficiencies are themost common DCAA finding.They are also entirelypreventable — by architecture.

12 min reading time
Compliance Mechanics

Timekeeping and Labor Distribution

"Timekeeping adequacy is not a training problem or a policy problem. It is a system architecture problem. Either the system enforces contemporaneous entry at the point of submission, or it does not. Policy cannot substitute for architecture when DCAA tests entry timestamps."

Paper 3 covers the complete operational mechanics of DCAA-compliant timekeeping: the contemporaneous entry standard, contract-specific LCAT validation, supervisor approval workflow requirements, correction procedure standards, and the labor distribution chain from time entry to cost pool.

DCAA examiners are trained to test what the system did, not what the policy said. For timekeeping, that means pulling system-generated entry timestamps and comparing them to the work dates charged. A timekeeping policy that requires daily entry but does not prevent late submissions from posting is invisible to DCAA examiners. The timestamp record is not.

What This Paper Defines

  • Policy says "enter time daily." System accepts any schedule.
  • LCAT validated by job title match against HR roles
  • Corrections allowed without preserved original value
  • Labor distribution performed in payroll or by journal entry
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The Argument

Why DCAA Tests Entry Timestamps — Not Policy Documents

DCAA examiners are trained to test what the system did, not what the policy said. For timekeeping, that means pulling system-generated entry timestamps and comparing them to the work dates charged. A timekeeping policy that requires daily entry but does not prevent late submissions from posting is invisible to DCAA examiners. The timestamp record is not. ""The contemporaneous entry requirement is not satisfied by a policy that says employees must enter time daily. It is satisfied by a system that records when the entry was made and enforces the daily submission requirement at the point of entry.""

The Correction Pattern Problem

One of the most consequential findings DCAA timekeeping auditors make is identifying correction patterns that suggest systematic non-contemporaneous entry. Common patterns include: corrections submitted consistently after a fixed delay (suggesting batch entry at end of week), corrections that consistently increase hours on high-rate contracts, and corrections submitted by supervisors rather than employees. These patterns are detectable in a complete correction audit trail and invisible in a system that allows corrections without preserving the original entry.

Timekeeping Adequacy — The Binary Test

Two questions determine timekeeping adequacy: (1) Does the system prevent non-contemporaneous labor charge entry by architecture, or by policy? (2) Can DCAA trace any labor cost on any invoice back to the original time entry, the work date, the approval, and any corrections — without manual reconstruction? If either answer is "by policy" or "with reconstruction," the timekeeping system does not satisfy the adequacy standard.

Daily
Contemporaneous entry standard
The standard DCAA tests on every timekeeping audit
#1
Most common DCAA finding type
Timekeeping deficiencies lead all adequacy finding categories
0
Retroactive corrections without trail
Every correction requires immutable justification and audit record
Contract
Specific LCAT validation required
Job title matching does not satisfy the adequacy standard

The Failure Modes

Four structural limitations identified in this research area.

Failure 01
Structural Failure

Non-Contemporaneous Entry

System accepts entries on any schedule. Policy says "enter daily." DCAA pulls entry timestamps. Policy compliance is invisible to examiners. Entry timestamps are not. Finding: timekeeping adequacy deficiency.

Failure 02
Structural Failure

Administrative LCAT Validation

System validates LCAT by job title match. Does not evaluate contract-specific qualification requirements. Employees with the right job title but wrong qualifications pass system validation and fail DCAA examination.

Failure 03
Structural Failure

Correction Without Immutable Trail

Corrections accepted without preserved original value, without timestamped justification, or by the same user who made the original entry. DCAA identifies correction patterns that suggest systematic retroactive reconstruction.

Failure 04
Structural Failure

Manual Labor Distribution

Direct/indirect segregation and cost pool allocation performed manually or by spreadsheet outside the timekeeping system. Manual distribution introduces misallocation risk and breaks the data lineage DCAA traces.

System Adequacy Requirements

The explicit structural capabilities verified by DCAA audits.

Requirement 01

Contemporaneous Entry — Architectural Enforcement

The system must capture the timestamp at the moment of entry and enforce the contemporaneous submission window by architecture.

  • Entry date and work date stored as separate fields
  • System-enforced deadline for same-day or next-day submission
  • Entries outside the window flagged or blocked before posting
  • Exception workflow requiring supervisor justification for late entries
  • Exception records captured in the audit trail with justification text
Requirement 02

Contract-Specific LCAT Validation

Every charge entry must be validated against the LCAT qualification requirements defined in the governing contract — not just the employee's HR job title.

  • Contract-specific LCAT qualification profiles maintained in the system
  • Education, experience, competencies, and clearance validated at charge entry
  • Charge rejected if employee does not meet contract qualification requirements
  • Validation performed against the live contract's LCAT framework
  • Validation record captured in the audit trail for every charge
Requirement 03

Immutable Correction Audit Trail

Every correction must generate an immutable audit record preserving the original entry, the correction, and the justification — before the correction is accepted.

  • Original entry value preserved — never overwritten
  • Correction requires employee-provided justification text
  • Correction timestamp captured at submission
  • Corrector identity and approver identity both recorded
  • SoD enforced — same user cannot make and approve a correction
Requirement 04

Automatic Labor Distribution

Direct/indirect segregation and cost pool allocation must be automatic and rule-based — derived from the time entry content, not from manual allocation decisions.

  • Direct labor allocated to contract/CLIN identified in the entry
  • CLIN ceiling validation performed at distribution
  • Indirect labor allocated to pools per CAS Disclosure Statement rules
  • Unallowable labor flagged and segregated automatically
  • Every distributed cost traceable back to its source time entry

The Architecture of Choice

Side-by-side comparison of structural assumptions and operational outcomes.

Policy-Based Timekeeping (Legacy ERP)

Policy says "enter time daily." System accepts any schedule.

DCAA pulls entry timestamps. The policy document is not evidence. The timestamp record is. Late entries create findings regardless of policy compliance.

LCAT validated by job title match against HR roles

Does not evaluate contract-specific qualification requirements. Noncompliant LCAT assignments pass system validation. DCAA examiners identify them during contract-specific LCAT review.

Corrections allowed without preserved original value

Original entry overwritten. No immutable justification record. DCAA cannot distinguish legitimate corrections from retroactive reconstruction. Both look the same in a system without immutable trails.

Labor distribution performed in payroll or by journal entry

Manual allocation decisions outside the timekeeping system. Traceability from cost pool to time entry requires reconciliation. Reconciliation gaps are potential findings.

Architecture-Based Timekeeping (xpdOffice)

System rejects non-contemporaneous entry before it posts

Timestamp captured at submission. Entries outside the contemporaneous window flagged or blocked. Exception workflow with immutable justification for documented exceptions.

LCAT validated against contract-specific qualification requirements at entry

Every charge validated against the governing contract's LCAT qualification profile — education, experience, competencies, clearance. Noncompliant charge rejected before posting.

Corrections generate immutable audit record before acceptance

Original value preserved. Justification required at submission. Timestamp, corrector identity, and approver identity all captured. SoD enforced — same user cannot make and approve.

Labor distributed automatically from time entry content

Rule-based distribution per contract type and CAS Disclosure Statement. Every distributed cost traceable to its source time entry. No manual allocation step. No reconciliation required.

Strategic Prediction

Strategic Insight

""The contemporaneous entry requirement is not satisfied by a policy that says employees must enter time daily. It is satisfied by a system that records when the entry was made and enforces the daily submission requirement at the point of entry.""

Frequently Asked Questions

How does DCAA test contemporaneous entry specifically?

DCAA examiners pull system-generated entry timestamps for a sample of time entries and compare them to the work dates charged. Entries where the entry timestamp is more than 24 hours after the work date (without a documented exception) are flagged as non-contemporaneous. The examiner then determines whether the non-contemporaneous entries are isolated exceptions or a systemic pattern. A systemic pattern produces a timekeeping adequacy finding that requires a corrective action plan and may trigger a formal system deficiency determination.

What is the difference between administrative and contractspecific LCAT validation?

Administrative LCAT validation checks whether the employee's HR job title matches the LCAT code being charged. It does not evaluate whether the employee meets the qualification requirements defined for that LCAT in the specific contract being charged. Contract-specific LCAT validation checks the employee's actual qualifications — education level, years of experience in the required discipline, technical competencies, and clearance level — against the requirements defined in the governing contract's LCAT matrix. Only contract-specific validation satisfies the adequacy standard. Administrative validation produces a system that passes its own checks and fails DCAA examination.

Can corrections ever be made without generating a finding?

Yes — but only when the correction system satisfies the audit trail requirements. The correction must preserve the original entry value, require a written justification, capture the correction timestamp separately from the original entry timestamp, enforce SoD (different users making and approving the correction), and produce an immutable record of all of the above. A well-documented correction with a complete audit trail is not a finding. A correction that overwrites the original entry or lacks justification is a finding regardless of whether the corrected entry is substantively accurate.

What does "automatic labor distribution" mean and why does DCAA care?

Automatic labor distribution means the system allocates labor costs to direct cost objectives and indirect cost pools based on rule-defined criteria derived from the time entry content — without any manual allocation decision. DCAA cares because manual labor distribution introduces the possibility of deliberate or inadvertent misallocation that is difficult to detect and reconstruct. Automatic, rule-based distribution produces a traceable allocation that DCAA can verify against the firm's CAS Disclosure Statement. Manual distribution produces an allocation that DCAA must verify against individual allocation decisions made at the time, which is both burdensome and unreliable.

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