What a DCAA labor floor check examines
A labor floor check, also called a MAAR 6 activity, tests whether employees exist, are performing work in the expected labor classification, and are charging labor to the appropriate job or indirect account. DCAA says auditors may make an unannounced visit, interview employees, observe work, review timekeeping procedures, trace labor charges to contract requirements, and reconcile observations with payroll records.
The purpose is not to see whether employees memorized an audit script. It is to test whether the contractor's written process matches daily behavior and whether labor records can be connected to actual people, assignments, and accounting records.
The 12-point floor check readiness list
Use this list to test whether the process works now. A policy document is useful only when employees follow it and the supporting records agree.
- Every employee knows they are responsible for entering their own time daily.
- Employees can identify the work they are performing and the charge code used for it.
- Current work authorizations match project, task, CLIN, and labor-category assignments where applicable.
- Direct and indirect codes have clear descriptions and owners.
- All hours worked are recorded, not only billable or paid hours.
- Employees know how to report a missing code or incorrect authorization.
- Corrections preserve the original charge, corrected charge, reason, and employee concurrence.
- Employee certification and supervisor approval are separate, retrievable events.
- The written policy matches the system configuration and actual deadlines.
- Training records cover employees, supervisors, and administrators.
- Labor distribution agrees with approved time and reconciles to payroll.
- Prior exceptions and internal findings have named owners and documented corrective action.
Prepare employees to explain the real process
Employees should be able to explain when they enter time, how they find the correct code, what they do when a code is missing, how they correct an error, and who approves the period. The strongest answer is the employee's normal behavior supported by the current system record.
Do not hand employees a list of phrases to repeat. Scripted answers can conflict with the system, create anxiety, and conceal a training gap. Teach the policy, run ordinary practice scenarios, and correct the underlying workflow when an employee cannot explain it.
- What are you working on today?
- Which code are you charging, and how do you know it is correct?
- When did you enter today's time?
- What do you do if you make a mistake?
- Can your supervisor change your time?
- How do you record indirect work or uncompensated overtime?
- Where can you find the timekeeping policy and code descriptions?
Test correction evidence, not only current totals
Choose several timecards with corrections. Retrieve the version before the change, corrected record, reason, person who acted, timestamp, employee concurrence, and new approval. Confirm that downstream labor and payroll reports use the corrected approved version.
A current report with the right total does not prove the correction control worked. The test is whether a reviewer can follow the change without asking an administrator to reconstruct it from email.
Reconcile the observed labor to payroll and contract records
DCAA's floor-check description includes reconciling observed labor charges with payroll and tracing charges to contract requirements. Prepare a repeatable path from the employee's approved time to labor distribution, payroll control totals, job-cost or general-ledger records, and the applicable contract assignment.
Do not create a special audit spreadsheet that cannot be reproduced next month. Use the same reports and reconciliation the company operates each period, with retained evidence of review and resolved differences.
Include remote employees and secure-site exceptions
Remote work changes the observation method, not the need for a reliable record. Verify remote employees' assignments, availability, daily entry, authorization, and manager oversight. Make sure supervisors can explain how they know the recorded work occurred without inventing surveillance that is unrelated to the contract.
For secure facilities or locations without daily system access, test the approved alternate process. Retrieve the contemporaneous temporary record, transfer into the official system, employee certification, and review. The exception should be documented before it is needed.
Run a mock floor check with a traceable sample
Select employees from different contracts, indirect functions, locations, managers, and employment arrangements. Ask a neutral reviewer to interview them, compare responses with today's entries and authorizations, then trace selected labor through the closed-period records.
Record each result as pass, observation, or control failure. Assign an owner and due date. A mock exercise that edits the evidence until every sample passes defeats the purpose.
- Employee interview and same-day time record
- Work authorization and labor-category support
- Policy and training acknowledgment
- A normal approved period
- A period containing a correction
- Labor distribution and payroll reconciliation
- Open corrective actions from prior internal reviews
What to do during and after an actual visit
Follow the company's audit-response and visitor procedures, identify the authorized company contact, preserve requested records, and answer questions truthfully. Do not tell employees to change time or create records after learning who was sampled. If clarification is needed, distinguish a fact from an estimate and route legal or contractual questions to qualified advisers.
After the visit, log requests, documents provided, questions, observed gaps, and corrective actions. Preserve the records as they existed during the review. Treat the findings as process information rather than a search for someone to blame.