DCAA timekeeping checklist

Assess each timekeeping control

Written procedures and trainingEmployees know how to enter, correct, certify and approve time, including exceptions.Evidence: Current policy, procedure, training materials and attendance records.

Employee-owned daily entryEach employee records their own time at least daily, with a documented exception procedure.Evidence: Sample daily entries, missing-time exceptions and employee attestations.

Work determines the chargeThe work performed—not funding or a desired budget result—determines the cost objective.Evidence: Work authorization tied to sampled employee charges and contract work.

Current code descriptionsEmployees can refer to maintained project, contract and indirect-code descriptions.Evidence: Authorized code list, descriptions, effective dates and access records.

All hours are recordedThe process captures all hours worked, whether paid or unpaid.Evidence: Complete-day reports, indirect codes and uncompensated-overtime treatment.

Supervisor entry is restrictedA supervisor prepares an employee timecard only under a documented, limited absence procedure.Evidence: Exception log showing actor, reason, employee concurrence and replacement record.

Corrections preserve evidenceThe original charge, corrected charge and employee concurrence remain retrievable.Evidence: Original value, corrected value, reason, actor, timestamp and reapproval history.

Certification and approvalThe employee certifies the period before the supervisor approves it.Evidence: Separate employee certification and supervisor approval with timestamps.

Responsibilities are separatedTimekeeping, payroll, employee entry and budget supervision are separated where practicable.Evidence: Role matrix, access permissions and tested separation of incompatible actions.

Labor distribution reconcilesHours and dollars by employee and cost objective reconcile with payroll and accounting records.Evidence: Labor distribution, payroll register, cost ledger and documented reconciliation.

Control maturity review

0/10Documented

0/10Operating

0/10Evidence ready

Prioritized next actionDocument: Written procedures and trainingExpected evidence: Current policy, procedure, training materials and attendance records.

This educational assessment is not DCAA certification, a compliance score, an audit opinion, legal advice or a review of your complete accounting system. Use the actual contracts, policies, controls and qualified advice applicable to your company.

What this checklist actually measures

This checklist reviews the timekeeping and labor-charging controls described in DCAA contractor guidance. It does not declare a company compliant, predict an audit result or evaluate the complete accounting system. Each control is reviewed at four practical stages: not established, documented, operating and evidence ready.

The distinction matters. A written policy is not the same as a control employees follow every day, and a control that operates is difficult to defend if the company cannot retrieve the relevant authorization, timecard, correction, approval, labor-distribution or training evidence.

Not established: the control is missing or the company has not verified it.
Documented: the policy, procedure or responsibility is written down.
Operating: employees and managers follow the control in normal work.
Evidence ready: the company has tested the control and can retrieve supporting records.

How to complete the assessment

Select the lowest status that is fully true for each control. If a policy exists but daily practice is inconsistent, select documented—not operating. If the workflow works but no one has tested whether the records can be produced, select operating—not evidence ready.

Ask a person outside the day-to-day timekeeping process to challenge the answers. For example, choose an employee and pay period, then trace the employee's work authorization, daily entries, corrections, certification, approval, labor distribution and payroll reconciliation. Record the missing evidence instead of assuming it exists.

Why there is no percentage compliance score

The controls are related and they are not equally weighted in every contract or audit. Nine documented controls do not compensate for managers silently rewriting employee time, and a perfect timekeeping workflow does not make an inadequate general ledger or cost-accumulation system acceptable.

The result therefore shows maturity counts and names the next control to advance. Use it to create an action plan, assign owners and test evidence—not as a certification badge for a proposal or customer.

What to do after all 10 controls are evidence ready

Run a mock labor floor check and repeat the trace across several employees, locations, managers and contract types. Confirm that employees can explain how they select charge codes, record all hours, correct an error and respond when they cannot access the normal system.

Then connect the time records to the broader accounting system. Labor distribution should reconcile hours and dollars with payroll and cost-accumulation records. Review direct and indirect cost segregation, contract cost accumulation, unallowable-cost treatment and the other criteria that may apply to the specific award.

Questions and definitions

Frequently asked questions

Does completing this checklist make a company DCAA compliant?

No. DCAA does not approve timekeeping products or certify a company through this checklist. Adequacy depends on the contractor's policies, actual practices, records, accounting system and applicable contract requirements.

Who should complete the checklist?

A controller, finance leader, contracts leader or operations owner can coordinate it, but employees, supervisors, payroll and accounting personnel should validate the controls they perform. An independent internal reviewer makes the result more credible.

How often should the controls be reviewed?

Review them before the first applicable award, after material policy or system changes, during employee and manager refreshers, and on a recurring internal-control schedule. High-risk contracts may justify more frequent sampling.

What evidence should be retained?

Typical evidence includes written procedures, training records, work authorization, charge-code descriptions, daily timecards, original and corrected entries, employee concurrence, certifications, approvals, labor-distribution reports and payroll reconciliations.

Primary sources

Review the executed contract and current official guidance before using a result for a compliance, accounting or contractual decision.

DCAA timekeeping checklist for government contractors