WORK AT HOME TIMESHEET REQUIREMENTS - FAR PART 31 COMPLIANCE

Timesheet Compliance in a Work-at-Home World

Government grantees and contractors from the NIH, NSF, DoE and DoD must properly record timesheets in accordance with FAR Part 31.  Improper timesheets can trigger an audit finding or worse. With so many employees working from home after the COVID-19 pandemic, how do you assure timesheet compliance? Here are some tips from the government accounting experts at JamesonCPA.

Create a Written “Work at Home” Timesheet Policy

During a government audit —and it doesn’t matter if it’s a Uniform Guidance Audit or a DCAA audit—you must assume that the government is looking for written proof that work is being performed as stated in your funding award. A written Work at Home (WAH) timesheet policy demonstrates that you know the regulations, you understand your responsibilities, and you’re committed to getting it right.

Your Work at Home timesheet policy can be fairly simple, but it must document how management gets comfortable that actual work is being performed by your employees when the work is happening remotely. An example of a Work at Home Policy would include:

• A statement of who is eligible to Work at Home (and for how long).
• Timesheet controls for WAH employees. For example: All timesheets must be submitted to the supervisor each week for signature and approval.
• A description of how you supervise WAH employees and their productivity, such as:
  • 2x/week phone call check ins
  • 1x/week review of physical work product
  • Any other action that management takes to make sure that employees are actually producing work defined in the funding award

Keep Records of Work at Home Timesheet Compliance

Just because you have a good Work at Home timesheet policy, doesn’t mean you follow it. To ensure your company is complying with the WAH timesheet policy, you should maintain written records to be able to demonstrate to an auditor that you’re doing what your policy states.  As examples:

• If you use Microsoft Teams, record some of these check ins
• If you primarily communicate through email, save these written interactions
• Maintain employee meeting attendance records
• Keep samples of work product through its evolution, not just the final work product

In the work at home world, the most important thing to keep in mind is that the government is skeptical that their investment is being spent properly. Creating a written WAH policy and maintaining records will ensure FAR Part 31 compliance and keep you out of trouble when questioned.

Learn More About Timesheet Requirements for FAR Part 31 Compliance

The best way to be sure your timesheets are on track is to visit our Learning Center, which contains numerous blogs, white papers, and videos that discuss timesheets and their importance.

Here are a few examples:

• To understand the difference between manual vs electronic timesheets, click here.
• To better understand uncompensated overtime and how it should be recorded, start here.

Ready to Learn More? Speak With A Government Funding Award Expert!
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