Last Friday, we discussed the importance of internal controls for contractor Work-at-Home (WAH) programs. It is the Government's belief that only a subset of employees can effectively work out of their homes and for those who do work out of their homes, supervision, work assessments, and timekeeping become very important.
DCAA (Defense Contract Audit Agency) and other contract auditors routinely conduct floorcheck audits. These unannounced employee interviews are designed to ensure the propriety of labor charges to Government contracts. Typically, the auditor has already made a selection of individuals he/she wants to interview prior to the unannounced visit. What happens when one or more of these individuals are working at home?
Current audit guidance states that when an employee selected to be floor checked is not present at the normal work-site due to a work at home program, the auditor should interview the supervisor. Discussions with the supervisor should concentrate on
- obtaining evidence of the employee's work
- documented evidence of supervisory control over the employee's WAH schedule
After interviewing the supervisor, the auditor should also communicate with the employee by phone to
- determine if the employee has knowledge of WAH procedures
- discuss the specific type of work being performed along with the related labor charge numbers
Finally, the employees employment should be verified to the payroll/personnel records.
One question frequently asked by employees contemplating a WAH schedule is the likelihood of a home visit by a Government auditor. That would be weird and extremely unlikely. Nowhere in the audit guidance is there a requirement that the auditor visit the employee at his/her home.