Friday, December 28, 2012

Work-at-Home (WAH) Programs

Many Government contractors have programs that allow employees to perform their work from home or from an alternative work site. There are advantages to such programs, reduced commuting time, less stress, and for the contractor, reduced overhead (assuming they can jettison some of their facilities). But with these WAH programs, comes a real need for internal controls to determine whether the program is effective. Government auditors are always concerned about potential abuse under WAH programs - many of them do it themselves and so, have first hand knowledge of potential risks, ineffective controls, and abuses.

Good internal controls over WAH programs should, at a minimum, address the following:
  • Eligibility and Status - Adequate policies should include a description of the type of work that may be performed at home. For example, work that must be closely supervised, requires access to non-portable equipment or depends on the frequent interaction with others, cannot be performed at home. Policies should also include the status of employees working at home (e.g. full time, part-time, temporary, etc.) and the employees' eligibility for benefits such as insurance and leave.
  • Approval policy, employee performance, work schedule and attendance. Contractor policies and procedures should require
    • proper advance approval by appropriate management officials,
    • continuing evaluation of the participating employee's performance in completing assigned tasks,
    • written documentation of the specific tasks to be performed along with the expected completion dates
    • that WAH employees attend periodic meetings at the contractor's work site to allow the employee and supervisor to discuss work progress, assign new tasks, and evaluate work performed, and
    • that WAH employees work a mutually agreeable set of core hours to allow management to have access to the WAH employee at designated times.
  • Timekeeping requirements - WAH employees hshould be required to submit timecards in accordance with the company-wide timekeeping system.

Contractors without the foregoing minimum controls will undoubtedly be cited for an accounting system deficiency with the potential for billing withholds.

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