TimeSheet Reporting Policy

PURPOSE

This policy establishes procedures for accurate charging of labor, timesheet preparation, and maintenance of labor audit trails in accordance with the Federal Acquisition Regulation (FAR) in supporting cost charged to USG contracts.

POLICY

It is company policy to ensure the accurate accumulation of labor charges to (a) chargeable projects for the billing of direct labor and to (b) indirect / overhead charge numbers for accurate calculation of Overhead and General and Administrative (G&A) expense rates.

SCOPE

This policy applies to all Public Services employees and to Accounting and Finance and management personnel responsible for reviewing and monitoring labor accounting practices. It also applies to employees from other KPMG Consulting lines of business working on Public Services projects.

The U.S. government has established criteria for the charging of the direct and indirect costs allocable to government contracts, incurred or to be incurred. In ascertaining what constitutes a cost, the policies and procedures followed must result in determining or estimating costs that are equitable and are consistently applied. [FAR 31.201-1 -- Composition of Total Cost]

BASIC REQUIREMENTS

• Has established these labor charging policies and procedures

• Periodic Training

• Periodic internal reviews and floorchecks.

RESPONSIBILITIES

GovC management is responsible for the overall implementation of this policy. Specific implementation responsibilities include:

• Individual employees record their time daily and submit completed timesheets for supervisory approval.

• Management informs employees of the project charge number to use for direct labor work effort. On federal government contracts, a written authorization should be provided to the employee. This authorization can take the form of a copy of the proposal, a copy of the statement of the work (SOW), an e-mail message, or an internal memorandum.

• Management-level personnel review and approve timesheets to ensure the accuracy of all time charges.

• Management ensures that each new employee receives (a) a copy of this policy and (b) a certification statement to be electronically signed. The Employee Certification of Understanding of Government Contracting Labor, Expense Recording and Unallowable Costs Policies states that the employee has read, and understands and will comply with the policy.

PROCEDURES

All employees are required to enter time charges for all authorized work effort performed.

Labor charges are recorded in accordance with the following procedures:

• 1. Employees make labor entries for all approved hours worked on their timesheets on a daily basis on-line.

• 2. Employees record the appropriate direct labor project number or indirect charge number on the timesheet and the number of hours worked.

TRAINING

Management uses the following procedures for training:

• All present employees and new employees (a) receive a copy of this policy and (b) electronically sign the compliance certificate.

• Initial training is given during employee orientation.

• Periodic staff meeting and interoffice memos are used as reminders of proper timekeeping procedures. Additionally, refresher training, as required, will be held on any new compliance issues.

• Employees with questions concerning this policy may contact our Public Services Federal Controller, our Public Services DCAA Liaison, or our Director of Government Contracts Compliance for clarifications or any site-specific requirements.

COMPLIANCE

Management uses the following compliance techniques / procedures for internal reviews:

• Management level employees review and approve all timesheet charges.

• Management conducts periodic floorcheck reviews of timesheet preparation practices at work locations. These floorchecks involve (a) review of employees' timesheet entries, (b) observation of work currently being performed, and (c) interview of employees.

Appropriate corrective action will be taken if issues are identified as a result of these reviews.

SANCTIONS

Sanctions will be imposed for failure to follow applicable timesheet requirements. Sanctions may include employees put on a Performance Improvement Plan (PIP), financial restitution, termination of employment and / or legal action.