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Time and Material Voucher Requirements


BorderC

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All,

I'm just curious what evidence contracting officers out out there are requiring and/or what contractors are providing to support clause 52.232-7 requirements.

My observation/experience is that the Government (where I am) asks for and has been satisfied to receive only a breakdown of direct labor costs by labor category, number of hours, and the contract rate.

For example:

SLC Hrs Rate Price

EN2 10 $10 $100

EN3 10 $15 $150

TOTAL 20 $250

That would be sufficient to pay the $250 (or $250,000 if it were the case).

The payment clause (52.232-7) states:

(5) Vouchers may be submitted not more than once every two weeks, to the Contracting Officer or authorized representative. A small business concern may receive more frequent payments than every two weeks. The Contractor shall substantiate vouchers (including any subcontractor hours reimbursed at the hourly rate in the schedule) by evidence of actual payment and by—

(i) Individual daily job timekeeping records;

(ii) Records that verify the employees meet the qualifications for the labor categories specified in the contract; or

(iii) Other substantiation approved by the Contracting Officer

I wonder, from your experiences, is it more or less common for the contractor to be required to submit the items from (i) and (ii) above? What other substantiation (iii) is commonly requested?

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BorderC,

From my contractor perspective, if you have a contract that contains 52.232-7, you should be prepared to comply with all of the clause requirements. Even if the CO does not request all the supporting documentation, you should collect it and be prepared to provide it upon request. Looking at recent headlines about companies facing allegations that they billed employees at improper labor categories, anybody who has a T&M contract should be thinking about that risk, and working to actively mitigate it.

If the CO doesn't specify any additional substantiation then I guess you don't have to worry about it. However, one area to consider might be evidence of CPE or certification refresher training when required.

Hope this helps.

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Although the contracting officer may not be asking for substantiation, remember that DCAA can audit the hours claimed. If you cannot support the hours claimed and show that they were worked by someone who meets the labor qualifications for the category listed, DCAA can question those hours.

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