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Threshold to self-report billing error in cost-reimbursement research subcontract

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While conducting an audit of labor charges to a federal cost-reimbursement research contract, contractor discovered that one invoice contained time that was not properly reviewed and approved by the principal investigator. The company has detailed policies and procedures related to labor charging and all the steps were followed with the sole exception of getting contemporaneous sign-off by the PI before submission of the invoice for reimbursement. The unapproved time for for one researcher, two weeks, roughly 24 hours.

Company is a subcontractor to higher-ed institution that has a DARPA contract. 

Company wants to know whether they should report the error to the prime and/or DARPA. They also want to know whether they should deduct the same value of that time from their next invoice. 

This seems like a small error, but this company wants to get it absolutely right. What should they do?

Thank you!


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Is there a thought that the hours were in any way incorrect? If not it's hard to see how the invoice was in any way a "false" claim. However, if the company wants to be cautious it can convert the hours to nonbillable and reflect the credit in the next billing cycle.

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