Daily vs. After-the-Fact Time Entries — Why DCAA Treats Them Differently
Most timekeeping findings in DCAA labor reviews come down to one issue: time that was entered well after the work was performed. The rule sounds bureaucratic — "enter time daily" — but it is grounded in a specific, defensible principle.
Why "daily" is more than a preference
Federal cost principles (FAR 31.201-2) require labor costs to be supported by adequate records. DCAA's working definition of "adequate" is contemporaneous — records created close enough in time to the work that they are presumed accurate.
Three things change when an entry is made the same day vs. days later:
- Anomaly detection. A 10-hour day charged to a single contract while the employee was actually on PTO is easy to catch in the moment. It is much harder to reconstruct three weeks later.
- Memory. Most people cannot reliably reconstruct task-level time after even 48 hours. After a week, the reconstruction is essentially educated guessing.
- Evidentiary weight. A timestamped, contemporaneous entry carries a much stronger presumption of accuracy than a backfilled one — both in DCAA's eyes and in any subsequent dispute.
When DCAA reviews labor, they are not just checking whether the hours are right. They are checking whether your process would have produced the right hours regardless of who reviewed them.
What "daily" actually means
DCAA does not publish a literal hourly deadline. The working interpretation that survives review is:
An employee should record their time by the end of the workday in which it was incurred, or — at the absolute outside — by the end of the next workday.
Beyond that, the entry stops being contemporaneous. If you allow week-long lags, you should expect a finding.
A few practical lines we recommend customers draw:
- Same-day entry is the standard. Make it the only path for normal entries.
- Next-day entry is the tolerated exception. Out-of-office, illness, system outage — fine, but logged as an exception.
- Anything later is a correction. Treat it as such: it gets a reason code, who made it, when, and an audit-trail entry. The original blank stays visible.
That last point matters: a correction is not the same as backfilling. A corrected entry leaves a paper trail. A backfill that looks like an original entry does not — and that is the practice DCAA finds.
What to put in your policy
A defensible written policy on time entry covers four things:
- The rule — daily entry, end of next workday at the latest.
- The exception path — what counts as a legitimate late entry and how it gets logged.
- Corrections — how an after-the-fact change is made, what is preserved, and who approves it.
- Supervisor responsibility — supervisors must surface late or absent entries within the same pay period, not at audit time.
If your policy reads "employees should submit time weekly," update it. That phrasing alone has been cited in actual DCAA labor system findings as evidence the contractor's process did not require contemporaneous records.
A small system test
Pull last month's records. For each entry, compute the difference between the workday and the entry timestamp.
- 90%+ same day: healthy.
- 80–90% same day: tighten the policy and the reminders.
- Below 80% or any week-long lags: you have a finding in waiting.
Informational only — not legal or audit advice. Specific contract terms and the CO/ACO's interpretation always govern.