Do timesheets have to be signed for labor charges incurred on a cost type contract to be paid?
For government contracts subject to Federal Acquisition Regulation (FAR) Subpart 31.2 (Contracts with Commercial Organizations), for a cost to be allowable, a cost must comply with all five of these requirements: (1) Reasonableness; (2) Allocability; (3) Standards promulgated by the CAS Board, if applicable, otherwise, generally accepted accounting principles and practices appropriate to the circumstances; (4) Terms of the contract; and (5) Any limitations set forth in Subpart 31.2.
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While the contract cost principles at FAR Part 31 do not contain any specific provision expressly requiring “signed” timesheets in order for labor charges to be allowable, signed timesheets (or “certified” timesheets) are often considered by contract auditors a necessary part of an acceptable labor cost accounting system. Absence of signed timesheets may therefore be a basis for a recommendation to the contracting officer to challenge the adequacy of a contractor’s labor cost accounting system and also to challenge the labor costs submitted without support of a signed timesheet for reimbursement under a theory that costs recorded as such are not adequately supported/documented.