Labor Category Audit and Communication Tips

When most people hear the word “audit”, they think of “accounting”.  However, it is important to remember that companies can be audited by the Government for labor category qualifications for Time and Materials (T&M) contracts. If the employee does not qualify for a labor category, the company will have to reimburse the Government for the difference between amount billed and amount that should have been billed depending on actual labor category qualification. Here is one process for handling Labor Category Qualifications.

1) Keep a log that includes at a minimum:

▪ Candidate/employee’s name
▪ Contract number
▪ Desired labor category
▪ Qualification requirements (education and experience)
▪ Education achieved (H.S., AA Degree, BA/BS, Master’s, PhD)
▪ Years of experience
▪ Approved (Yes/No)
▪ Reviewer for accountability reasons
▪ Date of approval/non-approval

2) Complete a form that includes the information from the items listed above and attach this to the candidate’s/employee’s resume.

3) Forward/E-mail the completed form and resume to HR before a candidate is hired or an employee is promoted.

4) Keep a soft and hard copy of the documents for the contractual records. For the hard copy, I recommend that you keep a notebook. Create a separate section for each contract and/or task order.

Communication: Tips, Tools, and Reminders

1. Do you have meetings on a regular basis regardless of whether its weekly, monthly, or quarterly? If so, you are on the right track to communicating effectively. While e-mail is vital to communication in today’s business world, you may not be receiving the entire message. According to Dragonbridge Corporation, only 7% of communication is words. Fifty-five percent of communication is body language, and 38% is tone. Most people have heard or read similar statistics. However, I mention this as a reminder because it’s important that while e-mail is crucial for documentation; meeting (preferably in person) allows one to relay information more clearly and allows others to provide feedback and ask questions for clarification.

2. As the Program Director, CEO, CFO, etc. do you cancel meetings when you do not have updates? While perhaps you do not have anything to report, you can use this opportunity to listen to others. Listening motivates employees, develops/enhances trust, reduces conflict, and helps you gain information about the project, competitors, and/or the customer (Janet Tingum, Demand Media). Ironically while one may have “no news”, there’s still an opportunity to learn. Moreover, it is somewhat presumptuous to conclude (before listening) that no one on the Team has ideas, comments, or questions. Next time try NOT cancelling that meeting and see how much valuable insight you gain.

3. Media is one effective communication tool. I connected on LinkedIn with Eileen Kent, who is the Federal Sales Sherpa. Eileen Kent has trained over 10,000 nationwide on federal sales, proposal writing, GSA schedules and contract vehicles. On the Federal Sales Sherpa Show, Eileen interviews experts speaking on various subjects regarding how to sell to the Federal Government. The show is mainly designed for Federal Contractors who are in their first few years of selling to the federal government. Go to the following link and listen to previous interviews The Federal Sales Sherpa


This blog is for informational purposes only. None of the content is, or will be deemed to constitute legal opinions or legal advice.

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