DCAA floor check remote employees through phone calls, video conferences, and supervisory verification interviews, not physical walkthroughs. Amerifusion Bookkeeping advises every government contractor with remote or hybrid staff to treat virtual floor checks with the same urgency as an in-person visit. A 2024 DCAA Memorandum for Regional Directors formally authorized alternate interview techniques for telework employees, but the agency still expects the same level of timekeeping evidence it would collect on-site [DCAA Activity Code 13500].
The shift to remote and hybrid work is permanent for most GovCon firms. Census Bureau data shows 27.6% of U.S. workers teleworked at least part-time in 2025, and government contractors adopted hybrid arrangements at an even higher rate.
DCAA designed its floor check procedures for physical offices. Auditors walked corridors, matched faces to timesheets, and observed work in progress.
That model broke when half the workforce went home. DCAA adapted by allowing telephone and video interviews for off-site employees. But the agency never relaxed its standards.
It expanded its toolkit. Contractors who assume remote work reduces floor check exposure are making a dangerous bet. The auditor who once walked your hallway now dials into your Zoom.
What DCAA Floor Checks Verify (and Why Remote Changes the Equation)
A DCAA floor check serves two objectives: verifying employee existence and evaluating timekeeping internal controls. Auditors sample employees from contractor rosters, confirm those employees are working, and compare what they observe against timesheet records and labor distribution reports. For remote workers, the auditor replaces physical observation with a phone or video call, but every other verification step remains identical [DCAA Career Blog: Common Audits].
Remote work complicates three specific verification points. First, the auditor loses the ability to confirm physical presence visually. A phone call replaces direct observation, and the auditor must rely on the employee’s responses, supervisor attestations, and digital evidence.
Second, the auditor cannot casually observe whether work activity matches the contract being charged. In an office, an auditor sees an engineer at a workstation running simulation software. Remotely, the auditor asks questions and reviews documentation.
Third, supervisory oversight becomes harder to verify. DCAM Section 6-410 requires meaningful supervisory review of timesheets. “Meaningful” means the supervisor has direct knowledge of what the employee worked on.
When a supervisor sits 200 miles from the employee, the auditor will probe how that knowledge is obtained. Weekly status meetings? Daily standups? Project management tool logs? The auditor wants specifics, not assurances.
The DCAA Virtual Floor Check Process
DCAA’s 2024 Memorandum for Regional Directors, titled “Revised Procedures for Real-Time Audits of Labor and Purchase Existence and Consumption,” formally authorized telephone and video conferencing as alternate floor check techniques. The memorandum removed mandatory annual audit requirements (MAARs) for real-time labor audits and shifted to a risk-based approach for scheduling [Baker Tilly: DCAA Revised Procedures].
Three things contractors need to understand about this change. The memorandum created efficiency options, not relaxation of standards. DCAA explicitly stated it maintains “a preference for conducting in-person interviews and floor checks to the greatest extent possible.”
Virtual techniques supplement on-site visits. They do not replace them.
The risk-based scheduling model means contractors with weaker internal controls receive more frequent audits. Contractors with strong electronic timekeeping systems, documented policies, and clean audit histories get longer intervals between checks. The audit frequency is now a direct reflection of your system maturity.
During a DCAA virtual floor check, expect this sequence:
- Auditor contacts the contractor’s designated representative to initiate the floor check and request the current employee roster, active contract list, and timekeeping records for the audit period.
- Auditor selects a sample of employees from the roster, including remote workers, and schedules phone or video interviews. Interviews are typically unannounced to the employee, even if the contractor’s representative knows the check is occurring.
- Auditor interviews each selected employee by asking about current work assignments, charge codes, timekeeping procedures, supervisor approval processes, and whether the employee received written timekeeping instructions.
- Auditor compares interview responses against timesheets, labor distribution records, and the contractor’s timekeeping policy. Discrepancies generate documented findings.
- Auditor evaluates work-at-home controls specifically: Does the contractor have a WAH policy? Does the employee know the policy? Has the supervisor documented evidence of work performed?
Work-at-Home Policy Requirements for DCAA Compliance
Remote workforce DCAA compliance starts with a documented work-at-home (WAH) policy. DCAA auditors evaluate WAH programs as a distinct category during floor checks. A contractor with 50% remote staff and no written WAH policy faces a near-certain finding.
The policy is not a nice-to-have human resources document. It is an auditable internal control [Jameson CPA: WAH Timesheet Requirements].
DCAA expects a WAH policy to address five minimum elements:
| WAH Policy Element | What DCAA Expects | Common Deficiency |
|---|---|---|
| Written telework agreement | Signed agreement between employee and contractor outlining expectations, work schedule, and deliverables | No agreement exists, or agreement lacks specifics about timekeeping obligations |
| Documented evidence of work performed | Deliverables, project outputs, status reports, or work logs demonstrating productive work during charged hours | No work product evidence retained; contractor relies solely on timesheet entries |
| Supervisory review of remote work | Documented review of work output by supervisor with knowledge of assignments; review frequency specified in policy | Supervisor approves timesheets without reviewing any deliverables or work product |
| Periodic on-site presence | Requirement for the employee and supervisor to meet periodically at the contractor work site | Fully remote employees never visit the office; no in-person touchpoint documented |
| Timekeeping procedures for remote work | Specific instructions for how remote employees record time, report absences, and handle corrections from a home office | Policy references on-site timekeeping only; no remote-specific procedures exist |
The periodic on-site presence requirement catches many contractors off guard. DCAA expects remote employees to physically visit the contractor’s facility at a defined interval. Quarterly is a common standard.
This is not about productivity monitoring. It validates the employment relationship and gives the supervisor a direct observation baseline to support timesheet approvals.
Preparing Remote Employees for DCAA Floor Check Interviews
Every employee who charges time to a government contract must be ready for a DCAA floor check interview at any time. Remote workers face the same questions as on-site staff, delivered by phone or video instead of in person.
The difference: remote employees have no visual cues from coworkers, no supervisor in the next office to consult, and no preparation window. The call arrives cold.
DCAA auditors ask remote employees these specific questions:
- What is your current job title and labor category?
- What contract or contracts are you working on today?
- What charge code did you use for today’s time entry?
- How do you record your time? What system do you use?
- Do you enter your own time, or does someone enter it for you?
- How does your supervisor review and approve your timesheet?
- Have you received written timekeeping instructions from your employer?
- What do you do if you need to correct a time entry?
- Do you record all hours worked, including uncompensated overtime?
An employee who stumbles on charge codes, cannot describe the correction process, or says “my admin enters my time” creates an immediate finding. Training is the fix. Every remote employee needs to answer these questions fluently before the auditor calls.
Run mock floor checks quarterly. Select three to five remote employees at random, call them without warning during a workday, and ask the same questions DCAA asks. Document the results.
Fix gaps before they become findings. The 30-minute investment in a mock check prevents the 30-day headache of a corrective action plan.
Documentation and Technology Requirements for DCAA Timekeeping Remote Workers
DCAA timekeeping remote workers must satisfy every requirement that applies to on-site employees, plus additional documentation proving remote work occurred as recorded. The electronic timekeeping system becomes the primary evidence trail when physical observation is impossible. Contractors relying on paper timesheets for remote staff face a significantly harder audit [DFARS 252.242-7006].
Remote-specific documentation requirements include:
- Electronic timekeeping with timestamps. System logs must prove daily, contemporaneous recording. A remote employee submitting five days of time entries on Friday afternoon triggers the same finding it would on-site. The system must enforce daily entry deadlines or flag late submissions for supervisor review.
- VPN or access logs. Login records from the contractor’s network, project management tools, or collaboration platforms provide corroborating evidence that an employee was working during charged hours. DCAA auditors increasingly request these logs during virtual floor checks.
- Work product documentation. Emails sent, documents produced, code committed, reports filed. Each represents tangible evidence that work occurred. Contractors should establish a standard practice of retaining weekly work product summaries for remote employees.
- Supervisory review records. Document that the supervisor reviewed specific deliverables, not only the timesheet. Meeting notes, project status updates reviewed, and approval emails all serve as evidence of meaningful oversight. DCAM 6-410 requires meaningful review, and a rubber-stamp approval from 200 miles away is the opposite of meaningful.
- Video conferencing capability. DCAA auditors require video or phone access to remote employees during floor checks. Employees must have functioning technology and availability during normal work hours. An employee who cannot be reached during a virtual floor check is treated the same as an empty desk during an on-site visit.
A $4M IT services contractor in Northern Virginia passed a virtual floor check in 2025 because every remote employee could pull up their timesheet in under 60 seconds, name their active charge codes, and describe their current deliverables. The auditor completed 12 phone interviews in one morning. Zero findings.
The contractor’s secret was not sophisticated technology. It was quarterly mock floor checks and a written WAH policy employees had actually read.
Common Failures in Remote Workforce DCAA Compliance
Virtual floor checks reveal a predictable set of failures. These are the deficiencies auditors document most often during a DCAA floor check. Remote employees in hybrid organizations are particularly exposed.
| Failure | What the Auditor Finds | Prevention |
|---|---|---|
| No WAH policy | Contractor has remote employees but no documented work-at-home policy addressing timekeeping controls | Draft and implement a WAH policy covering the five elements above before the next audit cycle |
| Employee unreachable | Auditor calls a remote employee during charged work hours; employee does not answer and does not return the call within a reasonable time | Require remote employees to be reachable by phone during all hours charged to a contract; include this in the telework agreement |
| Charge code ignorance | Employee cannot state the charge code for the contract they are billing today | Quarterly training on active charge codes; post charge code reference sheets in project management tools |
| Batch time entry | System logs show remote employees entering entire weeks of time on Friday or Monday | Configure system to require daily entry; implement auto-reminders; flag batch entries for supervisor investigation |
| Supervisor rubber-stamping | Supervisor approves timesheets within seconds of submission without reviewing work product or verifying accuracy | Require supervisors to document specific deliverables reviewed alongside each timesheet approval |
| No corroborating work evidence | Timesheet shows 40 hours charged to Contract X, but no emails, deliverables, meeting attendance, or system activity supports it | Implement weekly work product summaries; retain VPN logs and collaboration tool activity records |
The “employee unreachable” scenario deserves emphasis. When an auditor conducts an on-site floor check and finds an empty desk, the finding is documented immediately. The virtual equivalent is an unanswered phone call during charged hours.
Contractors should treat phone availability during work hours as a non-negotiable term of the telework agreement.
Key Takeaways
- Virtual floor checks carry the same weight as in-person visits. DCAA’s 2024 memorandum authorized alternate techniques for efficiency. It did not lower the compliance bar. Phone and video interviews test the same knowledge and produce the same findings as a hallway visit.
- A documented WAH policy is now an auditable internal control. Any contractor with remote employees needs a written policy covering telework agreements, work evidence, supervisory review, periodic on-site presence, and remote timekeeping procedures. No policy means an automatic finding.
- Mock floor checks are the highest-ROI compliance investment for hybrid teams. Call three remote employees without warning, ask the standard DCAA questions, and document results. Thirty minutes of prevention eliminates months of corrective action.
- Remote employees must be reachable during all charged hours. An unanswered phone call during a virtual floor check produces the same finding as an empty desk during an on-site check. Build phone availability into every telework agreement.
- Corroborating evidence separates clean audits from findings. Timesheets alone are not sufficient for remote workers. VPN logs, work product, meeting records, and supervisory review documentation together create the evidence package DCAA expects.
Frequently Asked Questions
How does DCAA conduct a floor check for remote employees?
DCAA conducts floor checks for remote employees by phone or video conference. The auditor contacts employees at their home office during charged work hours, asks about current assignments and charge codes, verifies timekeeping practices, and compares responses against timesheet records and labor distribution reports. The auditor also evaluates whether the contractor has a documented work-at-home policy with appropriate supervisory controls.
Does DCAA require a work-at-home policy for remote contractors?
Yes. DCAA expects contractors with remote or telework employees to maintain a written work-at-home policy addressing five elements: a signed telework agreement, documented evidence of work performed, supervisory review of remote work output, periodic on-site meetings, and remote-specific timekeeping procedures. Contractors without a WAH policy face a near-certain finding during any floor check or labor audit.
What questions does DCAA ask remote employees during a floor check?
Auditors ask remote employees to identify their job title, current contract assignments, active charge codes, timekeeping system and procedures, correction processes, and whether they received written timekeeping instructions. The auditor also confirms the employee enters their own time daily, records all hours including uncompensated overtime, and understands the supervisory approval process.
Are virtual floor checks less rigorous than in-person floor checks?
No. DCAA’s 2024 memorandum authorizing telephone and video interviews was designed for audit efficiency, not reduced scrutiny. The agency explicitly maintains a preference for in-person checks and applies the same evaluation criteria to virtual interviews. Discrepancies in employee responses, missing documentation, and timekeeping control weaknesses produce the same findings regardless of the interview format.
What happens if a remote employee cannot be reached during a DCAA floor check?
An unreachable remote employee during charged work hours creates the same audit concern as an empty desk during an on-site floor check. The auditor documents the failed contact attempt and evaluates whether the contractor’s supervisory controls verify employee availability. Repeated unreachable employees signal a systemic oversight failure and trigger expanded audit scope.
How often does DCAA conduct virtual floor checks?
DCAA shifted from mandatory annual floor checks to a risk-based scheduling model in 2024. Contractors with strong electronic timekeeping systems, clean audit histories, and documented WAH policies receive less frequent checks. Contractors with weaker controls, new government contracts, or prior findings face more frequent virtual and in-person audits. No set schedule exists, and checks remain unannounced.
Get Your Remote Workforce Audit-Ready
Remote work is not going away. Neither are DCAA floor checks. The contractors who pass a DCAA floor check on remote employees are the ones who trained their staff, documented their WAH policies, and ran mock floor checks before the auditor called.
Take the Compliance Readiness Check to evaluate your current posture, review your timekeeping system requirements, or book a discovery call with Amerifusion Bookkeeping for a CPA-level review of your remote workforce compliance program. Foundational requirements are covered in our DCAA compliance guide and DCAA compliance services page.
