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July 2015 | |||
Focus on Abt Policy: Time ReportingAbt is required to maintain complete and accurate records of each employee’s time in order to comply with government regulations and to promote good business practices. Abt implemented the “Total Time Reporting” system in order to align with the preferred Government accounting treatment of labor costs. This is the time keeping system preferred by the Defense Contract Audit Agency (“DCAA”). Abt’s time reporting policy requires employees to meticulously track hours and the projects they work on throughout the day. Why is this necessary?Information from Abt employees’ timesheets are the basis for labor charges to final cost objectives on the company’s contracts. Employees must meticulously track hours in order to ensure hours of work by all team members are recorded regularly and accurately and applied only to the correct project. This is a critical requirement that enables Abt to do the important work we enjoy on behalf of the US government and our other clients. When I know my manager only wants me to spend a certain number of hours on a task, I’m reluctant to go over that. I don’t want to make it seem that I need longer to complete the task than was allotted. So, do I do the budget or the job?Regardless of what is budgeted, our TTR system requires all employees to charge the actual number of hours worked and to charge that time to the correct charge number. This provides the company with information on the level of effort actually required to do our work and gives us a more accurate assessment of the cost of doing business. Remember: Federal Law imposes substantial penalties on the company and the individual employee for false claims on timesheets. Employees who fail to comply with the company’s time reporting policy are subject to disciplinary actions including termination. In addition, individuals engaging in this behavior are subject to enforcement actions by Federal authorities. | Spotlight on Abt Code of Conduct: Accurate Business and Financial Records Abt produces financial information about the company’s operations for internal and external reporting purposes. Accurate records are critical to Abt’s credibility in the marketplace, and to the company’s ability to meet compliance, legal, financial, and management obligations. Anytime you are asked to participate in the creation of any company records, you are responsible for the integrity of those records. Keys to Compliance: · Create records that reflect the truth of the underlying transaction or event · Only sign documents that you are authorized to sign and that you believe to be accurate · Only authorize purchases needed to conduct Abt business · Remember that emails and other electronic communications may all be considered business records · Retain, protect, and dispose of records in accordance with applicable policy · Do not destroy any records or documents against Abt’s document retention policy What’s wrong with recording revenue early or expenses late? We aren’t making the numbers up, just shifting them. Abt policy and the law require us to record all transactions truthfully. Shifting figures misrepresents our financial results. I think I found an error in an invoice we are sending to the client. My manager says what I found isn’t a problem. How should I raise my concern? An invoice is an example of a business record and must be accurate. It is critical that you notify a higher level of management in this situation. This could be a potentially serious error and could have implications under the False Claims Act, which prohibits knowingly submitting for payment or reimbursement a claim known to be false or fraudulent. | ||
Compliance Case StudyThe director of the Office of Acquisition and Assistance (OAA) at a USAID Mission in South America was the Contracting Officer for a USAID contract implemented by Company A. During the time he was the Contracting Officer for the contract involving Company A, he agreed to be listed as the program manager on a proposal submitted by Company A to another government agency. The director planned to leave his position with OAA and join Company A if it was awarded the contract. The director failed to notify his superiors of the conflict of interest and did not recuse himself from his responsibilities as Contracting Officer for Company A, resulting in a violation of the Federal Conflict of Interest statutes and the Procurement Integrity Act. As a result of the investigation, the director’s assignment was curtailed, resulting in his retirement as he had reached retirement age and had obtained an age waiver for his assignment. This situation, which was included in the 2015 USAID Inspector General’s Semiannual Report to Congress, reinforces the importance of Abt’s on Conflict of Interest policy and specifically the procedures in place regarding hiring former government employees. | |||
Compliance Hotline NumbersThe Ethics and Compliance Helpline Phone: 888-928-4231 (helpline int’l phone access codes) The Audit Committee Helpline Phone: 888-309-1558 (helpline int'l phone access codes) | Compliance Steering CommitteeRich Small (CFO/Chief Compliance Officer) – 617-349-2580, richard_small@abtassoc.com Clarissa Peterson (CHRO/Chief Ethics Officer) – 301-347-1460, clarissa_peterson@abtassoc.com Brian Roemer (General Counsel) – 301-347-5816, brian_roemer@abtassoc.com | ||
