March 9, 2018
Government contract clauses require that your company set up and maintain adequate internal controls. One common theme is employee training. Your business is expected to provide periodic instruction in aspects of government contracting, including the terms of a contract. Many clauses also require performing and executing activities specific to federal contracting.
Summary of Tips
Read your contract clauses. Obtain the guidance used by your oversight officials to identify their expectations for topics to cover in training courses.
Keep course sign-in sheets. Hold on to materials used for instruction and get written acknowledgment of one-on-one, on-the-job training and self-study. Electronically capture online training to support that it took place.
Prepare an annual training plan for each employee to address specific needs for initial and refresher courses.
The instructions you give employees must ensure that they can comply with those terms. Federal auditors and oversight officials will evaluate the adequacy of your business’s controls and then set the scope for forward pricing, costing and billing-related audits.
Those who need training include employees responsible for providing input, performing tasks or using the results of contract-related functions. For example, cost reimbursement billings may be handled by a small group that relies on historical accounting data. It’s prudent, then, to include company accounting personnel in training on how to invoice for federal contracts.
On the other hand, all employees should receive training in timekeeping procedures as they are required to comply with them. If you hire independent contractors, they should receive the same training as regular employees who perform the same or similar functions.
To gather information to help develop training courses, take a look at the standard programs and other guidance material used by government auditors, analysts and other oversight officials. Those documents describe federal requirements and expectations that you can incorporate in your written policies, procedures and instructions.
The government doesn’t define a preferred method of instruction, so it can range from classroom lectures or discussions to hands-on use of business software, one-on-one, on-the-job training and self-study. What is critical, however, is that your company document the training. Auditors will want to verify that it took place and they will expect documentation of both full training and refresher courses, even for your concern’s more seasoned staff.
The bottom line is that your employees must have training adequate for them to accomplish their jobs as well as execute and cope with actions specific to a contract. How your business does that is up to you.
Consider including attendance at compliance training as a factor in annual performance evaluations to help ensure that managers and employees make it happen. Your firm’s future as a federal contractor could depend on it.