You can get a defensible read on your enforcement gap in about ten minutes, with nothing more than your OCG document and three recent invoices.
This is the same diagnostic our team runs at the start of every engagement. It works.
Setup
Pick three invoices from last quarter:
- One from your highest-spend firm
- One from a mid-size firm you've worked with for years
- One from a newer firm on the panel
Print your OCG. Yes, on paper. You will read it differently than on a screen.
The checklist
For each invoice, scan for these eight things. Mark every line that fails.
1. Block billing
Any entry over 2.0 hours that lists more than one task in the narrative. Your OCG almost certainly forbids this; almost every invoice has at least one.
2. Internal conferences
Two or more timekeepers from the same firm logging time on the same date with overlapping narratives (calls, meetings, strategy sessions). Cross-check by date.
3. Rate above your cap
Pull the rate sheet that came with the engagement letter. Check every timekeeper's effective rate (amount ÷ hours) against the agreed cap for their class.
4. Non-billable administrative time
Travel coordination, calendaring, filing, organizing documents, formatting. These are usually paralegal entries and they often sneak through.
5. Vague narratives
Anything under ~40 characters, or anything that uses only generic verbs ("review", "research", "attention to") without specifying the work product.
6. Duplicate work
Two timekeepers reviewing the same document, drafting the same brief, or attending the same call without a clear OCG-permitted reason.
7. Minimum increment violations
If your OCG requires 0.1 increments, flag any entry rounded to 0.25 or 0.5. If your OCG forbids minimum-billing of phone calls, flag short calls billed at 0.3.
8. Travel time
Was it billed at full rate? Most OCGs require travel at half rate or non-billable when the timekeeper could work during transit.
What the numbers usually show
In a typical sample of three invoices, our analysts find:
- 8–15% of dollar value flaggable on the first read
- 20–35 line entries that fail at least one OCG rule
- 3–5 different rule categories violated per invoice
If your numbers look close to that, you have an enforcement gap, not a guidelines gap.
What to do with the result
You have three options:
- Push the adjustments back to the firms manually. This is what most departments do, and it scales poorly.
- Tighten the OCG language. Helpful, but the next invoice will still come back with the same patterns.
- Add an AI reviewer that reads every line on every invoice against your guidelines. This is what 42B does.
The audit is free either way. If you want us to run it on a real sample of your invoices and return a written report, send them over.
