Most legal departments believe their Outside Counsel Guidelines (OCGs) are doing the work. They were negotiated carefully, distributed at engagement, and acknowledged by every firm on the panel.
And yet, quarter after quarter, the same patterns surface: vague narratives, block-billed partner time, paralegal admin work that should never have hit the bill, and timekeepers above the agreed rate cap.
The math doesn't work
A mid-size legal department might receive 800–2,000 invoices a year across dozens of firms. A senior reviewer can read perhaps 15–20 invoices a day with real attention. The arithmetic is simple: nobody is reading every line.
What gets reviewed in practice is:
- The headline total against the matter budget
- A spot-check on partner hours
- Anything that looks visibly weird at a glance
What doesn't get reviewed:
- Whether a 0.3 hour entry violates the OCG's minimum-increment rule
- Whether two timekeepers on the same call counted as an internal conference
- Whether the associate billing 5.4 hours of "review prior pleadings" was actually doing duplicative work
- Whether the senior partner rate matches the rate sheet you negotiated 14 months ago
The enforcement gap is structural
This is not a discipline problem. Human reviewers cannot scale to read every line on every invoice from every firm, every month. The work is repetitive, the rules are detailed, and the consequences of missing one entry are usually invisible.
The OCG was written to save money. The review process throws away most of that savings before the invoice is paid.
The fix is not "review harder." The fix is to take the line-level enforcement work off humans entirely, and give reviewers the higher-leverage job: deciding what to do with flagged adjustments.
What good enforcement looks like
A correctly enforced OCG should produce, for every invoice:
- A complete line-by-line pass against every rule in your guidelines
- A citation back to the exact OCG section invoked for each flagged line
- A prioritized queue your reviewer can clear in minutes, not hours
- A clean audit trail of what was challenged and why
That is what 42B does - as an overlay on Legal Tracker, with no new workflow, no new software, and no second source of truth.
