How do you track cleaner hours for the 100-hour STR rule?

Question

For those using the 100-hour material participation rule on your STRs, how are you tracking how much time your cleaners actually spend at the property?

Most cleaning crews charge a flat turnover fee instead of an hourly rate, so their invoices don't show hours worked. Do you just use smart lock logs to see when they enter and leave, or ask them for time estimates? Curious what your CPAs usually want to see for this.

Kasing Ng · Answer

Hi Hubert, quick flip on this: your cleaners' hours don't count toward your 100. They count against you. The test is more than 100 hours AND at least as much as any other single person, including non-owners (Reg §1.469-5T(a)(3)). So if any one person logs more time than you, it fails even when you're over 100.

One thing that helps: it's per person, not the whole crew combined. If a company sends three cleaners at 40 hours each, that's 40 per person, not 120, so you only have to beat the busiest individual. Track their hours to prove yours come out on top.

Smart lock in and out times plus your own calendar is plenty. The regs don't strictly require a contemporaneous log, but courts give little weight to estimates reconstructed later with nothing behind them, so keeping it as you go is the safe play.

Andrew Steffens · Answer

Every CPA I talked to has a nuanced way of what they want for tracking. Do you have a good CPA? If not I would recommend @Christopher Tile

Hubert Grzesiak · Answer

Appreciate all the replies here, super helpful.

@Christopher Tile keeping a conservative high-end estimate per clean makes a lot of sense as a baseline so there are no surprises at year-end.

@Matthew Tregoning and @Hossein Sharifi good call on having the cleaner text a quick one-line headcount after each turnover and pairing it with the invoice and smart lock log. Definitely beats trying to figure out who showed up months later.

@Divin Kanyama and @Aaron Zimmerman agreed, pairing the lock logs with actual invoices and notes as you go seems like the cleanest way to hand it over to a CPA without making them dig through a mess.

Christopher Tile · Answer

@Andrew Steffens Thanks for looping me in!

@Hubert Grzesiak Smart lock log could work if you want to be as thorough as possible. A general time estimate for each clean would also work. Stay conservative on the high end, and make sure you beat the conservative total at the end of year.

Clever Mukori · Answer

Yes, I'd get the crew size in writing at the time of each clean, not after. The easiest way is to ask the cleaning company to text or email after each turnover with how many people came and their arrival and departure times, then save that next to the smart lock log for that date. If they won't do that, a quick note in your own calendar the same day (something like "2 cleaners, 11:05 to 1:40") is still far better than rebuilding it at tax time. It's also worth asking your CPA up front what format they want, so you only set the log up once.

Aaron Zimmerman · Answer

I like the smart lock idea a lot. you could also ask them to put each cleaners approximate time on the invoice or use video logs. I’d imagine the smart lock is a little easier.

Matthew Tregoning · Answer

I'd have the cleaning company send the date, names of the people on the job, and each person's start/finish time with the turnover report. A shared door code only tells you when someone entered, not who did what. Keeping that record alongside the flat-rate invoice seems much easier than reconstructing it later. I'd have your CPA confirm the format they want before you build the routine around it.

Hossein Sharifi · Answer

@Hubert Grzesiak Yes, I'd note it. For each turnover, record the date, lock-in and lock-out times, and how many cleaners came. A 3-hour visit by two people is 3 hours for each of them, not 6 hours for one person, and the busiest single person is what you're comparing against.

If the company won't tell you headcount, ask them to put it on the invoice or text a one-line note when they leave. Most will.

It's also worth logging your own time on those same days, like the walkthrough after the clean or restocking. Keep it all in one running spreadsheet as you go, not rebuilt in March.

Ray Williams · Answer

Have you researched the STR loophole on material participation ? Worth a read.

Divin Kanyama · Answer

@Hubert Grzesiak I’d use a consistent, contemporaneous system rather than relying on estimates created at year-end. Smart-lock entry and exit records can be helpful, but they may not perfectly reflect working time, so I’d pair them with cleaner schedules, turnover records, messages, and invoices.

You could also ask cleaners to record arrival and departure times on each job, even if they continue billing a flat fee. A simple shared log or added line on the invoice should make this easier.

Ultimately, confirm with your CPA what documentation they consider sufficient and whether any hours count differently under the applicable participation test. Keep your own activity log as well, with dates, tasks, and time spent, and retain the supporting records.

How do you track cleaner hours for the 100-hour STR rule?

How do you track cleaner hours for the 100-hour STR rule?

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