Vertical guide · Updated May 2026

Bankruptcy attorney time tracking: § 330 fee applications and US Trustee Guidelines

Q: What fee application standard applies to bankruptcy attorneys?

11 U.S.C. § 330(a) provides that the bankruptcy court may award a professional person employed in the case 'reasonable compensation for actual, necessary services rendered' and 'reimbursement for actual, necessary expenses.' The standard is stricter than the civil-rights lodestar standard: the Bankruptcy Code requires the court to consider whether the services were actual, necessary, and reasonably likely to benefit the estate at the time the services were rendered. The US Trustee's Program Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses require task-by-task time entries, identification of the professional performing each task, and contemporaneous time records — not reconstructed summaries. Courts applying § 330 have denied fees for block billing, vague descriptors, and reconstructed time in published opinions in the Southern District of New York, the District of Delaware, and the Ninth Circuit.

Q: What categories of time does a solo bankruptcy attorney most commonly fail to log?

The three categories most commonly absent from reconstructed Chapter 7 and Chapter 13 bankruptcy time records are: (1) creditor calls — in a Chapter 13 case, creditors (mortgage servicers, auto lenders, unsecured creditors) call to inquire about plan treatment, object to confirmation, or negotiate adequate protection; these calls run 10–30 minutes each and occur throughout a 3–5 year plan period, representing 20–60 hours of unlogged time across a 100-case Chapter 13 practice; (2) trustee and examiner calls — calls with the standing Chapter 13 trustee, the Chapter 7 trustee, or a court-appointed examiner to discuss case administration, asset disposition, and plan feasibility; (3) document-preparation time for plans, amendments, and motions — individual drafting sessions on plan confirmation briefs, objection responses, and amended schedules that are reconstructed as single-entry blocks rather than the actual 3–5 separate editing sessions.

Q: How does flat-fee vs. hourly billing work in bankruptcy practice and how does it affect time tracking?

Most consumer bankruptcy work (Chapter 7 and Chapter 13) is billed on a flat-fee basis set by local court rules or the No-Look Fee schedule. For example, in the Central District of California, the current No-Look Fee for Chapter 13 representation is $4,000–$5,500 depending on complexity. Attorneys billing at the No-Look Fee do not need to track time for most consumer cases. However, time tracking becomes critical in three bankruptcy scenarios: (1) Chapter 11 business reorganizations, where § 330 fee applications require detailed contemporaneous records; (2) adversary proceedings within any chapter, which are litigated separately and billed hourly; (3) cases that exceed the No-Look Fee, where the attorney must file a § 330 application to recover additional fees — and the application will be reviewed under the UST Guidelines, requiring contemporaneous records even for the flat-fee portion.

Bankruptcy attorneys who file § 330 fee applications face the strictest contemporaneous-records standard of any federal fee proceeding. The US Trustee Program's Guidelines require task-by-task entries in 0.1-hour increments with project-category coding — and explicitly prohibit reconstructed time. For the solo bankruptcy practitioner billing Chapter 11 reorganizations and adversary proceedings from QuickBooks, passive capture is the only way to meet that standard without a billing system running every day.

TL;DR

ClaimHour captures creditor and trustee phone calls, document-edit sessions on reorganization plans and adversary briefs, email-compose time for court filings and creditor correspondence, and calendar events for §341 meetings of creditors, confirmation hearings, and adversary proceedings — passively, from the date of engagement. For bankruptcy solos billing Chapter 11s and adversary proceedings from QuickBooks without a PMS, that means contemporaneous records meeting the UST Guidelines standard. $29–$59/mo. No PMS required.

The § 330 standard and US Trustee Guidelines

11 U.S.C. § 330(a)(1) permits the bankruptcy court to award "reasonable compensation for actual, necessary services rendered" by a professional employed in the case. The court considers, among other factors, whether the services were "reasonably likely to benefit the debtor's estate" at the time performed and whether the compensation is "reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under this title."

The US Trustee Program's Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses translate this standard into specific record-keeping requirements. The Guidelines require:

Time entries in increments of no greater than 0.1 hours (six minutes)
A specific task description for each time entry identifying the work performed
Identification of the professional or paraprofessional who performed each task
Project-category coding: entries grouped by function (general administration, asset analysis, claims administration, plan of reorganization, fee applications, adversary proceedings, etc.)
Contemporaneous records: the Guidelines state explicitly that "time records should be kept contemporaneously as services are rendered"

Block billing — combining multiple tasks into a single time entry — is explicitly prohibited. Reconstructed time — time estimated from memory or reconstructed from calendar entries after the work was performed — is identified as a ground for fee reduction in published UST objections and bankruptcy court decisions.

How § 330 scrutiny compares to the Hensley standard

The Hensley lodestar standard in civil rights and employment fee petitions calls for contemporaneous records as best practice and reduces or denies fees for block billing and vague descriptors — but it does not specify the time increment, require project-category coding, or explicitly prohibit reconstruction from memory. The UST Guidelines go further on every dimension. A bankruptcy attorney who transitions to § 330 practice after years of civil rights or employment fee petitions will find the contemporaneous-records requirement is enforced more strictly, more mechanically, and with a formal objection process that has no equivalent in the civil rights fee-petition system.

Where bankruptcy solos leak time: the three failure modes

Creditor calls throughout a Chapter 13 case

A Chapter 13 plan runs 3–5 years from confirmation to discharge. During those years, creditors call the debtor's attorney to inquire about plan payment status, to discuss adequate protection for secured creditors, to object to plan modifications, and to resolve payment posting disputes with mortgage servicers. In a practice with 100 active Chapter 13 cases, those calls average 2–5 per week across the portfolio — roughly 150–260 creditor contacts per year representing 30–65 hours of attorney time.

Most of these calls are short (10–20 minutes) and routine. They are not logged contemporaneously because the attorney is not currently billing the Chapter 13 case hourly — the flat fee was paid at confirmation. But if the case ever requires a fee modification, an adversary proceeding, or a motion for additional fees under § 330, the attorney needs to demonstrate the cumulative time invested. Passive capture logs every call: duration, counterparty, timestamp.

Trustee and examiner coordination calls

Calls with the standing Chapter 13 trustee — discussing plan feasibility, responding to trustee objections, negotiating modified plan terms — are billed separately from the confirmation flat fee in many districts. Calls with a Chapter 7 trustee about asset valuation and liquidation analysis, or with a court-appointed examiner about financial misconduct findings, are recoverable in the § 330 application. These calls occur irregularly, often without advance calendar notice, and are almost entirely absent from reconstructed fee applications. iOS call metadata captures each call when it occurs: number, duration, direction.

Document-preparation fragmentation

A Chapter 11 reorganization plan of reorganization goes through multiple drafts over months of negotiation with creditors' committees, secured lenders, and the trustee. An adversary proceeding complaint and discovery set take weeks of non-consecutive drafting. The attorney who reconstructs this work at fee-application time converts 8 separate 45-minute drafting sessions into a single "plan drafting — 6 hours" entry — which is block billing under the UST Guidelines. Document-edit focus-duration events capture each session separately: the October 14th session on the plan's treatment of Class 3 unsecured creditors (40 min), the October 19th session on the feasibility analysis (55 min), the November 2nd session integrating the secured lender's markup (35 min).

Chapter 11 adversary proceedings: the most fee-exposed context

Adversary proceedings within bankruptcy cases — fraudulent transfer avoidance actions, preference recovery actions, dischargeability proceedings, and stay violation motions — are litigated separately from the main bankruptcy case and billed hourly rather than at a flat fee. They are the highest-stakes fee-application context for solo bankruptcy practitioners because: (1) they generate the most hours per matter; (2) they produce a formal § 330 application with UST scrutiny; and (3) they run on the same compressed timeline as any federal litigation, meaning the attorney has the least time to maintain time records carefully.

A fraudulent transfer avoidance action in a small Chapter 11 generates 80–200 hours of attorney time from complaint drafting through trial or settlement. At a $350/hr billing rate, a 120-hour adversary proceeding represents $42,000 of fee exposure that requires a UST-compliant § 330 application. The UST Guidelines requirement for 0.1-hour contemporaneous entries across that 120-hour case means 600–1,200 individual time entries — each of which must describe a specific task, identify the attorney who performed it, and fall within a project category code.

Passive capture reduces the burden by generating the underlying event log automatically: every call with opposing counsel, every calendar event for hearings and depositions, every document-edit session on motions and briefs. The attorney converts the passive capture log into UST-compliant time entries with the correct project codes — but the underlying contemporaneous record exists regardless of whether the attorney remembered to start a timer.

How ClaimHour fits bankruptcy practice

If you are a solo bankruptcy practitioner handling Chapter 11 reorganizations and adversary proceedings under the § 330 standard and UST Guidelines — billing from QuickBooks without a PMS — ClaimHour's passive capture layer generates the underlying contemporaneous event log. The 0.1-hour entries and project-category codes still require attorney judgment at fee-application time, but they are derived from a contemporaneous record rather than constructed from memory. Join the waitlist and we'll email when early access opens.

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