Incurred Cost Submission
FAC 2005-52 Amends FAR to Include Guidance on Adequate Incurred Cost Submissions
For several years now, many contractors have objected to DCAA requiring them to utilize the Incurred Cost Electronic or ICE model to submit what DCAA considered an adequate incurred cost submission (ICS) as mandated by FAR 52.216-7 . Those complaints can now be directed towards the FAR Councils because they have, essentially, incorporated the ICE model into the Allowable Cost and Payment clause, FAR 52.216-7. FAC 2005-52 , effective June 11, 2011, included FAR Case 2008-020 as a final rule. This case revises procedures for clearing final audit reports and quick-closeout procedure, and sets forth a description of an adequate final indirect cost rate proposal and supporting. Read More.
DoD Announces Process to Resolve Contract Audit Recommendations
In a Departmental Memorandum dated December 4, 2009, Shay Assad , the Director of Defense Procurement and Acquisition Policy , announced a new process that would be used to resolve disagreements between contracting officers and DCAA auditors regarding which costs should be included in the contracting officer’s pre-negotiation objective. This new process is to be used when the contracting officer plans to sustain less than 75% of questioned costs regarding a proposal valued at $10 million or more. For these purposes, questioned costs do not include costs that are characterized as unsupported in the audit report. Under the new process, if a contracting officer intends to sustain. Read More.
What Can CB&H’s Government Contractor Services Group Do For Your Business in 2010?
The previous decade was a tough one for all businesses, including contractors and subcontractors to the federal government. Unfortunately, successfully delivering innovative, world-class solutions for federal customers did not, and does not protect government contractors from being pilloried as under delivering for the soldiers and taxpayers we serve. Historic levels of incoherence, with regard to requirements definition and regulatory consistency, have significantly increased the cost of operating as a compliant contractor. Today, it is essential that government contractors have access to best-in-class professional advice from experts possessed of the training and experience necessary to provide value-added and comprehensive regulatory compliance. Read More.
The Importance of an “Adequate” Incurred Cost Submission
On August 20, 2009, a proposed rule was published in the Federal Register entitled Federal Acquisition Regulation; FAR Case 2008-020, Contract Closeout (Federal Register/Vol. 74, No. 160/Thursday, August 20, 2009/Proposed Rules). In addition to containing provisions for closing out contract files, this proposed rule most notably contains provisions governing the consequences of submitting an “inadequate” incurred cost submission and the insertion of DCAA into the procurement process relative to the contractual withholding of fee. The proposed rule as written defines in great detail what constitutes an “adequate” incurred cost proposal, which is taken word for word from DCAA’s model incurred cost proposal as contained in Chapter 6 of. Read More.