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New DCAA Guidance on Revised Policies Related to Low-Risk Incurred Cost Submissions

As the Defense Contract Audit Agency (“DCAA”) slowly pushes to eliminate Incurred Cost Submission (“ICS”) audit backlog, DCAA has recently published a new memorandum (“MRD”) revising guidance for selecting low-risk Incurred Cost Submission proposals less than $250 million in “auditable dollar volume” (“ADV”). Published on May 27, 2016, the memorandum revises the MRD 12-PPD-023(R), dated September 6, 2012, and MRD 13-PPD-021(R), dated October 29, 2013. While not specifically defined in the Federal Acquisition Regulation (“FAR”), Contract Audit Manual (“CAM”) or elsewhere, ADV is typically considered by DCAA to be the total contract cost for flexibly priced government contracts and subcontracts. Read More.

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