The Incurred Cost Submission: When It Is Required, How to Prepare and Best Practices

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Contractors with the Federal Acquisition Regulation (FAR) Clause 52.216-7, Allowable Cost and Payment included in their cost reimbursable and time & materials (T&M) contracts are required to submit an Incurred Cost Submission (ICS). Submitting your ICS on time to the appropriate Government Administrative Contracting Officer and the cognizant Defense Contract Audit Agency (DCAA) office can be a hurdle but a requirement. Late submissions are subject to a unilateral decision by the Contracting Officer (CO) to apply a decrement factor, which will reduce the billed cost.

In this episode of Cherry Bekaert’s GovCon Podcast, Brendan Halloran, a Senior Manager in the Firm’s GovCon practice who was previously a Divisional Administrative Contracting Officer (DACO) at the Defense Contract Management Agency (DCMA), welcomes Eric Poppe, a Managing Director in Cherry Bekaert’s Government Contracting Industry practice. Together they cover the ICS submission process, the first step in developing final indirect cost rates for contractors with flexibly priced contracts, due six months after the end of the fiscal year.

Listen in as they discuss:

  • When an ICS is a requirement
  • ICS preparation and required schedules
  • DCAA’s ICE Model
  • The importance of the preparation, due diligence and review process
  • Factors that can play into questioned costs and the full audit program
  • Process for extensions and repercussions for not timely submitting an ICS
  • Common issues and best practices

If you have any questions specific to your situation, Cherry Bekaert’s GovCon consultants are available to discuss your situation with you.

Related Guidance:
Article: It’s That Time Again…. How to Get a Head Start on your Annual Incurred Cost Submission

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