Capital Edge’s Tip Line #15: Advance Agreements & Pending Incurred Cost Submission Changes

Capital Edge Tip Line – March 6, 2026

Advance Agreements & Pending Incurred Cost Submission Changes – Edition 15

In this week’s Capital Edge Tip Line, CEO Chad Braley discusses a new court ruling on advance agreements as well as pending changes coming for the Incurred Cost Submission (ICS), which would simplify requirements for government contractors.

Key Updates from This Week’s Tip Line

What You Need To Know

What’s happening? Good news is on the way for the Incurred Cost Submission with simplified requirements. Additionally, a new decision has been made on a long-standing court case on advance agreements.

What's being discussed? 

1. Decisions have been made in the long-standing court case on advance agreements.

The takeaway: Advance agreements must be compliant with the FAR and incorporated into your contract.

2. FAR 52.216-7 Allowable Cost and Payment is being rewritten. Key changes on the table include:

• Eliminating Schedule L
• Moving requirements from Schedule O to Schedule H
• Condensing Schedule K with fewer reporting requirements
• Applying Schedule J only to subcontracts above the new TINA thresholds
• Moving the completion of Schedule I after indirect rates are finalized

The takeaway: The ICS should be getting simplified, which is a win.

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