Director | Government Contract Regulatory Compliance Practice | Capital Edge Consulting
The DCAA released recently a revised Incurred Cost Proposal Adequacy Checklist (Version 3.0), effective immediately. http://www.dcaa.mil/Guide_for_Determining_Adequacy_of_Contractor_Incurred_Cost_Proposal.pdf
I have not compared side-by-side the former and revised versions; however, according to the corresponding MRD issued August 27, 2015, the main changes in Version 3.0 center on alignment with 52.216-7 (Allowable Cost and Payment clause) requirements related to final indirect expense rates. Also, the MRD states that a contractor’s incurred cost proposal may be deemed adequate – even with a few inadequacies noted during the audit. It goes on to say that there is no specific number of single inadequacies that are allowed before the entire submission will be deemed inadequate; conversely, a single significant deficiency may be enough to deem the proposal inadequate.
The MRD guidance concludes by stressing that the ultimate determination of adequacy, or not, needs to be based on the professional judgment of the audit team. We will have to see how this goes?
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