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We can help you with everything from evaluating your ICS compliance status to settling audit issues.
Does your organization have contracts containing FAR 52.216-7 Allowable Cost and Payment? If so, an annual Final Indirect Cost Rate Proposal, more commonly referred to as the Incurred Cost Proposal (ICP) or Incurred Cost Submission (ICS) is required. We work with numerous companies to develop, assist with, or review final indirect cost submissions.
What is the Incurred Cost Submission?
When Must the Incurred Cost Submission be Submitted?
The requirement to submit a FAR Incurred Cost Submission is contained in FAR clause 52.216-7(d)(2)(i) – Allowable Cost and Payment, which states, “The contractor shall submit an adequate final indirect cost rate proposal to the contracting officer (or cognizant federal agency official) and auditor within the 6-month period following the expiration of each of its fiscal years.”
Incurred Cost Submission Training
Capital Edge provides incurred cost submission training to Federal contractors. We provide preparation for the ICS audit, review and recommendations, audit management and audit response. Our Government contract consultants provide an overview of the submission process, helping with everything ICS related.
To learn more about our incurred cost submission training, contact us today.
Audits of ICP / ICS present their own challenges to the contractor as these audits have historically represented the largest amount of dollars examined by the Defense Contract Audit Agency (DCAA) relative to all other types of audits. Whether it’s preparation of the submission schedules, guidance on cost allowability, audit support, or navigating requirements after receiving final rate determinations, Capital Edge’s team of experts have the expertise and experience to support your organization.
At Capital Edge, our experts have extensive experience supporting contractors ranging from small businesses to Fortune 500 companies across a variety of industries in addressing this complex contract requirement.
All of our clients’ needs are different. We tailor our approach to meet the needs and business objectives of each-and-every client. Our experts have extensive experience supporting Federal contractors with their ICP / ICS needs, including incurred cost audit support.
Here are the latest questions being asked about ICS
The Office of Federal Procurement Policy (OFPP) has not published the 2020 compensation cap amounts. However, the OFPP did post the formula to be used to calculate the cap. The cap has also been released by DCAA in MRD 20-PSP-004(R) dated August 20, 2020.
Cap is for contracts awarded after June 24, 2014.
No, the DCAA ICE Model is not required, however the required information that it contains is. Contractors have the ability to submit using their own format or template with the same required information.
The DCAA Incurred Cost Submission Adequacy Checklist is can be found here on the DCAA website.
An incurred cost proposal or incurred cost submission is required for Federal contractors who have flexibly priced contracts or subcontracts containing FAR 52.216-7 – Allowable Cost and Payment clause. It is due within 6 months following the end of the contractor’s fiscal year. For most contractors with a December 31 fiscal year end, the submission is due the following June 30th.
The incurred cost audit can occur anytime after the ICS is submitted. Typically, the audit happens months to years after submission.
Given this delay related to incurred cost audits, it is important to ensure that the data supporting the ICS is organized and available when the audit starts. Check out this video to learn best practices for preparing for the incurred cost audit while preparing the ICS.
Capital Edge government contract consultants support Government Contractors and Federal Grant Recipients. Our consultants specialize in the regulatory compliance matters you need.
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