Whitepaper: The Audit World's Biggest Myths
Download Now

Incurred Cost Submission

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?

An incurred cost submission determines the final actual indirect cost rates that contractors incur during their fiscal year. These final rates determine whether the contractor owes the government (or higher tier sub) or the government (or higher tier sub) owes the contractor. 

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.


Get Help With Your ICS Proposal Today

Fill out the form below or call  (855-227-3343)

Contact us today for immediate support around Incurred Cost Submission (ICS) and audit preparation.

Who We Are
  • Our team of experts possess unsurpassed qualifications, experience, and certifications and have previous working experience including industry, Government or “Big Four” consulting firms and possess specific relevant experience navigating Federal compliance.
  • We have extensive experience supporting clients with incurred cost proposals from beginning to end, or where support is needed in between.
  • Our experts roll up their sleeves to provide just the right level of support each client needs, including preparing entire incurred cost proposals, preparing certain schedules, reviewing proposals prepared by clients, and supporting incurred cost audits.
Why Choose Us
  • We have a deep bench of finance and accounting subject matter experts who are unrivaled in the market, both from an experience and knowledge standpoint and, also in providing the critical consulting and advisory support to our clients resulting in the ultimate objective – receiving the cognizant Federal agency official-issued ICP / ICS adequacy determination letter and ultimately final approved indirect rates.
  • We foster long term relationships with our clients to ensure that we provide just the right level of support needed for each engagement.
How We Can Help

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. 

  • Full incurred cost submission development
  • Development of specific schedules
  • Review of client prepared incurred cost submissions
  • Preparation of incurred cost proposal revisions
  • Incurred cost audit support
Tips to Prepare for the Audit While You Prepare the ICP / ICS Audit
  • Documentation is critical for a successful. Frequently during government audits – “if you can’t show me, it didn’t happen”.
  • Spread the knowledge and wealth. Continuity is essential as there will likely be a lag in time between submission and an audit. Internal training and existing policy and procedure will mitigate the loss of knowledge required to successfully support and audit.
  • Prepare supplemental schedules, even though they are not required for a submission to be deemed adequate by DCAA.
  • Keep a “working copy“. This version of the file should be fully linked and contain all completed supplemental schedules. It will prove invaluable during the audit.
  • Understand audit expectations. Clear communication and setting of expectations at the beginning of an audit can smooth the process. Understand the DCAA audit program and applicable audit guidance and request a detailed entrance conference.
ICS Audit Prep

Frequently Asked Questions

Here are the latest questions being asked about ICS

What is the current Contractor Compensation limit?

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.

  • 1/1/22 – 12/31/22: $589,000
  • 1/1/21 – 12/31/21: $568,000
  • 1/1/20 – 12/31/20: $555,000
  • 1/1/19 – 12/31/19: $540,000

Cap is for contracts awarded after June 24, 2014.

Is the DCAA ICE Model required?

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. 

What is the statute of limitations for an ICS?
The statute of limitations for an ICS is 6 years and the clock begins upon submission.

Where can the DCAA Incurred Cost Submission Adequacy Checklist be found?

The DCAA Incurred Cost Submission Adequacy Checklist is can be found here on the DCAA website.

When is Incurred Cost Submission required?

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.

When does the Incurred Cost Audit occur?

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.

Contact us today for immediate support around Incurred Cost Submission (ICS) and audit preparation.


CAS Training


We have quite a few upcoming trainings that could benefit you and your team as you navigate the CAS. Check out our existing events or contact us about custom training for your business today!

About Capital Edge Consulting

Capital Edge government contract consultants support Government Contractors and Federal Grant Recipients. Our consultants specialize in the regulatory compliance matters you need.

Contact Our Experts

8200 Greensboro Dr #1400
McLean, VA 22102

Stay In Touch


Call Us: (855) 227-3343

© 2023 Capital Edge. ALL RIGHTS RESERVED.
crossmenuchevron-down linkedin facebook pinterest youtube rss twitter instagram facebook-blank rss-blank linkedin-blank pinterest youtube twitter instagram Skip to content