Preparing and Submitting a DCAA Incurred Cost Submission (ICS)

As a federal government contractor you are responsible for submitting an Incurred Cost Submission, if you have at least one contract with the ‘Allowable Cost and Payment’ clause (cost-type or time and materials T&M).   

Incurred Cost Submissions have a high probability of being audited, be prepared.

Compliance requirements for incurred cost submissions

What is an Incurred Cost Submission?

The Defense Contract Audit Agency (DCAA) incurred cost submission is a report of what your actual indirect expenses were for the government compared to the indirect costs you billed using provisional billing rates.

Also known by Indirect Cost Proposal (ICP) or Indirect Cost Rate Proposal (ICRP).

Who Must Submit an Incurred Cost Submission?

All federal contractors holding cost-reimbursable or time and materials (T&M) contracts. 

More specifically, federal contractor that hold an applicable contract subject to the Federal Acquisition Regulations clause, ‘Allowable Cost and Payment’ (FAR 52.216-7) and/or ‘Payments under Time-and-Materials and Labor-Hour Contracts’ (FAR 52.232-7). 

When Must the Incurred Cost Submission be Filed?

Incurred cost submissions are due six months after completion of the contractor’s fiscal year end.

Example: Fiscal year-end 12/31, incurred cost submission are due by 6/30.

Required Submission Schedules

  • Schedule A – Summary of Indirect Expense Rates
  • Schedule B, C, D – Indirect Cost Pools
  • Schedule E – Claimed Allocation Bases
  • Schedule F – Cost of Money
  • Schedule G – Booked and Claimed Direct Costs
  • Schedule H – Direct Costs by Contract at Claimed Rates
  • Schedule H-1 – Government Participation by Pool
  • Schedule I – Cumulative Allowable Cost Worksheet
  • Schedule J – Subcontract Information
  • Schedule K – Hours and Amounts on T&M Contracts
  • Schedule L – Payroll Reconciliation
  • Schedule M – Accounting/Organization Changes
  • Schedule N – Certificate of Indirect Costs
  • Schedule O – Contract Closing Information

Common Deficiencies

  • IR&D/B&P not fully burdened (Schedule B)
  • Not all intermediate allocations disclosed (Schedule D)
  • Unallowable costs not included in G&A base (Schedule E)
  • Government participation not calculated for all final indirect rates (Schedule H-1)
  • Physically complete contracts not shown (Schedule I & O)
  • Lack of subcontractor information (Schedule J)
  • Signed certification not included or not signed by at least a Vice President or CFO (Schedule N)

Self Assessment

This is a helpful DCAA self assessment tool for assessing the adequacy of final direct and indirect incurred costs to ensure compliance with the contractual requirements under FAR.

ICE Model Resources

The Incurred Cost Electronically (ICE) Model is an Excel spreadsheet that provides contractors with a standard user-friendly electronic package to assist in preparing timely and adequate incurred cost submissions.

Have Questions or Need Consulting Expertise, We Are Here to Help!

If you have any questions please reach out, we’d love to chat further and assist your organization with your incurred cost submissions, including:

  • Prepare your submission utilizing the DCAA ICE Model.
  • Review your company prepared submission for adequacy.
  • Assist with DCAA audit defense.

Learn more about our GovCon Managed Accounting Services and Iuvo as a Deltek Premier Partner.

Book a free consult call with us!

About Iuvo Systems

Iuvo Systems is the premier GovCon accounting services firm that provides DCAA compliant outsourced bookkeeping, consulting, implementation and training to government contractors. In addition to working with large prime contractors we specialize in working with 8(a), SBA, HUBZone, Women, Minority and Veteran owned firms utilizing QuickBooks, Deltek Costpoint and other industry specific applications.

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