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Contractors are required to use provisional billing rates when invoicing costs under cost reimbursable contracts or submitting an SF1443 Contractor’s Request for Progress Payment. FAR 42.704, Billing rates, requires the contracting officer or auditor (usually DCAA) to establish the billing rates. DCAA has undergone a reorganization, and the office assigned to your contractor site may have shut down or the staff may have been relocated.
Where Do You Send Your Provisional Billing Rate Submission or Midyear Update?
DCAA has enhanced its Contractor Submission Portal (CSP) to allow contractors to submit their annual or revised Provisional Billing Rate Submissions electronically through CSP. Previously, only incurred cost submissions could be submitted electronically. Contractors can now submit a new billing rate proposal, update their proposal, or withdraw their billing rates. Once uploaded, an automated email will be sent to the applicable DCAA office that has cognizance. If you are not currently using CSP to submit incurred cost submissions, you will need to register in the Procurement Integrated Enterprise Environment (PIEE).
Takeaways
The use of Contractor Submission Portal (CSP) for provisional billing rates is not required. It is not clear if DCAA has notified contractor locations that offices have closed, have been realigned under Land, Sea and Air, or what branch will be handling your audits or establishing your billing rates, so you need this option. You don’t want to delay obtaining DCAA-established billing rates to keep your billing process flowing and limit any impact on cash flow. Be prepared for additional requests for data from your new friendly auditor, “I am from the Government and here to help,” do not bet on it. Most likely, you will not be working with the same auditor who is familiar with your accounting system and staff. And don’t expect a new auditor will accept the documentation you provided in the past.
Guidance and Support for Accounting System Compliance
Redstone GCI works with contractors across the U.S. and internationally to help them understand government requirements and maintain an adequate accounting system. Our team assesses compliance with DCAA pre-award requirements and expectations, assists with accounting and billing policies and procedures, and provides training to accounting staff. We also support contractors in resolving findings that may arise during government audits and reviews. In addition, our team of experts offers ongoing compliance consulting, outsourced accounting support, and software services for systems such as Deltek Costpoint, Unanet, and QuickBooks, giving contractors comprehensive resources to meet requirements and strengthen internal controls.
Lynne is a Director with Redstone Government Consulting, Inc. providing government contract consulting services to our clients primarily related to Commercial Item Determinations and support, Cost Accounting Standards, DFARS Business System Audits, Proposals, and Incurred Cost. Prior to joining Redstone Government Consulting, Lynne served in several capacities with DCAA and DCMA for over 35 years. Professional Experience Lynne began her career working with DCAA in the Honeywell Resident Office, Clearwater, FL in 1984. Lynne’s experience included various positions which involved conducting or reviewing forward proposals or rate audits, financial capability audits, progress payments, accounting and estimating systems, cost accounting standards, claims and disclosure statement reviews. She is an expert in FAR, DFARS, CAS and testified as an expert witness. Lynne assisted in drafting the commercial item guidance for DCAA Headquarters. Lynne was assigned as a Regional Technical Specialist where she provided guidance to 20 field offices on highly complex or technical issues relative to forward pricing, financial capability or progress payment issues. As an Assistant for Quality, she was involved in reviewing and ensuring audit reports were in compliance with policy and GAGAS as well as made NASBA certified presentations to the staff including but not limited to billing reviews, CAS, unallowable cost and progress payments. To enhance her experience in government contracting, Lynne accepted a position with DCMA in 2015 as part of the newly organized DCMA Cadre of Experts in the Commercial Item Group. This included performing reviews of prime contractor’s assertions and/or commercial item determinations as well as performing price analyses. Lynne was a project lead and later became a lead analyst where she engaged with the buying commands on requests and reviewed price analysis reviews performed by a team of 5 analysts. She also assisted the DCMA CPSR team relative to commercial items and co-instructed the Commercial Item Training presented to DCMA. Education Lynne earned a Bachelor of Science Degree in Accounting from the University of Central Florida. Certifications State of Florida Certified Public Accountant State of Alabama Certified Public Accountant Defense Acquisition Workforce Improvement Act (DAWIA) Level III- Auditing DAWIA Level III – Contracting