Redstone Government Consulting Blog | Incurred Cost Proposal Submission (ICP/ICE)

We knew this was coming based on the June 30, 2025, PF 2025-38 (FAL 2025-05) Implementation of Indirect and Fringe Benefits Cost Reimbursement Limits on Financial Assistance Awards guidance to Granting officers. However, we believed the May 15, 2025, preliminary injunction issued by the U.S. District Court for the District of Massachusetts in the case of Association of American Universities et al. v. U.S. Department of Energy would slow down DOE‘s implementation of the cap on indirect cost recovery for more than just Institutions of Higher Education (IHEs). Sadly, that is not the case.

Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)

Recently, we conducted research related to some incurred cost audit findings for a client and came across an Armed Services Board of Contract Appeals (ASBCA) case that highlighted key information every contractor, especially small businesses, should know. The Technology Systems, Inc. ASBCA No. 59577 reads like a soap opera. It starts with some ups and downs. There were audit findings in Fiscal Year (FY) 2001, which the contractor and the Administrative Contracting Officer (ACO) negotiated. For FY 2002 to 2006, the contractor’s indirect rates were accepted as proposed. This was followed by relationship issues during the FY 2007 audit between the Defense Contract Audit Agency (DCAA) auditor and the contractor (No surprise to most of us). Then, a period of separation occurred, from FY 2009 to 2013, when DCAA decided that proposal pricing supporting new contract awards was the priority. During this time, the contractor’s FY 2007 incurred cost audit was shelved, along with significant potential questioned costs. Then, in an act of desperation, the ACO issued a Contracting Officer’s Final Decision (COFD) based on a DCAA memorandum for the FY 2007, which questioned costs to avoid the statute of limitations running out. Ok, enough of the soap opera, let’s go through the things you need to know.

Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Litigation Consulting Support, Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

The Good

Ok, finding some good is going to be a challenge. Let's start with the fact that the Defense Contract Audit Agency (DCAA) receives approximately 3,500 incurred cost proposals annually, but only audits around 500 of them. And even though DCAA is still auditing about 75% of the dollars submitted ($193B), only .3% is questioned ($760M), and only 31% of that is likely to be sustained by contracting officers. This comes from the DCAA Report to Congress for 2024.

See, we did find some good.

Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

I believe most prudent businesspeople would consider providing water and coffee to their employees and customers a reasonable business expense and consider it an allowable cost. Well, Defense Contract Audit Agency (DCAA) auditors are not most people and, in most cases, have little to no business experience, so they believe providing water and coffee is an unallowable cost.

Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

Government contracts can be a great opportunity. They often come with stability, a steady income, and the chance to scale your business. But they also come with strings attached: a detailed set of rules and expectations, especially when it comes to your accounting. Unfortunately, many government contractors learn about those rules the hard way, which is after they’ve already made a mistake. In this article, we’ll walk through some of the most common accounting mistakes that can derail even experienced contractors, cost you money, or worse, jeopardize your contracts.

Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, DCAA Audit Support, Quickbooks, Government Regulations, Federal Acquisition Regulation (FAR)

What do indirect rates and indirect costs in Unanet mean for my organization? This is a question most of the world of government contractors ask. Managing costs isn’t just about tracking the dollars that are spent. It’s also about maintaining a profit, compliance with federal regulations and contract terms, and meeting organizational goals and standards. Unanet plays a pivotal role in navigating the complexities of government contracting, specifically, indirect rates and costs.

Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Unanet

How much do you know about DCAA and its oversight of your incurred cost proposals (ICP) and indirect cost rates? Would it help to understand what is done and why? Knowing what initiates a DCAA audit of an incurred cost proposal and maintaining a good system of internal controls can potentially keep you from audit.

Topics: Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)

Job costing involves tracking all expenses related to a specific job or project, including materials, labor, subcontractors, travel, and various other costs. For government contractors, this is especially crucial. In the context of payroll, job costing means taking each labor dollar and accurately allocating it to the appropriate cost pool and project. So, theoretically, all you need to do is set up a few projects, establish a DCAA-compliant chart of accounts, ensure you're following FAR Part 31 cost principles, and you’re ready to go, right? Unfortunately, it’s not that simple.

Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, Quickbooks, Federal Acquisition Regulation (FAR)

Does the Government find most of the cost incurred by a contractor to be reasonable? I must say it does appear that way. Defense Contract Audit Agency (DCAA) FY 2023 Report to Congress shows that of the $186B incurred cost audited, there was only $1.1B in audit exceptions (.6%). So, the world is good, and we can move on. If that were only the case. Remember that while this percentage is low, this is money you have already spent that the Government will not pay you for, which directly impacts your bottom line.

Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

Again, this year our friendly DCAA auditors have taken up the government requirement to calculate and publish annually the new compensation cap as provided for in Section 702 of the Bipartisan Budget Act of 2013 (BBA; Pub. L. 113-67), dated December 26, 2013. The 2025 compensation cap amount is $671,000. Below we have provided the compensation caps going back to 2019.

Topics: Proposal Cost Volume Development & Pricing, Employee & Contractor Compensation, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)