Current FAR Requirements
Federal Acquisition Regulations (FAR) 42.101 provides that normally, “the Defense Contract Audit Agency (DCAA) is the responsible Government audit agency.” While DCAA’s website states “DCAA provides audit and financial advisory services to DoD and other federal entities responsible for acquisition and contract administration.” DCAA only has appropriated funds to provide services to the Department of Defense (DoD). All other federal agencies must pay for DCAA services. This can make a decision related to the necessity of an audit service a budget-based decision. Today, DCAA is current on the required incurred cost audits of contractors with DoD contracts, but contractors with mostly National Aeronautics and Space Administration (NASA) contracts are years behind in their required incurred cost audits. If, as the FAR states, “DCAA is the responsible Government audit agency,” why is it not a Federal audit agency (dare we say – FCAA)? This would make things much easier for NASA and other federal agencies that need their contracts audited. However, given that this isn’t the case, DCAA is not the only option for federal agencies. Many agencies other than DoD have contracted with third-party CPA firms to get necessary audits performed.
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Topics:
Incurred Cost Proposal Submission (ICP/ICE),
DCAA Audit Support,
Government Regulations,
Grants & Cooperative Agreements (2 CFR 200)
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 2024 cap amount is $646,000. Below, we have provided the compensation caps going back to 2016.
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Topics:
Employee & Contractor Compensation,
Incurred Cost Proposal Submission (ICP/ICE),
DCAA Audit Support,
Government Regulations,
Federal Acquisition Regulation (FAR)
It’s that time of year to start thinking about the preparation of the incurred cost proposal if you are a Contractor with flexibly priced contracts. The incurred cost proposal is required for cost type, time, and material contracts subject to FAR 52.216-7, “Allowable Cost and Payment.” Cost type and time and material contracts have a cost-reimbursable element that needs to be trued up (i.e., final indirect rates), hence the reason for the incurred cost proposal. There are many subsections listed within the FAR clause 52.216-7(d), thus defining the required schedules for an adequate indirect cost rate proposal.
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Topics:
Incurred Cost Proposal Submission (ICP/ICE)
Starting back in 2021, DCAA issued updates to its audit programs supporting the audit of incurred cost. Here are a few interesting things we noted in the updates.
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Topics:
Incurred Cost Proposal Submission (ICP/ICE),
DCAA Audit Support,
Government Regulations,
Federal Acquisition Regulation (FAR)
What is the Incurred Cost Submission? What is Schedule O? What are the Supplemental A Schedules? This VLOG will briefly explain the Incurred Cost Submission, how to complete Schedules O and the Supplemental A Schedules, and the importance of those schedules.
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Topics:
Incurred Cost Proposal Submission (ICP/ICE),
Vlog
In a saga which conjures up the phrase: “It ain’t over till it’s over” (quotation attributed to the late, great Yogi Berra), the US Court of Appeals for the Federal Circuit (Case 21-2304) in a decision dated 01-3-2023, reversed an ASBCA Decision (60091, et al), the latter having found Raytheon’s policies for tracking potentially unallowable Lobbying and Organization costs to be reasonable, thus allowable.
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Topics:
Incurred Cost Proposal Submission (ICP/ICE),
DFARS Business Systems
Schedules H and J are some of the most important parts of the Incurred Cost Submission. This VLOG will briefly explain the Incurred Cost Submission, how to complete Schedules H and J, and the importance of each schedule.
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Topics:
Incurred Cost Proposal Submission (ICP/ICE),
Vlog