The ASBCA Giveth and the Federal Circuit Taketh Away

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

The Incurred Cost Submission: Why are Schedules H and J Important?

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

2023 Compensation Cap Update

Executive Compensation Limit for Government Contractors

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

The Court of Appeals Reverses The Armed Services Board in The Raytheon Case

Apparently, nothing the Board found was to the liking of the judges at the United States Court of Appeals for the Federal Circuit in Case Number 21-2304, Secretary of Defense v. Raytheon Company, Raytheon Missile Systems, decided January 3, 2023. This was the appeal from the Armed Services Board of Contract Appeals in Nos. 59435, 59436, 59437, 59438, 60056, 60057, 60058, 60059, 60060, and 60061.

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Topics: Incurred Cost Proposal Submission (ICP/ICE), Government Regulations, Federal Acquisition Regulation (FAR)

The Incurred Cost Submission: Why are Schedules B, C, D, and Fringe Important?

Schedules B, C, D, and Fringe 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 B, C, D, and Fringe, and the importance of each schedule.

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Topics: Incurred Cost Proposal Submission (ICP/ICE), Vlog

The Incurred Cost Submission: Why is Schedule K Important?

Schedule K is one of the most important parts of the Incurred Cost Submission and is an area of great interest for the Government and its auditors. This VLOG will briefly explain the Incurred Cost Submission, how to complete Schedule K, and the importance of Schedule K.

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Topics: Incurred Cost Proposal Submission (ICP/ICE), Vlog

The Incurred Cost Submission: Why is Schedule I the Most Important Schedule?

Schedule I is the most important part of the Incurred Cost Submission and is the single area of great interest for the Government and its auditors. This VLOG will briefly explain the Incurred Cost Submission, the importance of Schedule I, and how to resolve potential issues.

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Topics: Incurred Cost Proposal Submission (ICP/ICE), Vlog

Limitation on Pass-Through Charges in Government Contracts


Does the Total of All Proposed Subcontract Costs Exceed 70% of the Total Contract Costs?

Is your company submitting a proposal to the government/prime contractor that includes a total of all subcontract costs exceeding 70 percent of the total costs proposed? If so, you must identify “added value” in your proposal so the government/auditor does not classify the indirect cost applied to the total subcontract cost as “excessive pass-through charges.”  The government considers indirect costs and profit/fee that a contractor applies to subcontract costs that exceed 70 percent of the contract to be “pass through costs.” This applies to lower tier subcontract costs also. If there is no negligible value added by the contractor, the government or auditor will question the indirect costs and profit/fee applied to the subcontract costs as unallowable excessive pass through under FAR 31.203(i).

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Topics: Compliant Accounting Infrastructure, Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations

Preparing for Incurred Cost Submissions with Deltek Costpoint

Now that year-end and quarter 1 is behind us, what is next? If you guessed Incurred Cost Submissions (ICS), you are correct. June 1st is fast approaching and there are a few housekeeping items you can do to ensure that your accounting team has an efficient and painless process ahead of them.

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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Deltek Costpoint

Does Micro-Purchase Threshold Apply to Government Contractors?


Government Contractor Purchases below the Micro-Purchase Threshold Require NO Documentation

This is a common misconception within the GOVCON community. While the expectations are clearly less documentation and effort are required than that of a larger dollar value purchase, there is not a magic threshold at which NO documentation of the fair and reasonable price is allowed.

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Topics: Compliant Accounting Infrastructure, Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)