Do I need to file for Incurred Cost Submission (ICS)? If you have performed one or more Cost Reimbursable or Time and Materials (T&M) contracts (prime AND subcontracts) during your fiscal year in accordance with Federal Acquisition Regulations (FAR) 52.216-7, you will need to complete and submit Incurred Cost Submission (ICS) to the DCAA and DCMA.
When is the due date for ICS submissions? Incurred cost claims are due six (6) months after completion of the contractor’s fiscal year end.
What documentation do I need to provide? In accordance with the DCAA ICE Model, the following information is required in an ICS.
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
Why should you care? You may have to lower your rates and pay the government back the difference if your overhead costs are less than projected. It is important to monitor your costs, particularly overhead costs before your ICS is due. Should your costs be lower than projected maybe it’s time to make an investment that you have been putting off in efforts to maintain your billing rates. On the other hand, if your costs are much higher than expected you don’t want to wait until the end of the year to try to cut costs or tell your client that rates are going up. Lastly, if submissions are late, you may be at risk to lose the ability to bill the government and could even be subject to penalties.
Now What? Do you have questions about your ICS? Contact PCI’s government contract specialists to prepare or review your Incurred Cost Submission. Contact us today!
