SlideShare a Scribd company logo
INCURRED COST SUBMISSIONS (ICS)
WEBINAR
Presented By: Tetiana Gervis, CPA
Senior Associate, Industry Specialty Services, BDO
Hosted By: Kim Koster
VP of Corporate Strategy, Unanet
AGENDA
2
Overview of Presentation
I. Background
II. Timeline and Submission
III. Preparation Techniques and Best Practices
IV. ICS Audit Trends
V. Questions
BDO USA, LLP, a Delaware limited liability partnership, is
the U.S. member of BDO International Limited, a UK
company limited by guarantee, and forms part of the
international BDO network of independent member firms.
BACKGROUND
WHAT IS AN INCURRED COST SUBMISSION (ICS)?
4
 Formally known as an Indirect Cost Rate Proposal (ICP, ICRP or ICS); used interchangeably.
 Purpose is to establish final annual indirect cost rates and determine over/under billing for the
period covered by the ICS (presented on Schedule I)
 The submission includes the direct and indirect expenses incurred by the contractor during its
fiscal year.
 ICS schedules show the detailed calculations of indirect pool(s) and base(s), a summary of costs
incurred by contract, other supporting schedules, and the Certificate of Final Indirect Costs.
 Rates developed from this submission are used for a variety of purposes, typically as the source
or starting point for calculations such as Provisional Billing rates, Forward Pricing rates, etc.
REQUIREMENTS
5
 FAR 52.216-7 - Allowable Cost and Payment requires Government contractors to “submit an
adequate final indirect cost rate proposal to the Contracting Officer (or cognizant Federal
agency official) and auditor within the 6-month period following the expiration of each of its
fiscal years.”
 Reasonable extensions may be requested in writing by the Contractor and granted in writing by
the Contracting Officer.
 The proposed rates shall be based on the Contractor’s actual cost experience for that period.
 The Allowable Cost and Payment clause applies to cost-reimbursement type and T&M contracts
(FAR 16.307).
 All federal contracts should be included and reported individually. It is permissible to lump or
group all commercial and fixed price work together. In total, all contract costs should reconcile
to the Trial Balance and other books of record.
• For Subcontractors: Refer back to your subcontract agreement to ascertain whether the
Allowable Cost and Payment clause has been flowed-down; thus requiring subcontractors to
prepare and provide an incurred cost submission.
WHY IS AN ICS SIGNIFICANT?
6
 Finalized indirect cost rates provide for a timely settlement of costs under cost-reimbursement
and T&M contracts.
• The establishment of final rates shall be used for contract closeout (unless quick-closeout
procedures are used).
 The ICS is the contractor’s final opportunity to voluntarily disallow costs (pre-audit) that could
be perceived or determined to be unallowable.
 Adjusts provisional or interim billing rates as necessary to establish the final indirect cost rates
after year end.
 Final indirect cost rates are used in negotiating the final price of Federal contracts and in other
situations requiring that indirect costs be settled before contract prices are established.
 An ICS can provide a historical basis for the determination of final rates and which can be used
to forecast provisional rates.
 Contractors must update billings on all contracts to reflect the final indirect cost rates and
update the schedule of cumulative direct and indirect costs claimed and billed within 60 days
after settling final rates (per FAR 52.216-7(d)(2)(v)).
WHY IS AN ICS SIGNIFICANT? (CONT.)
7
 Concluding the audit of an ICS, the contractor and contracting officer will execute a written
understanding specifying the terms and finalization of indirect rates, which would include:
• The agreed-upon final indirect cost rates,
• The bases to which the rates apply,
• The periods for which the rates apply,
• Any specific indirect cost items treated as direct costs in the settlement, and
• The affected contract and/or subcontract, identifying any with advance agreements or special
terms and the applicable rates.
 The written agreement does not change any monetary ceiling, contract obligation, or specific
cost allowance or disallowance provided for in the contract.
BDO USA, LLP, a Delaware limited liability partnership, is
the U.S. member of BDO International Limited, a UK
company limited by guarantee, and forms part of the
international BDO network of independent member firms.
TIMELINE AND SUBMISSION
TIMELINE FOR AN INCURRED COST SUBMISSION
9
 Per FAR 52.216-7, an incurred cost submission is due within six (6) months after the contractor’s
fiscal year end (FYE).
 If the contractor does not submit the proposal within six (6) months of its FYE the DCAA may
send reminder letters to the contractor.
 Once the submission becomes six (6) months overdue (one year after the end of the fiscal year)
and no extension has been granted by the Contracting Officer, the DCAA auditor may provide the
CO with unilateral rate recommendations. As a result, the Contracting Officer can make a
unilateral determination as authorized by FAR 42.703-2(c)(1) and FAR 42.705(c)(1).
 Delinquent ICS’ result in rate recommendations that will be based on either (1) a decrement
factor applied to indirect rates using relevant contractor historical data or (2) a company-wide
decrement factor based on questioned costs at high risk contractors applied to total contract
costs, if no relevant historical data exists.
 The rate recommendation will apply to active contracts, as well as physically complete
contracts for the overdue fiscal year end.
INCURRED COST SUBMISSION AUDIT
10
 After submission, and the determination has been made that a contractor’s incurred cost
submission is adequate, then typically the cognizant DCAA Field Audit Office (FAO) will initiate
the incurred cost audit within six months after receipt of an adequate proposal.
 The audit is guided by DCAA’s Post Year End Incurred Cost Audit Program
 During the course of the audit, the DCAA auditor should discuss audit findings with the
government contractor as they arise.
 The contractor is expected to provide timely feedback on these issues to ensue prompt
resolution of audit findings and facilitate an efficient and effective audit process.
 An exit conference will be held to summarize issues and resolutions identified during the audit
process when significant audit findings are found.
INCURRED COST SUBMISSION AUDIT (CONT.)
11
 The contractor will be given a final opportunity to respond to the audit findings and comments
submitted by the contractor will be included in the audit report (as comments should have been
relayed during the audit process as questioned costs were identified).
 The DCAA office provides the final report to the contracting officer (CO) (or cognizant Federal
agency official) for establishing the final indirect cost and billing rates.
 The Contracting Officer may provide the government contractor an opportunity to personally
address the results of the audit report during “Negotiations.”
 During negotiations the contractor’s position and supporting documentation is presented and
considered prior to the CO issuing its final decision regarding questioned costs and final indirect
cost rates. DCAA auditors can be extended the invitation to attend negotiations.
 Within 120 days, or longer if approved in writing by the CO, after settlement of the final annual
indirect cost rates for all years of a physically complete contract, the contractor must submit a
completed invoice or voucher reflecting the settlement amount and rates (e.g., “ICS True-up”).
WHAT DCAA LOOKS FOR…
12
 An adequate incurred cost submission: use of the ICE Model (or similar format) containing all of
the required schedules.
 Schedule N is signed by an authorized party (usually CFO or above).
 A contractor’s submission of all claimed costs incurred for cost type and/or T&M reimbursable
government contracts, including adjustments and explanatory notes.
 Identification of unallowable costs (voluntary deletions) and expressly unallowable costs with
notes accompanying adjustments.
 Identification, by contract, of awards containing FAR 52.242-3 - Penalties for Unallowable Costs
(penalty clause).
 If costs are reasonable, allocable, and allowable in accordance with GAAP, CAS, FAR, and
contract provisions.
WHAT DCAA LOOKS FOR…(CONT.)
13
 Certain “trigger” accounts that may contain unallowable costs. The process for identifying
accounts with a higher probability of being selected for testing consists of, but is not limited to:
• If there have been any changes to the indirect cost rate structure between the last audited fiscal year and
the year in review. Both direct and indirect costs will be evaluated
• The results of performing a comparative analysis between the CFY and prior fiscal year pool expenses and
direct costs
• New accounts
• Prior years incurred cost audit or other audit findings
• Audit Leads
• Fraud Risk Indicators
• Audit history/experience with the government contractor
• Auditor judgment
BDO USA, LLP, a Delaware limited liability partnership, is
the U.S. member of BDO International Limited, a UK
company limited by guarantee, and forms part of the
international BDO network of independent member firms.
PREPARATION TECHNIQUES AND BEST
PRACTICES
PREPARATION TECHNIQUES
15
Use of DCAA ICE Model
 The purpose of the DCAA ICE Model is to assist contractors in meeting its requirement for
submitting an adequate final indirect cost rate proposal as required by FAR 52.216-7(d).
 The ICE Model schedules present the minimum information needed to begin an audit and can be
obtained at: http://www.dcaa.mil/ice_model.html.
 The required content of the proposal and the supporting data will vary depending on the size of
the firm, complexity of the accounting system, and type of business. Verify that the latest
model is being used or downloaded.
 Use of the Model is preferred, although not mandatory, as long as the submission includes the
required schedules and support.
 The company name and fiscal period should be included on all schedules submitted.
 A separate schedule needs to be prepared for each final and intermediate indirect expense pool.
If pool costs are accumulated by department, departmental expenses should be identified within
each pool.
 DCAA prefers that contractors include an index, similar to that used in the model, and note if
certain schedules are not applicable.
 Contractors are encouraged to submit their proposal in electronic format.
REQUIRED VS. SUPPLEMENTAL
16
 Required Schedules
• To be completed and provided to DCAA at the time of submission, if applicable.
• Some schedules, while identified as required, do not have to be completed if the schedule
does not apply to the company (i.e., Capital Cost of Money, Intermediate Schedules).
 Supplemental Schedules
• Additional schedules which are not required to be provided at the time of submission for the
determination of an adequate submission; however, may be required during the audit process.
• Can be requested to be provided at the entrance conference to help determine audit risk,
preliminary and field audit steps.
• Federal contractors should consider completing and including the supplemental schedules at
the time of submission to decrease delays in facilitating the audit.
REQUIRED SCHEDULES
17
 Per FAR 52.216-7(d)(2)(iii) An adequate indirect cost rate proposal shall include the following
data unless otherwise specified by the cognizant Federal agency official:
Indirect Cost Pools
• Schedule A – Summary of all Claimed Indirect Expense Rates
• Schedule B – General and Administrative (G&A) Expenses (final)
• Schedule C – Overhead Expenses (final)
• Schedule D – Intermediate/Occupancy Expenses (e.g., Facilities, Homogeneous Service
Centers, Home Office)
• Schedule E - Claimed Allocation Bases by element of cost used to distribute indirect costs
• Fringe* - Schedule of Fringe Benefit Expenses
• Schedule F – Facilities Capital Cost of Money Factors Computation
*Although not individually listed as a required schedule for adequacy, a separate schedule for these expenses are normally created. An
alternative is to include the fringe expenses on Schedule D-x.
REQUIRED SCHEDULES (CONT.)
18
Contract Costs
• Schedule G – Reconciliation of Books of Account and Claimed Direct Costs by Major Cost
Element
• Schedule H – Schedule of Direct Costs by Contract/Subcontract and Indirect Expense Applied
at Claimed Rates (as well as a subsidiary schedule of Government Participation percentages in
each of the allocation base amounts)
• Schedule I – Cumulative Direct and Indirect Costs Claimed and Billed by Contract and
Subcontract
• Schedule J – Subcontract Information
• Schedule K – Summary of Time-and-Materials and Labor-Hours contract, including labor
categories, labor rates, hours, direct materials, other direct costs, and indirect expenses
applied at claimed rates
Other Schedules
• Schedule L – Reconciliation of Total Payroll per IRS Form 941 to Total Labor Distribution Costs
• Schedule M – Listing of Decisions/Agreements/Approvals and Description of
Accounting/Organizational Changes
• Schedule N – Certificate of Final Indirect Costs
• Schedule O – Contract Closing Information for Contracts Completed in this Fiscal Year
KEY SCHEDULES
19
Schedule B is linked to the following SCHEDULE B
schedules: ICE (version 2.0.1g)
Sched D (x), Intermediate Allocations
Sched E, Bases
Sched H, Contract Costs General and Administrative (G&A) Expenses (Final Indirect Cost Pool)
Summary Sch H
Sched P, IR&D/B&P
ICE MANUAL
RECHECK FORMULAS AND LINKS AFTER COMPLETING SCHEDULE
TOTAL PER
ACCOUNT G/L, F/S
NUMBER DESCRIPTION Amount & TRIAL BAL. ADJUSTMENT CLAIMED NOTES Reference
- -
- -
- -
SUBTOTAL - - - -
Intermediate Allocations:
SUBTOTAL - - - -
IR & D Mat'l,Trvl,ODC(Sum SCH H) - - SUM SCHED H
IR & D Labor (Sum SCH H) - - SUM SCHED H
IR & D Overhead(Sum SCH H & SCH E) - - - 1 SUM SCHED H SCHED E
B & P Mat'l,Trvl, ODC(Sum SCH H) - - SUM SCHED H
B & P Labor (Sum SCH H) - - SUM SCHED H
B & P Overhead(Sum SCH H & SCH E) - - - 1 SUM SCHED H SCHED E
-
TOTAL G & A EXPENSE POOL - - -
Acct Balances
Enter Company Name Here
Enter Company Location Here
General and Administrative (G&A) Expenses
Fiscal Year End - mm/dd/yyyy
Insert rows as needed here, then copy data (Account Number, Desc,
Amount by Dept) from accounting records. Delete this textbox.
Schedule B
 G&A costs broken down by account name and number (before intermediate allocations)
 Any intermediate allocation amounts from Service Center, Home Office, Fringe, etc.
 B&P costs broken out separately into Labor, Fringe, Overhead, and ODC’s
 Total expense pool amount
 All unallowable costs should be deducted out in the adjustments column in the schedule
KEY SCHEDULES (CONT.)
20
Schedule C
 Schedule of Overhead claimed expenses by element of cost as identified in accounting records for
each final indirect cost pool
 Calculates overhead expenses, those costs that are closely associated with contract performance
• Support functions for direct labor, subcontractors, etc.
 Schedule includes details of costs by account name and number (before intermediate allocations)
• One schedule per O/H Pool (e.g., Manufacturing, Engineering, Onsite, Offsite, FCCOM)
• Any intermediate allocation amounts from Service Center, Fringe, etc.
Schedule C is linked to the following SCHEDULE C (1)
schedules: ICE (version 2.0.1e)
Schedule D(x)
ICE MANUAL
RECHECK FORMULAS AND LINKS AFTER COMPLETING SCHEDULE
ACCOUNT TOTAL PER G/L
NUMBER DESCRIPTION Amount & TRIAL BAL/FS ADJUSTMENTS CLAIMED Notes Ref.
- -
- -
- -
Subtotal - - - -
Intermed Pool-1 - - - - Sched D (1)
ADD: Fringe Allocation - - - Fringe
Total Overhead Pool - - -
Enter Company Name Here
Acct Balances
Enter Company Location Here
Overhead
Fiscal Year End - mm/dd/yyyy
Overhead Expenses (final indirect cost pool)
Insert rows as needed here, then copy data (Account Number, Desc,
Amount by Dept) from accounting records. Delete this textbox.
KEY SCHEDULES (CONT.)
21
Schedule D
 Intermediate pools, containing costs not specifically associated with any one pool
 Types of intermediate pools include:
• Home Office expenses*
• Service Centers
• Fringe Benefits
*Home Office allocations generally require a separate ICS to be formally prepared and submitted.
This Schedule does not contain any links to SCHEDULE D (1)
other schedules. ICE (version 2.0.1e)
ICE MANUAL
IMPORT DATA FROM ACCOUNTING RECORDS
RECHECK FORMULAS AND LINKS AFTER COMPLETING SCHEDULE
ACCOUNT PER G/L
NUMBER DESCRIPTION & TRIAL BAL/FS ADJUSTMENT CLAIMED NOTES REFERENCE
-
- 1
-
Total - - -
ADD: Fringe Allocation - - - Fringe
Total W / Alloc. - - - TO Sched A
Allocation of Expenses Based on
Square Feet Utilized ( Preparation Note 4 & Sample Note 2)
Claimed Allocation
Base % of Expense of Amts per
(i.e. Sq. Ft.) Total Adjustments Allocation G/L See Preparation Note 4
G & A TO Sched B
Amount 0.00% - - 2
O/H - OH TO Sched C (1)
Amount 0.00% - -
O/H - F_Pool-6 TO Sched C (6)
Amount 0.00% - -
- 0.00% - - TO Sched A
Enter Company Name Here
Enter Company Location Here
Intermed Pool-1 (Intermed. Pool)
Fiscal Year End - mm/dd/yyyy
Intermediate Indirect Cost Pool
Insert rows as needed here, then copy data (Account Number, Desc, Amount)
from accounting records. Delete this textbox.
FRINGE
FRINGE BENEFITS POOL
Account Account Name
Year to Date
Per G/L Adjustments Claimed Amount Notes Ref.
4510 Health and Life Insurance 550,000 - 550,000
4520 401(k) Contributions 158,000 - 158,000
4530 Payroll Taxes 37,500 - 37,500
4540 Holiday Leave 34,654 - 34,654
4550 Disability Leave 32,675 - 32,675
Total Pool 812,829 - 812,829
Total Base 3,678,302 - 3,678,302 Sch. E
Fringe Rate 22.10%
Fringe Allocated Labor Dollars % of Total
Direct Labor 2,998,724 81.52% 662,656$ To Sch. H
Overhead Labor 257,036 6.99% 56,800$ To Sch. C
G&A Labor 275,675 7.49% 60,918$ To Sch. B
Technology Service Center Labor 146,867 3.99% 32,455$ To Sch. D
Total Labor 3,678,302 100% 812,829
Fringe Allocated
ABC, LLC
Anywhere, VA
FISCAL YEAR ENDED 12/31/2014
FRINGE
22
Schedule D
 Missing allocation tables on both Fringe and Intermediate allocation schedules. The allocation
table must include:
• Allocation base by recipient (i.e., direct labor, overhead, G&A, subcontract costs);
• The percentage of the total base for each recipient; and
• The total dollars allocated to each recipient.
A B
B
A
KEY SCHEDULES (CONT.)
KEY SCHEDULES (CONT.)
23
Schedule E is linked to the following SCHEDULE E
schedules: ICE (version 2.0.1e)
Summary Sched H
Sched H, Contract Costs
Schedule C(x), Overhead
Schedule B, G&A
ICE MANUAL
RECHECK FORMULAS AND LINKS AFTER COMPLETING SCHEDULE
PER G/L, F/S PER G/L
Fringe Pool & TRIAL BAL/FS ADJUSTMENTS CLAIMED Notes Ref.
Fringe Pool -$ -$ -$ Fringe
Fringe Base:
G&A Labor -$ -$ Fringe
Direct Labor - - "
Indirect Labor (Overhead Pools) - - "
Indirect Labor (Intermediate Pools) - - "
Total Fringe Base -$ -$ -$
Fringe Rate 0.00% 0.00%
Fringe Base* - Straight time direct and indirect labor dollars.
PER G/L, F/S PER G/L
& TRIAL BAL/FS ADJUSTMENTS CLAIMED Notes Ref.
G&A Pool -$ -$ -$ Sched B
G & A Base:
Contract Labor -$ Summary Sched H
Contract Travel - "
Contract Material - "
Other Direct Costs - "
Subcontracts - "
Subtotal = DIRECT COSTS -$
General Ledger Overhead (before adjustments) - Sched C (x)
Less: IR&D/B&P O/H transferred to G & A pool.
IR &D O/H (at G/L rate) - SCHED B
B&P O/H (at G/L rate) - "
Less: Material related costs to arrive at Value Added base.
Direct Material -
Subcontracts -
Other Misc Adjustments to G&A Base (provide detailed support) -
G&A Base - Value Added (exludes IR&D/B&P and COM) -$
G&A Rate 0.00%
Enter Company Name Here
Enter Company Location Here
Fiscal Year End - mm/dd/yyyy
Claimed Allocation Bases by element of cost used to distribute indirect costs
Schedule E
 Calculates the allocation bases for all final indirect pools
KEY SCHEDULES (CONT.)
24
Schedule E
 Costs in each base should be broken down and by line item and entered as a link to other inputs
in the ICS, such as schedules H or otherwise
 Schedule A should reference base amounts included on Schedule E
 Adjustments should be thoroughly explained via footnotes
 No information should be hardcoded
 Allocation bases for intermediate pools are sometimes incorporated as well*
 Example allocations bases include:
• G&A: Total Cost Input (TCI) or Value Added (TCI less direct subcontracts and direct materials)
• Subcontracts and Material Handling (SM&H): direct subcontracts and direct materials
• Overhead: direct labor, and fringe, plus B&P/IR&D labor and B&P/IR&D fringe
• Fringe: total labor, FTE, headcount
• Facilities: square footage or headcount
*The intermediate allocation bases will also need to be included on Schedule D
KEY SCHEDULES (CONT.)
25
Schedule E
 Explanation of all allocation bases must be included and match its description.
SCHEDULE E
DESCRIPTION Allowable Costs
Unallowable
Costs Total NOTES
Fringe Pool:
765,398$ - 765,398$ Sch. Fringe
Fringe Base:
Total Labor Dollars 6,754,398$ -$ 6,754,398$ Sch. E-1
Fringe Cost Base is total labor dollars for all full and part-time employees.
G&A Pool:
987,543$ -$ 987,543$ Sch. B
G&A Base:
Contract Direct Costs
Labor 777,568$ 777,568$ Sch. H
Fringe 136,353 136,353 Sch. H
ODCs 4,743,088 4,743,088 Sch. H
Materials & Subcontracts 126,582 126,582 Sch. H
Indirect Expenses 159,868 159,868 Sch. H
Total Direct Costs 5,943,459$ - 5,943,459$
Overhead Before Adjustments 140,785$ 140,785$ Sch. C
Value Add Base 6,084,244$ - 6,084,244$ Sch. B
G&A Base is total direct and indirect costs, except G&A, material and subcontract costs (value-added cost input).
CLAIMED ALLOCATION BASES BY COST ELEMENT OF COST USED TO DISTRIBUTE INDIRECT COSTS
FISCAL YEAR ENDED 12/31/14
ABC, LLC
Anywhere, VA
KEY SCHEDULES (CONT.)
26
Schedule F
 Facilities Capital Cost of Money (FCCM)
• Costs associated with facilities capital used to perform a contract
• Cost of money rate is the arithmetic mean of the interest rates (most recent) specified by the
Secretary of the Treasury (CAS 414)
• Applies the cost of money to the capital used, as long as it is allocated correctly and is
allowable
Schedule F is linked to the following schedules: SCHEDULE F
Schedule F-1, Net Book value of Assets ICE (version 2.0.1e)
Summary Schedule H, Contract Costs
Schedule E, Bases FACILITIES CAPITAL
ICE MANUAL COST OF MONEY FACTORS COMPUTATION
Computing COM Rate:
Treasury
Rate Mos. COM Rate
Jan - Jun 6.00 0.000%
Jul - Dec 6.00 0.000%
0.000%
RECHECK FORMULAS AND LINKS AFTER COMPLETING SCHEDULE
NBV BASES
Sched F-1 Sched E
1. Applicable 2. Accumulation 3. Allocation of 4. Total Net 5. COM for Cost 6. Allocation 7. Facilities
Company 1 Cost of Money & Distribution of Undistributed Book Value Accounting Base For Capital COM
Cost Accounting Period 20xx Rate NBV Period Period Factors
Recorded 0.00% - (Basis Of Allocation) (Column 2+3) (Column 1*4) In units (Column 5/6)
Business Leased Property - of measure
Unit Corporate/Group
Facilities Total -
Capital Undistributed -
Distributed -
Overhead Unused - - - - - 0.00000
Pools Unused - - - - - 0.00000
LESS: COM on IR&D/B&P Labor:
Unused - - 0.00000 Sum Sched H
Unused - - 0.00000
Subtotal -
G&A G & A - - - -
Expense Pools ADD: COM on IR&D/B&P Labor -
Subtotal: - - 0.00000
TOTAL - - - -
Enter Company Name Here
Enter Company Location Here
Fiscal Year End - mm/dd/yyyy
Months percentage added for demonstration purposes -
adjust as needed
KEY SCHEDULES (CONT.)
27
Schedule H is linked to the following schedules: SCHEDULE H
Schedule A - Applied Overhead, G&A, & COM Rates ICE (version 2.0.1e)
Summary Schedule H
Schedule H-1 Govt Participation
ICE MANUAL
INPUT DATA FROM ACCOUNTING RECORDS
RECHECK FORMULAS AND LINKS AFTER COMPLETING SCHEDULE Sched A
Total Claimed Direct G&A Claimed
JOB SUBCONTRACT Labor Total Sub- Direct O/H Costs Plus Base G &A Total Total Grand
ORDER CONTRACT NUMBER NUMBER OH Labor Travel Material ODC Contracts Costs OH O/H (Value Added) Applied Costs COM Total
XX. CONTRACT TYPE
- - - - - - - - -
- - - - - - - - -
- - - - - - - - -
- - - - - - - - -
- - - - - - - - -
XX. TOTAL CONTRACT TYPE: - - - - - - - - - - - - - -
TOTAL CONTRACT COSTS - - - - - - - - - - - - - -
IR & D - - - -
B& P - - - -
TOTAL IR & D/B & P - - - - - - - - -
GRAND TOTAL - - - - - - - -
Enter Company Name Here
Enter Company Location Here
Fiscal Year End - mm/dd/yyyy
Schedule of Direct Costs by Contract/Subcontract
and Indirect Expense Applied at Claimed Rates
Sched A
Schedule H
 This schedule is one of the most important and the basis for a large portion of the submission
 Calculates actual incurred costs by contract, broken out by contract type and element of cost
KEY SCHEDULES (CONT.)
28
Schedule H
 Project status reports or detailed project ledgers are traditionally used to compile direct costs
for each contract
 Indirect rates (as calculated in Schedule A) are applied to the direct contract costs to determine
the total indirect expenses for each contract
 Only Flexibly Priced Federal awards are required to be separately identified on Schedule H (at
billing level), commercial or other non-Federal contracts can be aggregated as one line item
 Best Practices:
• Include federal agency/customer name, by award
• Differentiate between claimed and unclaimed (non-billable) direct costs by cost element and
applied indirect costs
• Include a column which totals both claimed and unclaimed amounts, by cost element
• Reconcile total costs incurred on Schedule H to Trial balance or detailed General Ledger
• Include attributes of clients accounting structure (i.e., project codes) into schedule to allow
for simple edits
• Calculate indirect rate caps on this schedule for greatest efficiency and easy linkage to
Schedule I
• Use commercial ‘plug’ to save time, if appropriate
29
Schedule H
 Prime/Sub Contract numbers must be included on the Schedule H and be consistent across
Schedules H, I,J, and K.
 Prepared at the billing level
 Best Practice: Include customer name/federal agency, by award.
SCHEDULE H
Sch. A Sch. A Sch. A Sch. A
20.56% 15.45% 8.35% 4.56%
Award Type Customer
Name
Project
No.
Project
Name
Contract
No.
Subcontract No. Direct
Labor
Travel ODCs Total Direct
Costs -
Value Add
Materials Subcontracts Allowable
Fringe
Allowable
Overhead
Value Add
Direct Costs
Plus Fringe &
OH
G&A Total
M&S
M&S
Handling
Grand
Total
COSTTYPE
CPAF (Agency) 100 ABC ABC-123-000 3,255 5,554 6,644 15,453 - - 669 606 16,729 1,397 - - 18,125
CPFF (Agency) 101 DEF ABC-234-000 STU 4,523 4,344 55,533 64,400 4,663,000 344,422 930 842 66,172 24,592 5,007,422 228,338 5,326,525
COSTTYPE TOTAL 7,778 9,898 62,177 79,853 4,663,000 344,422 1,599 1,449 82,901 25,988 5,007,422 228,338 5,344,650
T&M (Agency) 200 GHI CDE-456-000 VWX 345,435 43,533 6,332 395,300 - 553,322 71,021 64,343 530,664 46,417 553,322 25,231 1,155,635
345,435 43,533 6,332 395,300 - 553,322 71,021 64,343 530,664 46,417 553,322 25,231 1,155,635
Fixed Price (Agency) 300 JKL EFG-678-000 15,345 2,567 664 18,576 55,633 - 3,155 2,858 24,589 2,265 55,633 2,537 85,024
FIXEDPRICE TOTAL 15,345 2,567 664 18,576 55,633 - 3,155 2,858 24,589 2,265 55,633 2,537 85,024
COMMERCIAL 500 MNO HIJ-932-029 125,555 13,000 1,409 139,964 - - 25,814 23,387 189,165 15,795 - - 204,960
IR&D/B&P 900 PQR 34,229 986 283 35,498 - - 7,037 6,376 48,911 - - - 48,911
GRANDTOTAL 528,342 69,984 70,865 669,191 4,718,633 897,744 108,627 98,412 876,230 90,466 5,616,377 256,107 6,839,180
Sch. C Sch. B Sch. C-1
5,616,377
Sch. E- Mat. & Sub Handling
T&M TOTAL
SCHEDULE OF DIRECTCOSTS BY CONTRACT/SUBCONTRACT
FISCALYEARENDED12/31/14
Anywhere, VA
ABC, LLC.
ANDINDIRECTEXPENSE APPLIEDATCLAIMEDRATES
KEY SCHEDULES (CONT.)
30
Schedules B through E to H
 Pool and Base amounts on Schedules B through E must tie to Schedule H.
A
A
B
B
Schedule C
OVERHEADPOOL
Account AccountName YeartoDate PerG/L Adjustments ClaimedAmount
7000 OverheadLabor 53,892 - 53,892
7010 LaborNonAllowable 2,494 - 2,494
7020 Travel 14,632 - 14,632
7030 Professional Fees 17,932 - 17,932
Subtotal OverheadPool 88,950 - 88,950
Intermediate Allocation
TechSvcCenterAllocation 9,462 - 9,462
Total OverheadPool 98,412 - 98,412
BASETOTAL 636,900 - 636,900
OverheadRate 15.45%
ABC,LLC
Anywhere,VA
FISCALYEARENDED12/31/2014
CONTRACTORSITEOVERHEAD
SCHEDULE H
Sch. A Sch. A Sch. A
15.45% 8.35% 4.56%
Award Type Customer
Name
Allowable
Overhead
Direct Costs
Plus Fringe &
OH
G&A Total
M&S
M&S
Handling
Grand
Total
COST TYPE
CPAF (Agency) 606 16,729 1,397 - - 18,125
CPFF (Agency) 842 66,172 24,592 5,007,422 228,338 5,326,525
COST TYPE TOTAL 1,449 82,901 25,988 5,007,422 228,338 5,344,650
T&M (Agency) 64,343 530,664 46,417 553,322 25,231 1,155,635
64,343 530,664 46,417 553,322 25,231 1,155,635
Fixed Price (Agency) 2,858 24,589 2,265 55,633 2,537 85,024
FIXED PRICE TOTAL 2,858 24,589 2,265 55,633 2,537 85,024
COMMERCIAL 23,387 189,165 15,795 - - 204,960
IR&D/B&P 6,376 48,911 - - - 48,911
GRAND TOTAL 98,412 876,230 90,466 5,616,377 256,107 6,839,180
Sch. C Sch. B Sch. C-1
ABC, LLC.
Anywhere, VA
FISCAL YEAR ENDED 12/31/14
SCHEDULE OF DIRECT COSTS BY CONTRACT/SUBCONTRACT
AND INDIRECT EXPENSE APPLIED AT CLAIMED RATES
T&M TOTAL
KEY SCHEDULES (CONT.)
KEY SCHEDULES (CONT.)
31
Schedule K
 Breaks out all T&M contracts to calculate labor hour and costs
 Ensure that T&M rates are current and be aware of potential mid-year rate changes (due to
escalation or an exercised option year)
 Material and travel costs then added, and loaded with the claimed G&A rate, if applicable
 For each contract the total costs and task ceilings should be calculated
This Schedule is linked to schedule A for the G&A rate. SCHEDULE K
Any changes in data will affect Schedule I. ICE (version 2.0.1e)
Other than G&A rate, only manual or externally imported entries
Schedule A - Applied Overhead, G&A, & COM Rates
ICE MANUAL
RECHECK FORMULAS
NOTE: Hidden rows have been inserted that will allow for automatic adjustment of the column totals when additional rows are inserted
Contract Labor Contract No. Contract No. Contract No. Contract No.
Category (1) Task: Task: Task: Task:
LABOR Rate (2) Hrs Amount Rate (2) Hrs Amount Rate (2) Hrs Amount Rate (2) Hrs Amount
Program Manager - - # - -
Senior Engineer - - - -
Engineer - - - -
Analyst - - - -
Technical Typist - - - -
TOTAL - - - - - - - -
OTHER COSTS
Material Costs (3) - - - -
Sched A
Material Overhead 0.00% - - - -
Travel Costs (3) - - - -
Sched A
G&A @: 0.00% (4) - - - -
Subtotal - - - -
TOTAL - - - -
Task Ceilings
Enter Company Name Here
Enter Company Location Here
Summary of Hours and Amounts on Time and Material/Labor Hour Contracts
Fiscal Year End - mm/dd/yyyy
KEY SCHEDULES (CONT.)
32
Schedule K
 Details are in the same level used for billing.
 All contracts identified as T&M on Schedule H are reported on Schedule K.
 ODCs and Travel costs tie to Schedule H.
Same level detail as
used for billing
Must Match Sch H
SCHEDULE K
Contract No. 120-434
Task: A123
Contractor Labor Category Rate Hrs Amount
LABOR
Labor- Category I 54.09 45.00 2,434$
Labor- Category II 79.54 132.00 10,499$
Labor Support I 66.56 35.00 2,330$
Labor Support IV 71.87 67.50 4,851$
20,114
OTHER COSTS
Material Costs -
Material Overhead -
Other Direct Costs 740
Travel Costs 20,654
21,394
G&A Rate 16.54% Sch A 6,865
Sub-total 28,259
Total 48,374$
Task Ceiling 50,000$
SUMMARY OF HOURS/AMOUNTS ON T&M/LABOR HOURS CONTRACTS
FISCAL YEAR ENDED 12/31/2014
Anywhere, VA
ABC, LLC
KEY SCHEDULES (CONT.)
33
Schedule I is linked to the following schedules: SCHEDULE I
Schedule H, Contract Costs ICE (version 2.0.1e)
Schedule K, T&M RECHECK FORMULAS
ICE MANUAL Schedule of Cumulative Direct and Indirect Costs Claimed and Billed
by Contract and Subcontract
Unsettled/Claimed Direct
Prior And Indirect Costs Using
Subject Years Total Less Net
To Settled Prior Year Current Year Cumulative Contract Cumulative Date Cost Over Physically
Penalty Total Costs Costs Settled or Limitations Settled or Billed (Under) Complete
Order Clause Costs FYE FYE Claimed Rebates/Credits Claimed PV No. Through Amount Billing (Note 7)
Contract No. Subcontract No. No. Note (2) Note (3) Note (4) Note (4) Note (5) Note (6)
SCHED H SCHED H
Cost Type & Flexibly Priced: (note 1)
- - - -
Subtotal-Cost & Flexibly Priced Contracts - - - -
SCHED K SCHED K
Time & Material
- - - -
Subtotal-Time & Material Contracts - - - -
Total- Cost/Flexibly Priced and Time & Material Contracts - - - -
Cumulative Cost Billed (Manual Entry)Claimed
Enter Company Name Here
Enter Company Location Here
Fiscal Year End - mm/dd/yyyy
Schedule I
 Determines the costs claimed versus those billed for all Federal cost reimbursement and T&M
awards (subcontracts are traditionally included)
 All cost reimbursement and T&M contracts are identified separately on schedule and should be
sorted by Federal Agency
 Information on Schedule I should be presented at the billing level for each award
KEY SCHEDULES (CONT.)
34
Schedule I
 Current year claimed costs are linked from Schedule H (cost reimbursement) and Schedule K
(time and materials) and added to prior year settled/claimed costs
 Billed costs are determined from the final invoice of the Contractor's fiscal year and should be
the cumulative billing figure for the award
 Intent of Schedule I is to calculate the total over or (under) billing on all Federal awards
 Other considerations:
• ‘Contract Limitations, Rebates, Credits’ column should be used for adjustments to claimed
costs such as:
 Excess costs above contract ceiling rates/amounts,
 Unallowable costs per contract terms,
 Cost incurrence outside of the period of performance,
• ‘Net Cumulative Settled or Claimed’ column should not exceed the total contract ceiling
• Indicate whether awards are ‘physically complete’ and reported on Schedule O
• Cumulative Billings should identify Fee amounts, where appropriate, and not include these
amounts ‘Over/Under Billing’ column
SCHEDULE I
Less:
Total Contract Cumulative
Subject Prior Years Cumulative Limitations, Net Cumulative Costs Billed OVER Physically
CONTRACT Subcontract Order to Penalty Settled Total Settled or Rebates & Settled or AMOUNT (UNDER) Complete
TYPE CONTRACT NO. No. No. Clause Costs FYE 12/31/10 FYE 12/31/12 FYE 12/31/13 FYE 12/31/14 Claimed Credits Claimed (LESS FEE) BILLED
SCH H
Cost Type Contracts
CPFF ABC-123 007643 345 N - 56,744 55,673 556,778 123,400 792,595 0 792,595 792,600 5 YES
CPFF DEF-456 347 Y - - 635,422 876,662 454,688 1,966,772 0 1,966,772 1,966,772 - NO
CPFF GHI-789 007645 586 Y - - 8,765,422 5,533,322 6,677,888 20,976,632 0 20,976,632 20,977,600 968 YES
CPFF JKL-654 647 N - 600,703 2,333,400 4,455,673 557,774 7,947,550 0 7,947,550 7,947,500 (50) YES
CPFF MNO-321 007647 737 Y - 4,556,555 6,664,334 5,666,633 637,655 17,525,177 0 17,525,177 17,525,177 - NO
Subtotal CPFF Contracts -$ 5,214,002$ 18,454,251$ 17,089,068$ 8,451,405$ 49,208,726$ -$ 49,208,726$ 49,209,649$ 923$
SCH K
Time & Material Contracts
T&M PQRS 227 N - 45,622 5,552 224 4,442 55,840 0 55,840$ 55,840 - YES
T&M TUVW 619 N - - 5,443 555 33,345 39,343 0 39,343$ 39,343 - NO
Subtotal T&M Contracts -$ 45,622$ 10,995$ 779$ 37,787$ 95,183$ -$ 95,183$ 95,183$ -$
ABC, LLC
Anywhere, VA
FISCAL YEAR ENDED 12/31/2014
SCHEDULE OF CUMULATIVE DIRECT AND INDIRECT COSTS
CLAIMED AND BILLED ON COST / FLEXIBLY PRICED AND TIME AND MATERIAL CONTRACTS
35
Schedule I
 Fiscal Year current dollars should reconcile to Sch. K for T&M contracts and Sch. H for cost type
contacts.
 Contracts identified as physically complete are reported on Schedule O.
 Contracts subject to penalty provision are identified.
 Prior FYEs’ costs should carried forward from and reconcile to prior FYE ICS’.
 Cumulative billed costs should exclude fee amounts for cost-type contracts.
 Inclusion of contract limitations to prevent overstating claimed costs.
KEY SCHEDULES (CONT.)
KEY SCHEDULES (CONT.)
36
Schedule J
 Subcontracts under any T&M or cost reimbursement prime contract
 Intent is to provide identification of subcontracts you have awarded to companies for which you
are the prime or upper-tier contractor, including inter-divisional effort
 Information that must be included:
• Subcontract number
• Prime contract number
• Subcontractor name and address
• Subcontractor point of contact and phone number
• Total value of subcontract
• Costs incurred in that fiscal year
• Award type
 Costs incurred on Schedule H must agree with the amounts reported on Schedule J
Schedule not linked to SCHEDULE J
other schedules. ICE (version 2.0.1e)
ICE MANUAL
<Insert Subcontract Type> subcontracts issued under flexibly priced prime contracts – Yes ___ No ___
PRIME SUBCONTRACTOR'S SUBCONTRACTOR'S POINT OF CONTACT SUBCONTRACT INCURRED AWARD
SUBCONTRACT NO. PRIME CONTRACT NO. CONTRACT VALUE NAME & ADDRESS DUNS NUMBER AND PHONE NO. VALUE From To IN FY 2009 TYPE
Enter Company Name Here
Enter Company Location Here
Fiscal Year End - mm/dd/yyyy
Subcontract Information
Performance Period
37
Schedule J
 Period of Performance and Subcontract Numbers must be included.
 Inclusion of all subcontracts awarded to flexibly-priced contracts (detailed out).
 Best Practice: Lump fixed-price and commercial awards and tie to schedule H.
 Total subcontracts presented on Schedule J must tie to Schedule H.
SCHEDULE J
2014
TOTAL COSTS
SUBCONTRACT NO.
PRIME CONTRACT
NO.
Project
Code
NAME AND
ADDRESS POINT OF CONTACT VALUE START DATE END DATE INCURRED
AWARD
TYPE
Cost-type subcontracts issued under flexibly priced prime contracts – Yes _X__ No ___
654-777-765-000 ABC-1213 123 Name and Address
POC Name
Address
Phone Number 16,750$ Jan/23/2010 Jan/22/2016 6,753$ CPFF
763-654-879-001 STU-5055 124 Name and Address
POC Name
Address
Phone Number 78,150$ Jul/23/2012 Oct/22/2017 76,321$ CPFF
764-888-653-007 EDG-4987 125 Name and Address
POC Name
Address
Phone Number 236,000$ Mar/15/2011 Mar/14/2019 98,765$ CPFF
T&M/LH subcontracts issued under flexibly priced prime contracts – Yes _X__ No ___
283-458-298-294 MRY-8392 293 Name and Address
POC Name
Address
Phone Number 15,000$ Apr/06/2012 Dec/31/2018 45,500$ T&M
Incentive subcontracts under flexibly priced prime contracts: Yes _____ No __X__
Subcontract orders based on cost issued under IDIQ prime contracts: Yes_____ No_X___
Subcontract orders based on cost issued under IDIQ prime contracts: Yes_____ No_X___
Inter-divisional/intercompany and FFP effort issued under flexibly priced prime contracts: Yes_____ No_X_
Total Subcontract Costs Reported on Schedule J 227,339$
Total FFP Subcontract Costs Presented on Schedule H 181,839
Total Commercial Subcontract Costs Presented on Schedule H 715,905
Total 1,125,083$ Sch H
1,125,083 Sch H
Recon -$
ABC, LLC
Anywhere, VA
FISCAL YEAR ENDED 12/31/14
SUBCONTRACT INFORMATION
KEY SCHEDULES (CONT.)
KEY SCHEDULES (CONT.)
38
Schedule L
 Reconciliation of Total Payroll to Total Labor Distribution
• Ties total labor expense to IRS Form 941's
• Payroll information should be entered directly from Form 941
• Labor distribution information is entered using links from schedule H (for direct labor) and
schedules B, C, and D (indirect labor expenses)
• Total 941 amount needs to reconcile to the labor totals from the rest of the ICS
Schedule O
 Contract Closing Information
• Use only for contracts ‘physically’ completed the fiscal year of ICS
• Includes the following information on each closed contract, broken out by contract type:
o Contract Number
o Performance Period
o Whether or not it is ready to close
o Contract ceiling amount
o Contract fee
o Level of Effort cumulative hours, actual and required
KEY SCHEDULES (CONT.)
39
Schedule L
Schedule L is linked to the following schedules: SCHEDULE L
Schedule C, Overhead ICE (version 2.0.1e)
Schedule B, G&A RECHECK FORMULAS
Schedule D, Occupancy
Schedule H, Claimed Allocation Bases
ICE MANUAL
NOTE: Hidden rows have been inserted that will allow for automatic adjustment of the column totals when additional rows are inserted
NOTE: Links not established for indirect costs because they have to be linked to account numbers inserted by contractor.
General
Acct No. Description Ledger Reference
Direct Labor - Summary SCHED H
General & Administrative: SCHED B
Salaries - link from Schedule B
Holiday Wages -
Vacation Wages -
Sick Leave -
Personal Absence -
Overhead Pools (incl Fringe): SCHED C (x)
Wages - link from Schedule C
Holiday Wages -
Vacation -
Sick Leave -
Severance Pay (in full) -
Intermediate Pools:
Occupancy Wages - SCHED D (x)
Overtime Premium (in ODCs) - link from schedule D
Overtime Premium -
-
TOTAL LABOR DISTRIBUTION -
PER IRS
FORM 941
1ST QTR.
2ND QTR
3rd QTR.
4th QTR.
Plus: Current Year Accrual
Minus: Prior Year Accrual
Other Adjustments
TOTAL PAYROLL -
Other Adjustment to arrive at Total Payroll Distributed (Provide detailed support)
Enter Company Name Here
Enter Company Location Here
Fiscal Year End - mm/dd/yyyy
to Total Labor Costs Distribution
Reconciliation of Total Payroll per IRS form 941
Schedule L
General
Acct No. Description Ledger Reference
Direct Labor 528,342 Sch H
General & Administrative:
8000 Labor 265,766 Sch B
Fringe:
4100 Health and Life Insurance 550,000 Sch Fringe
4200 401(k) Contributions 158,000 Sch Fringe
4300 Payroll Taxes 37,500 Sch Fringe
4400 Holiday Leave 34,654 Sch Fringe
4500 Disability Leave 32,675 Sch Fringe
Total 1,606,937
PER IRS
FORM 941
1ST QTR. 450,890
2ND QTR 325,966
3rd QTR. 276,989
4th QTR. 350,987
Plus: Current Year Accrual 156,777
Minus: Prior Year Accrual 38,997
Other Adjustments: Medical FSA 5,654
TOTAL PAYROLL 1,606,260
Variance 677 0.04% (variance % of total payroll costs)
ABC, LLC
Anywhere, VA
FISCAL YEAR ENDED 12/31/14
Reconciliation of Total Payroll per IRS
to Total Labor Costs Distribution
40
Schedule L
 Salary and Wages reported on Schedule L must reconcile to corresponding pools.
 Acceptable variance regarded as “immaterial” varies depending on auditor judgment.
KEY SCHEDULES (CONT.)
KEY SCHEDULES (CONT.)
41
Schedule O
This Schedule does not contain any links to SCHEDULE O
other schedules. ICE (version 2.0.1e)
MANUAL ENTRIES
ICE MANUAL
Ready
Performance Period To Contract Ceiling
Contract No. Order No. From To Close(1) Amount (2) Fee(3) Required Actual Notes
Cost Type:
Time & Material
Level of Effort
Cumulative Hours
Schedule of Contract Closing Information
Enter Company Name Here
Enter Company Location Here
Fiscal Year End - mm/dd/yyyy
(if applicable)
for those Contracts which Work Effort was Completed During
SCHEDULE O
Contract
Type Order No Contract No. From To Required Actual
CPFF 7643 ABC-123-456 Feb/12/2010 Oct/16/2014 YES 800,600 875,000 N/A N/A [1]
T&M 8645 DEF-789-101 Mar/20/2012 Oct/01/2014 YES 20,980,000 - 167,235 167,235
T&M 8646 GHI-112-131 Jun/15/2010 May/31/2014 YES 7,955,500 - 64,832 64,899
Notes:
[1] Level of Effort does not apply to these contracts.
ABC, LLC
Anywhere, VA
FISCAL YEAR ENDED 12/31/2014
SCHEDULE OF CONTRACT CLOSING INFORMATION
Notes
FOR THOSE CONTRACTS WHICH WORK EFFORT WAS COMPLETED DURING FISCAL YEAR
Level of Effort - Cummulative HoursPerformance Period
Ready to
Close
Contract
Ceiling(Value) Fees
42
Schedule O
 Contracts identified as physically complete on Schedule I are reported on Schedule O (and vice
versa, should reconcile).
 Schedule O should contain LOE information, period of performance and ceiling information,
where applicable.
KEY SCHEDULES (CONT.)
SUPPLEMENTAL SCHEDULES
43
 Below is a list of supplemental schedules:
Supplemental Schedules
• Supplemental A – Comparative Analysis of Indirect Expense Pools Detailed by Account with
Prior Year and Budgetary Data
• Supplemental B – General Organization and Executive Compensation Information
• Supplemental C – Identification of Prime Contracts Under Which the Contractor Performs as a
Subcontractor
• Supplemental D – Description of Accounting System
• Supplemental E – Procedures for Identifying and Excluding Unallowable Costs from the Costs
Claimed and Billed
• Supplemental F – Certified Financial Statements and Other Financial Data
• Supplemental G – Management Letter from Outside Certified Public Accountants (CPAs)
Concerning any Internal Control Weaknesses
• Supplemental H – Actions that have been and/or will be implemented to correct the
weaknesses described in the Management Letter
SUPPLEMENTAL SCHEDULES (CONT.)
44
 Below is a list of supplemental schedules:
Supplemental Schedules
• Supplemental I – List of all internal audit reports issued since the last disclosure of internal
audit reports to the Government
• Supplemental J – Annual internal audit plan of scheduled audits to be performed in the fiscal
year when the final indirect cost rate submission is made
• Supplemental K – Federal and State Income Tax Returns
• Supplemental L – Securities and Exchange Commission 10-K Annual Report
• Supplemental M – Minutes from Board of Directors (or Trustees) meetings
• Supplemental N – Listing of delay claims and termination claims submitted which contain costs
relating to the subject fiscal year
• Supplemental O – Contract Briefings; which generally includes a synopsis of all pertinent
contract provisions
TOTAL COST RECONCILIATION
45
Amount Reference Notes
Total Costs per ICS:
Total Claimed Costs 11,743,498 Sch H
Unbillable Direct Costs 314,811 Sch H
G&A Adjustments (6,080,424) Sch B
Total Costs per ICS 5,977,885
Costs per TB:
Costs per TB 5,977,885 TB to ICS
Variance -
NOTES:
Reconciliation of Total Costs per ICS to TB
ICS FY 2016
Reconciliation of Total Costs per ICS to TB
 Purpose is to ensure total costs per the trial balance reconcile to total cost claimed
RECONCILIATION OF ICS RATES
46
Reconciliation of ICS Rates between Schedules
FY2016
Diff from Diff from Sch H-1 Diff from
Cost Element Schedule A Schedule E Sch A Description Schedule H Sch A Description Amount Sch A
Fringe Pool
Fringe on Direct Labor 483,508 Fringe Base
Fringe on OH Labor 10,698 Direct Labor 1,044,349
Fringe (Full) Fringe on G&A Labor 44,245 G&A Labor 95,566
POOL 538,450 538,450 - 538,450 - Indirect Labor 23,107
BASE 1,163,022 1,163,022 - 1,163,022 -
FRINGE RATE 46.30%
Fringe (Limited)
POOL 142,208 142,208 - Fringe Pool 142,208 -
BASE 625,223 625,223 - Fringe Base 625,223 -
FRINGE RATE 22.75%
Fringe (Other)
POOL - - - Fringe Pool - -
BASE 1,523 1,523 - Fringe Base 1,523 -
FRINGE RATE 0.00%
Fringe (SCA)
POOL 700,714 700,714 - Fringe Pool 700,714 -
BASE 1,913,100 1,913,100 - Fringe Base 1,913,100 -
FRINGE RATE 36.63%
Overhead Expenses
POOL 109,252 109,252 - Overhead Pool 109,252 -
BASE 4,910,624 4,910,624 - Overhead Base 4,910,624 -
O/H RATE 2.22%
General and Administrative (G&A) Expenses
POOL 1,803,762 1,803,762 - G&A Pool 1,803,762 -
BASE 10,254,547 10,254,547 - G&A Base 10,254,547 -
G& A RATE 17.59%
 Purpose is to ensure the rates identified on Schedule A reconcile to:
• Schedule E
• Schedule H
• Schedule H-1
TRIAL BALANCE TO ICS RECONCILIATION
47
Fringe (Full) Fringe (Limited) Fringe (Other) Fringe (SCA) Schedule B Schedule C Schedule H
Account Number Account Description Balance Fringe Fringe Fringe Fringe G&A Overhead Direct Costs Total Variance Notes
0400-000-00 PTO EXPENSE - - - - - - - - - -
0400-039-00 PTO EXPENSE 94,697.01 94,697 - - - - - - 94,697 -
0400-040-00 PTO EXPENSE 33,807.09 - 33,807 - - - - - 33,807 -
0400-042-00 PTO EXPENSE 55,338.17 - - - 55,338 - - - 55,338 -
0425-042-00 VISION INSURANCE 43.40 - - - 43 - - - 43 -
0427-039-00 BENEFIT ADMIN FEES 301.85 302 - - - - - - 302 -
0427-040-00 BENEFIT ADMIN FEES 13.00 - 13 - - - - - 13 -
0427-042-00 BENEFIT ADMIN FEES 112.29 - - - 112 - - - 112 -
0500-301-00 OVERHEAD LABOR - DIV 1 1,009.47 - - - - - 1,009 - 1,009 -
0521-001-00 BUSINESS INSURANCE 40,657.03 - - - - - 40,657 - 40,657 -
0523-000-00 OFFICE SUPPLIES 3,368.83 - - - - - 3,369 - 3,369 -
0523-301-00 OTHER FACILITIES COST 7,013.00 - - - - - 7,013 - 7,013 -
0524-000-00 POSTAGE AND DELIVERY 655.13 - - - - - 655 - 655 -
0525-000-00 UTILITIES 47.05 - - - - - 47 - 47 -
0580-301-00 SC ALLOCATION IN - DIV 1 1,058.31 - - - - - 1,058 - 1,058 -
0700-001-00 G&A LABOR 95,565.71 - - - - 95,566 - - 95,566 -
0702-001-00 CONSULTANTS 5,802.50 - - - - 5,803 - - 5,803 -
0921-001-00 INTEREST INCOME (8.97) - - - - (9) - - (9) -
0922-001-00 CFSS ALLOCATION - UNALLOW 6,698.41 - - - - 6,698 - - 6,698 -
SFX ACCT 39 DIRECT LABOR - FULL 1,043,747.18 - - - - - - 1,044,349 1,044,349 601 1
SFX ACCT 40 DIRECT LABOR-LIMITED 625,133.30 - - - - - - 625,223 625,223 89 2
SFX ACCT 41 DIRECT LABOR-OTHER 1,523.04 - - - - - - 1,523 1,523 -
SFX ACCT 56 UNBILLABLE COSTS 10,163.24 - - - - - - 10,163 10,163 -
SFX ACCT 39 DIRECT LABOR -FULL 601.36 - - - - - - - - (601) 1
SFX ACCT 40 DIRECT LABOR-LIMITED 89.47 - - - - - - - - (89) 2
SFX ACCT 44 NAVAR ODC'S 65,273.59 - - - - - - - - (65,274) 4
5,977,885.05 538,450 142,208 - 700,714 (4,491,633) 98,553 8,989,592 5,977,885 (0)
Trial Balance
 Purpose is to ensure total costs per the trial balance reconcile to direct and indirect schedules
before adjustments and intermediate allocations
DCAA INCURRED COST SUBMISSION ADEQUACY
CHECKLIST
48
 Best Practice: Use the DCAA Incurred Cost Submission Adequacy Checklist as an basis for internally reviewing
the submission prior to forwarding it to the Contracting Officer and auditor. It can be found at:
http://www.dcaa.mil/Guide_for_Determining_Adequacy_of_Contractor_Incurred_Cost_Proposal.pdf
UNALLOWABLE COSTS
49
 Review submission for proper exclusion of unallowable expenses in accordance with the cost
principles found at FAR Part 31 (46 cost principles)
 Types of Unallowable costs:
• Expressly unallowable costs (7 of 46; i.e., Alcohol)
• Costs with limitations
• Mutually agreed to be unallowable costs (i.e. per contract terms)
• Directly associated costs
 If a cost is not specifically identified in FAR Part 31, could still be unallowable if it doesn’t meet
the allowability criteria:
• Reasonable?
• Allocable?
• Complies with contract terms?
• GAAP/CAS compliant?
• Adequately Supported?
 Following penalties (FAR 42.709-1) may apply for including unallowable costs in billings, claims,
or proposals:
• Disallowance of cost plus the amount equal to disallowance
• Interest on the paid portion, if any, of the disallowance
• If the indirect cost was determined to be unallowable for that contractor prior to the
submission of Incurred Cost Proposal, the penalty is 2x the disallowed amount.
 The unallowable costs do not have to have been paid in order to assess a penalty
KEY TAKEAWAYS
50
 Purpose is to establish final annual indirect cost rates and determine over/under
• Required to submit within 6-months of each of its fiscal year end (FAR 52.216-7)
 Schedules B, E, and H are where the most common errors occur
 Scrub unallowable activity from high risk accounts (“trigger accounts”)
• Ensure proper documentation is maintained for costs incurred!
• Leverage Salary Surveys to the maximum extent practicable
 Ensure unallowable overhead expenses are included in the G&A base
 Perform reconciliations and check your work!
 2018 Report to Congress Coming Soon!
BDO USA, LLP, a Delaware limited liability partnership, is
the U.S. member of BDO International Limited, a UK
company limited by guarantee, and forms part of the
international BDO network of independent member firms.
AUDIT TRENDS
AUDIT TRENDS
52
 Consultants
• Standardize documentation required from consultants (e.g., consulting agreements, sufficient
detail for invoices)
• Market analysis of billing rates should help support agreements
• Substance of the documentation is key to supporting cost incurred
 Executive Compensation
• Ensure your HR Department has a standard processes for developing “compensation bands”
(Written Compensation Plan/Policy)
• Utilize salary surveys to the maximum extent practicable (e.g., Towers Watson, ERI, Mercer,
Radford)
• Approximately $540,000, for FY19, based on applied escalation factors from the Bureau of
Labor Statistics (BLS)1,2
 Bonuses
• Documented bonus plan establishing parameters (e.g., who is eligible, timing of payouts, and
how bonuses are calculated)
• Employment agreements outlining potential compensation
Notes:
1. Section 702 of the Bipartisan Budget Act of 2013 (BBA; Pub. L. 113-67, December 26, 2013) established a $487,000 cap on the reimbursement of compensation costs
for contractor employees, adjusted annually to reflect the change in the Employment Cost Index for all workers as calculated by the Bureau of Labor Statistics (BLS)
2. Current FY Cap Amount = Prior FY Cap Amount x Change in Employment Cost Index for all workers [i.e., BLS Table 4. Compensation (Not Seasonally Adjusted)
Employment Cost Index for total compensation, for civilian workers, by occupational group and industry. (Twelve Months Ended September 30)]
AUDIT TRENDS, CONT.
53
 Medium and small contractors will receive more attention from DCAA
 Quicker contract close outs
• Contracting officers can avoid negotiations and go straight to closing out contracts using rates
established by DCAA
 Continued use of multi-year audits (less favorable for Contractors)
 Commercially Accepted Standards for Risk and Materiality
• Provide for both qualitative and quantitative considerations
• Auditors encouraged to discuss quantitative and qualitative materiality considerations with
contracting officers or other government customers
 Statute of Limitations (6 years per FAR 33.206(b))
• DCMA may establish rates with the option of a unilateral cost decrement (FAR 42.703‐2(c)(1) &
42.705(c)(1))
• The current rate, updated in 2016, is 16.4 percent
2017 REPORT TO CONGRESS
54
 Incurred cost audits continued to be a top priority, reducing the backlog to an average age of
14.3 months
• DCAA expects to be fully compliant with Congress’s NDAA mandate that audit backlog
inventory must not exceed one year
 Examined nearly $281B in defense contractor costs across 3,581 audit reports
 Currently taking DCAA 143 days from the time an ICS audit starts to the time the audit report is
issued
2017 REPORT TO CONGRESS
55
 Major contractors made up a significant proportion of examined. 6,786 incurred cost years were
closed.
 Only 2,860 incurred cost audits in backlog at the close of 2017
 Goal is to eliminate ICS backlog by FY2020 but on track for GFY 2018
Integrates with 3rd Party Payroll
Providers
Plan Execute Monitor Recognize Account
• CRM & Pipeline Mgmt.
• Purchase Requisition
• Budgeting & Revenue
Forecasting
• Resource Scheduling
• Skills Mgmt.
• Scenario Planning
• Pricing
• Timesheets
• Expense Reports &
Per Diems
• Purchase Orders
• Approvals
• Collaboration and
Notes
• Contract Mgmt.
• Real-Time
Dashboards & KPIs
• Project Status,
Utilization, & Burn
Rate
• Open Commitments
• Gross & Net Margin
• % Complete & EVM
• Backlog
• GAAP Compliance
• T&M, FP, and CP
• Revenue
Recognition – As
Worked, %
Complete &
Schedules
• General Ledger
• Accounts Payable
• Accounts
Receivable
• Cost Pools
• Indirect Rates
• PO Match: 2-Way or
3-Way Match
One Software for Projects, People & Financials
QUESTIONS?
TETIANA GERVIS, CPA
SENIOR ASSOCIATE, BDO
TGERVIS@BDO.COM
KIM KOSTER
VICE PRESIDENT OF CORPORATE STRATEGY, UNANET
KKOSTER@UNANET.COM

More Related Content

What's hot

Project procuremenet contract in ethiopia
Project procuremenet contract in ethiopiaProject procuremenet contract in ethiopia
Project procuremenet contract in ethiopia
Guta Mengesha
 
HOME Overview
HOME OverviewHOME Overview
HOME Overview
WVHDF
 
Procurement of services ppt
Procurement of services pptProcurement of services ppt
Procurement of services ppt
paribeshtimsina1
 
Fc3 domestic transfer pricing
Fc3 domestic transfer pricingFc3 domestic transfer pricing
Fc3 domestic transfer pricingvinothsavi
 
Ifrs 2
Ifrs 2Ifrs 2
Drafting of valuation report CA. Sudha Bhushan
Drafting of valuation report CA. Sudha BhushanDrafting of valuation report CA. Sudha Bhushan
Drafting of valuation report CA. Sudha Bhushan
TAXPERT PROFESSIONALS
 
Contract Management
Contract ManagementContract Management
Contract Managementadvsharma
 
Wb consultant 3a
Wb consultant 3aWb consultant 3a
Wb consultant 3aJoy Irman
 
Capital gain-45
Capital gain-45Capital gain-45
Capital gain-45
Admin SBS
 
Leases- The Winding Road Ahead
Leases- The Winding Road AheadLeases- The Winding Road Ahead
Leases- The Winding Road Ahead
DecosimoCPAs
 
2 ias 37 provisions-updated.pptx
2 ias 37  provisions-updated.pptx2 ias 37  provisions-updated.pptx
2 ias 37 provisions-updated.pptx
ESHETIE MEKONENE AMARE
 
CAPITAL GAINS
CAPITAL GAINSCAPITAL GAINS
CAPITAL GAINS
RAJESH JAIN
 
IFRS 4: Insurance Contract & IAS 24: Related Party Disclosure
IFRS 4: Insurance Contract & IAS 24: Related Party DisclosureIFRS 4: Insurance Contract & IAS 24: Related Party Disclosure
IFRS 4: Insurance Contract & IAS 24: Related Party Disclosure
M.K.Jahid Shuvo
 
How capital gain is to be computed when superstructure (building) less than 3...
How capital gain is to be computed when superstructure (building) less than 3...How capital gain is to be computed when superstructure (building) less than 3...
How capital gain is to be computed when superstructure (building) less than 3...
D Murali ☆
 
A presentation on bank audit
A presentation on bank auditA presentation on bank audit
A presentation on bank audit
JannatunChowdhury
 
BANC Q4 2019 Earnings Presentation
BANC Q4 2019 Earnings PresentationBANC Q4 2019 Earnings Presentation
BANC Q4 2019 Earnings Presentation
BancofCalifornia
 

What's hot (20)

Airtel info.
Airtel info.Airtel info.
Airtel info.
 
Project procuremenet contract in ethiopia
Project procuremenet contract in ethiopiaProject procuremenet contract in ethiopia
Project procuremenet contract in ethiopia
 
HOME Overview
HOME OverviewHOME Overview
HOME Overview
 
Bkozlowski wpa
Bkozlowski wpaBkozlowski wpa
Bkozlowski wpa
 
Hw01 fin. mgmt.
Hw01 fin. mgmt.Hw01 fin. mgmt.
Hw01 fin. mgmt.
 
Procurement of services ppt
Procurement of services pptProcurement of services ppt
Procurement of services ppt
 
Fc3 domestic transfer pricing
Fc3 domestic transfer pricingFc3 domestic transfer pricing
Fc3 domestic transfer pricing
 
Ifrs 2
Ifrs 2Ifrs 2
Ifrs 2
 
Drafting of valuation report CA. Sudha Bhushan
Drafting of valuation report CA. Sudha BhushanDrafting of valuation report CA. Sudha Bhushan
Drafting of valuation report CA. Sudha Bhushan
 
Contract Management
Contract ManagementContract Management
Contract Management
 
Wb consultant 3a
Wb consultant 3aWb consultant 3a
Wb consultant 3a
 
Capital gain-45
Capital gain-45Capital gain-45
Capital gain-45
 
Leases- The Winding Road Ahead
Leases- The Winding Road AheadLeases- The Winding Road Ahead
Leases- The Winding Road Ahead
 
2 ias 37 provisions-updated.pptx
2 ias 37  provisions-updated.pptx2 ias 37  provisions-updated.pptx
2 ias 37 provisions-updated.pptx
 
CAPITAL GAINS
CAPITAL GAINSCAPITAL GAINS
CAPITAL GAINS
 
IFRS 4: Insurance Contract & IAS 24: Related Party Disclosure
IFRS 4: Insurance Contract & IAS 24: Related Party DisclosureIFRS 4: Insurance Contract & IAS 24: Related Party Disclosure
IFRS 4: Insurance Contract & IAS 24: Related Party Disclosure
 
How capital gain is to be computed when superstructure (building) less than 3...
How capital gain is to be computed when superstructure (building) less than 3...How capital gain is to be computed when superstructure (building) less than 3...
How capital gain is to be computed when superstructure (building) less than 3...
 
IFRS 4
IFRS 4IFRS 4
IFRS 4
 
A presentation on bank audit
A presentation on bank auditA presentation on bank audit
A presentation on bank audit
 
BANC Q4 2019 Earnings Presentation
BANC Q4 2019 Earnings PresentationBANC Q4 2019 Earnings Presentation
BANC Q4 2019 Earnings Presentation
 

Similar to The Scoop on the Incurred Cost Submission

AS-7 Construction Contracts and AS-18 Related Party Transactions
AS-7 Construction Contracts and AS-18 Related Party TransactionsAS-7 Construction Contracts and AS-18 Related Party Transactions
AS-7 Construction Contracts and AS-18 Related Party Transactions
Prakhar Jain
 
ICDS : Construction Contracts
ICDS : Construction ContractsICDS : Construction Contracts
ICDS : Construction Contracts
TAXPERT PROFESSIONALS
 
Audit of contracts version 2
Audit of contracts version 2Audit of contracts version 2
Audit of contracts version 2
EMAC Consulting Group
 
Ensuring Accuracy Best Practices for DCAA's Incurred Cost Submissions.pdf
Ensuring Accuracy Best Practices for DCAA's Incurred Cost Submissions.pdfEnsuring Accuracy Best Practices for DCAA's Incurred Cost Submissions.pdf
Ensuring Accuracy Best Practices for DCAA's Incurred Cost Submissions.pdf
dcaaconsultant
 
Small Business Required Accounting_System
Small Business Required Accounting_SystemSmall Business Required Accounting_System
Small Business Required Accounting_SystemMaria Nguyen
 
Presentation_Advisory & Intragroup service.pptx
Presentation_Advisory & Intragroup service.pptxPresentation_Advisory & Intragroup service.pptx
Presentation_Advisory & Intragroup service.pptx
AsadurRahman84
 
Construction contract
Construction contractConstruction contract
Construction contract
Aqsa Shafique
 
Article construction contracts and icds
Article   construction contracts and icdsArticle   construction contracts and icds
Article construction contracts and icds
oswinfo
 
Transfer Pricing - Indian Transfer Pricing Landscape.pdf
Transfer Pricing - Indian Transfer Pricing Landscape.pdfTransfer Pricing - Indian Transfer Pricing Landscape.pdf
Transfer Pricing - Indian Transfer Pricing Landscape.pdf
Steadfast Business Consulting
 
29205rtpfinalmay2013 1
29205rtpfinalmay2013 129205rtpfinalmay2013 1
29205rtpfinalmay2013 1
homeankushin
 
ICDS - IIIConstruction contract
ICDS - IIIConstruction contract ICDS - IIIConstruction contract
ICDS - IIIConstruction contract Madhuri Devi
 
Improve Your Outcomes on Cost Type Contracts
Improve Your Outcomes on Cost Type ContractsImprove Your Outcomes on Cost Type Contracts
Improve Your Outcomes on Cost Type Contracts
Unanet
 
Ind as 37, provisions, contingent liabilities and contingent assets
Ind as   37, provisions, contingent  liabilities and contingent assetsInd as   37, provisions, contingent  liabilities and contingent assets
Ind as 37, provisions, contingent liabilities and contingent assets
sathishpalankar
 
Revenue Recognition In IFRS By Yash Batra
Revenue Recognition In IFRS By Yash BatraRevenue Recognition In IFRS By Yash Batra
Revenue Recognition In IFRS By Yash Batra
Yash Batra
 
Mastering the Income Statement Implementing Robust Cost Accounting Systems fo...
Mastering the Income Statement Implementing Robust Cost Accounting Systems fo...Mastering the Income Statement Implementing Robust Cost Accounting Systems fo...
Mastering the Income Statement Implementing Robust Cost Accounting Systems fo...
Robert E Jones
 
Bills of quantities
Bills of quantitiesBills of quantities
Bills of quantities
Ar.Vijay Kumar
 
Public Meeting - Contract Close-Out - Ground Rules
Public Meeting - Contract Close-Out - Ground RulesPublic Meeting - Contract Close-Out - Ground Rules
Public Meeting - Contract Close-Out - Ground Rules
Asia Master Training آسيا ماسترز للتدريب والتطوير
 
Types of contracts
Types of contracts   Types of contracts
Types of contracts
MANNU KUMAR
 

Similar to The Scoop on the Incurred Cost Submission (20)

AS-7 Construction Contracts and AS-18 Related Party Transactions
AS-7 Construction Contracts and AS-18 Related Party TransactionsAS-7 Construction Contracts and AS-18 Related Party Transactions
AS-7 Construction Contracts and AS-18 Related Party Transactions
 
ICDS : Construction Contracts
ICDS : Construction ContractsICDS : Construction Contracts
ICDS : Construction Contracts
 
Audit of contracts version 2
Audit of contracts version 2Audit of contracts version 2
Audit of contracts version 2
 
Ensuring Accuracy Best Practices for DCAA's Incurred Cost Submissions.pdf
Ensuring Accuracy Best Practices for DCAA's Incurred Cost Submissions.pdfEnsuring Accuracy Best Practices for DCAA's Incurred Cost Submissions.pdf
Ensuring Accuracy Best Practices for DCAA's Incurred Cost Submissions.pdf
 
Small Business Required Accounting_System
Small Business Required Accounting_SystemSmall Business Required Accounting_System
Small Business Required Accounting_System
 
Accounting_System_Requirements
Accounting_System_RequirementsAccounting_System_Requirements
Accounting_System_Requirements
 
Presentation_Advisory & Intragroup service.pptx
Presentation_Advisory & Intragroup service.pptxPresentation_Advisory & Intragroup service.pptx
Presentation_Advisory & Intragroup service.pptx
 
Construction contract
Construction contractConstruction contract
Construction contract
 
Ias11
Ias11Ias11
Ias11
 
Article construction contracts and icds
Article   construction contracts and icdsArticle   construction contracts and icds
Article construction contracts and icds
 
Transfer Pricing - Indian Transfer Pricing Landscape.pdf
Transfer Pricing - Indian Transfer Pricing Landscape.pdfTransfer Pricing - Indian Transfer Pricing Landscape.pdf
Transfer Pricing - Indian Transfer Pricing Landscape.pdf
 
29205rtpfinalmay2013 1
29205rtpfinalmay2013 129205rtpfinalmay2013 1
29205rtpfinalmay2013 1
 
ICDS - IIIConstruction contract
ICDS - IIIConstruction contract ICDS - IIIConstruction contract
ICDS - IIIConstruction contract
 
Improve Your Outcomes on Cost Type Contracts
Improve Your Outcomes on Cost Type ContractsImprove Your Outcomes on Cost Type Contracts
Improve Your Outcomes on Cost Type Contracts
 
Ind as 37, provisions, contingent liabilities and contingent assets
Ind as   37, provisions, contingent  liabilities and contingent assetsInd as   37, provisions, contingent  liabilities and contingent assets
Ind as 37, provisions, contingent liabilities and contingent assets
 
Revenue Recognition In IFRS By Yash Batra
Revenue Recognition In IFRS By Yash BatraRevenue Recognition In IFRS By Yash Batra
Revenue Recognition In IFRS By Yash Batra
 
Mastering the Income Statement Implementing Robust Cost Accounting Systems fo...
Mastering the Income Statement Implementing Robust Cost Accounting Systems fo...Mastering the Income Statement Implementing Robust Cost Accounting Systems fo...
Mastering the Income Statement Implementing Robust Cost Accounting Systems fo...
 
Bills of quantities
Bills of quantitiesBills of quantities
Bills of quantities
 
Public Meeting - Contract Close-Out - Ground Rules
Public Meeting - Contract Close-Out - Ground RulesPublic Meeting - Contract Close-Out - Ground Rules
Public Meeting - Contract Close-Out - Ground Rules
 
Types of contracts
Types of contracts   Types of contracts
Types of contracts
 

More from Unanet

Huntsville GovCon Growth Summit 2020 - Summit 7 - Cybersecurity Maturity Mode...
Huntsville GovCon Growth Summit 2020 - Summit 7 - Cybersecurity Maturity Mode...Huntsville GovCon Growth Summit 2020 - Summit 7 - Cybersecurity Maturity Mode...
Huntsville GovCon Growth Summit 2020 - Summit 7 - Cybersecurity Maturity Mode...
Unanet
 
What is Going on in the GovCon Market? Benchmarks and Trends for Government C...
What is Going on in the GovCon Market? Benchmarks and Trends for Government C...What is Going on in the GovCon Market? Benchmarks and Trends for Government C...
What is Going on in the GovCon Market? Benchmarks and Trends for Government C...
Unanet
 
The CMMC Has Arrived. Are You Ready?
The CMMC Has Arrived. Are You Ready?The CMMC Has Arrived. Are You Ready?
The CMMC Has Arrived. Are You Ready?
Unanet
 
Project Forecasting from the Perspective of an EVMA and EIA-748
Project Forecasting from the Perspective of an EVMA and EIA-748Project Forecasting from the Perspective of an EVMA and EIA-748
Project Forecasting from the Perspective of an EVMA and EIA-748
Unanet
 
DCAA Compliant Time & Expense Reporting Automation
DCAA Compliant Time & Expense Reporting AutomationDCAA Compliant Time & Expense Reporting Automation
DCAA Compliant Time & Expense Reporting Automation
Unanet
 
Control the Future - Budget, Plan & Forecast
Control the Future - Budget, Plan & ForecastControl the Future - Budget, Plan & Forecast
Control the Future - Budget, Plan & Forecast
Unanet
 
The Project Life Cycle Through the Lens of a Project Based ERP
The Project Life Cycle Through the Lens of a Project Based ERPThe Project Life Cycle Through the Lens of a Project Based ERP
The Project Life Cycle Through the Lens of a Project Based ERP
Unanet
 
Control the Future - Budget, Plan & Forecast
Control the Future - Budget, Plan & ForecastControl the Future - Budget, Plan & Forecast
Control the Future - Budget, Plan & Forecast
Unanet
 
Win Your Next Defense Opportunity - Seaport Next Generation (NxG)
Win Your Next Defense Opportunity - Seaport Next Generation (NxG)Win Your Next Defense Opportunity - Seaport Next Generation (NxG)
Win Your Next Defense Opportunity - Seaport Next Generation (NxG)
Unanet
 
Resource Management Maturity - Does Your Resource Management Practice Work Fo...
Resource Management Maturity - Does Your Resource Management Practice Work Fo...Resource Management Maturity - Does Your Resource Management Practice Work Fo...
Resource Management Maturity - Does Your Resource Management Practice Work Fo...
Unanet
 
Control the Future - Budget, Plan & Forecast
Control the Future - Budget, Plan & ForecastControl the Future - Budget, Plan & Forecast
Control the Future - Budget, Plan & Forecast
Unanet
 
Why Do Projects Fail? Getting Ready for EIA 748 – Earned Value Management (EVM)
Why Do Projects Fail? Getting Ready for EIA 748 – Earned Value Management (EVM)Why Do Projects Fail? Getting Ready for EIA 748 – Earned Value Management (EVM)
Why Do Projects Fail? Getting Ready for EIA 748 – Earned Value Management (EVM)
Unanet
 
The Business of Projects
The Business of ProjectsThe Business of Projects
The Business of Projects
Unanet
 
Indirect Rates - What Strategy is Right for your Organization
Indirect Rates - What Strategy is Right for your OrganizationIndirect Rates - What Strategy is Right for your Organization
Indirect Rates - What Strategy is Right for your Organization
Unanet
 
Introduction to Earned Value Management
Introduction to Earned Value ManagementIntroduction to Earned Value Management
Introduction to Earned Value Management
Unanet
 
Project Billing and Revenue Recognition
Project Billing and Revenue RecognitionProject Billing and Revenue Recognition
Project Billing and Revenue Recognition
Unanet
 
Top Reasons to Make Managing Your Pipeline a Priority
Top Reasons to Make Managing Your Pipeline a PriorityTop Reasons to Make Managing Your Pipeline a Priority
Top Reasons to Make Managing Your Pipeline a Priority
Unanet
 
Top Signs You May Have Outgrown Your Legacy ERP System
Top Signs You May Have Outgrown Your Legacy ERP SystemTop Signs You May Have Outgrown Your Legacy ERP System
Top Signs You May Have Outgrown Your Legacy ERP System
Unanet
 
Government Contract Foundations – Understanding Indirect Rates
Government Contract Foundations – Understanding Indirect RatesGovernment Contract Foundations – Understanding Indirect Rates
Government Contract Foundations – Understanding Indirect Rates
Unanet
 
Cybersecurity for GovCons - DFARS 252.204-7012 Latest Updates and Last Call
Cybersecurity for GovCons - DFARS 252.204-7012 Latest Updates and Last CallCybersecurity for GovCons - DFARS 252.204-7012 Latest Updates and Last Call
Cybersecurity for GovCons - DFARS 252.204-7012 Latest Updates and Last Call
Unanet
 

More from Unanet (20)

Huntsville GovCon Growth Summit 2020 - Summit 7 - Cybersecurity Maturity Mode...
Huntsville GovCon Growth Summit 2020 - Summit 7 - Cybersecurity Maturity Mode...Huntsville GovCon Growth Summit 2020 - Summit 7 - Cybersecurity Maturity Mode...
Huntsville GovCon Growth Summit 2020 - Summit 7 - Cybersecurity Maturity Mode...
 
What is Going on in the GovCon Market? Benchmarks and Trends for Government C...
What is Going on in the GovCon Market? Benchmarks and Trends for Government C...What is Going on in the GovCon Market? Benchmarks and Trends for Government C...
What is Going on in the GovCon Market? Benchmarks and Trends for Government C...
 
The CMMC Has Arrived. Are You Ready?
The CMMC Has Arrived. Are You Ready?The CMMC Has Arrived. Are You Ready?
The CMMC Has Arrived. Are You Ready?
 
Project Forecasting from the Perspective of an EVMA and EIA-748
Project Forecasting from the Perspective of an EVMA and EIA-748Project Forecasting from the Perspective of an EVMA and EIA-748
Project Forecasting from the Perspective of an EVMA and EIA-748
 
DCAA Compliant Time & Expense Reporting Automation
DCAA Compliant Time & Expense Reporting AutomationDCAA Compliant Time & Expense Reporting Automation
DCAA Compliant Time & Expense Reporting Automation
 
Control the Future - Budget, Plan & Forecast
Control the Future - Budget, Plan & ForecastControl the Future - Budget, Plan & Forecast
Control the Future - Budget, Plan & Forecast
 
The Project Life Cycle Through the Lens of a Project Based ERP
The Project Life Cycle Through the Lens of a Project Based ERPThe Project Life Cycle Through the Lens of a Project Based ERP
The Project Life Cycle Through the Lens of a Project Based ERP
 
Control the Future - Budget, Plan & Forecast
Control the Future - Budget, Plan & ForecastControl the Future - Budget, Plan & Forecast
Control the Future - Budget, Plan & Forecast
 
Win Your Next Defense Opportunity - Seaport Next Generation (NxG)
Win Your Next Defense Opportunity - Seaport Next Generation (NxG)Win Your Next Defense Opportunity - Seaport Next Generation (NxG)
Win Your Next Defense Opportunity - Seaport Next Generation (NxG)
 
Resource Management Maturity - Does Your Resource Management Practice Work Fo...
Resource Management Maturity - Does Your Resource Management Practice Work Fo...Resource Management Maturity - Does Your Resource Management Practice Work Fo...
Resource Management Maturity - Does Your Resource Management Practice Work Fo...
 
Control the Future - Budget, Plan & Forecast
Control the Future - Budget, Plan & ForecastControl the Future - Budget, Plan & Forecast
Control the Future - Budget, Plan & Forecast
 
Why Do Projects Fail? Getting Ready for EIA 748 – Earned Value Management (EVM)
Why Do Projects Fail? Getting Ready for EIA 748 – Earned Value Management (EVM)Why Do Projects Fail? Getting Ready for EIA 748 – Earned Value Management (EVM)
Why Do Projects Fail? Getting Ready for EIA 748 – Earned Value Management (EVM)
 
The Business of Projects
The Business of ProjectsThe Business of Projects
The Business of Projects
 
Indirect Rates - What Strategy is Right for your Organization
Indirect Rates - What Strategy is Right for your OrganizationIndirect Rates - What Strategy is Right for your Organization
Indirect Rates - What Strategy is Right for your Organization
 
Introduction to Earned Value Management
Introduction to Earned Value ManagementIntroduction to Earned Value Management
Introduction to Earned Value Management
 
Project Billing and Revenue Recognition
Project Billing and Revenue RecognitionProject Billing and Revenue Recognition
Project Billing and Revenue Recognition
 
Top Reasons to Make Managing Your Pipeline a Priority
Top Reasons to Make Managing Your Pipeline a PriorityTop Reasons to Make Managing Your Pipeline a Priority
Top Reasons to Make Managing Your Pipeline a Priority
 
Top Signs You May Have Outgrown Your Legacy ERP System
Top Signs You May Have Outgrown Your Legacy ERP SystemTop Signs You May Have Outgrown Your Legacy ERP System
Top Signs You May Have Outgrown Your Legacy ERP System
 
Government Contract Foundations – Understanding Indirect Rates
Government Contract Foundations – Understanding Indirect RatesGovernment Contract Foundations – Understanding Indirect Rates
Government Contract Foundations – Understanding Indirect Rates
 
Cybersecurity for GovCons - DFARS 252.204-7012 Latest Updates and Last Call
Cybersecurity for GovCons - DFARS 252.204-7012 Latest Updates and Last CallCybersecurity for GovCons - DFARS 252.204-7012 Latest Updates and Last Call
Cybersecurity for GovCons - DFARS 252.204-7012 Latest Updates and Last Call
 

Recently uploaded

2024 RoOUG Security model for the cloud.pptx
2024 RoOUG Security model for the cloud.pptx2024 RoOUG Security model for the cloud.pptx
2024 RoOUG Security model for the cloud.pptx
Georgi Kodinov
 
How Does XfilesPro Ensure Security While Sharing Documents in Salesforce?
How Does XfilesPro Ensure Security While Sharing Documents in Salesforce?How Does XfilesPro Ensure Security While Sharing Documents in Salesforce?
How Does XfilesPro Ensure Security While Sharing Documents in Salesforce?
XfilesPro
 
Why React Native as a Strategic Advantage for Startup Innovation.pdf
Why React Native as a Strategic Advantage for Startup Innovation.pdfWhy React Native as a Strategic Advantage for Startup Innovation.pdf
Why React Native as a Strategic Advantage for Startup Innovation.pdf
ayushiqss
 
Gamify Your Mind; The Secret Sauce to Delivering Success, Continuously Improv...
Gamify Your Mind; The Secret Sauce to Delivering Success, Continuously Improv...Gamify Your Mind; The Secret Sauce to Delivering Success, Continuously Improv...
Gamify Your Mind; The Secret Sauce to Delivering Success, Continuously Improv...
Shahin Sheidaei
 
In 2015, I used to write extensions for Joomla, WordPress, phpBB3, etc and I ...
In 2015, I used to write extensions for Joomla, WordPress, phpBB3, etc and I ...In 2015, I used to write extensions for Joomla, WordPress, phpBB3, etc and I ...
In 2015, I used to write extensions for Joomla, WordPress, phpBB3, etc and I ...
Juraj Vysvader
 
First Steps with Globus Compute Multi-User Endpoints
First Steps with Globus Compute Multi-User EndpointsFirst Steps with Globus Compute Multi-User Endpoints
First Steps with Globus Compute Multi-User Endpoints
Globus
 
Enhancing Research Orchestration Capabilities at ORNL.pdf
Enhancing Research Orchestration Capabilities at ORNL.pdfEnhancing Research Orchestration Capabilities at ORNL.pdf
Enhancing Research Orchestration Capabilities at ORNL.pdf
Globus
 
How to Position Your Globus Data Portal for Success Ten Good Practices
How to Position Your Globus Data Portal for Success Ten Good PracticesHow to Position Your Globus Data Portal for Success Ten Good Practices
How to Position Your Globus Data Portal for Success Ten Good Practices
Globus
 
De mooiste recreatieve routes ontdekken met RouteYou en FME
De mooiste recreatieve routes ontdekken met RouteYou en FMEDe mooiste recreatieve routes ontdekken met RouteYou en FME
De mooiste recreatieve routes ontdekken met RouteYou en FME
Jelle | Nordend
 
Exploring Innovations in Data Repository Solutions - Insights from the U.S. G...
Exploring Innovations in Data Repository Solutions - Insights from the U.S. G...Exploring Innovations in Data Repository Solutions - Insights from the U.S. G...
Exploring Innovations in Data Repository Solutions - Insights from the U.S. G...
Globus
 
TROUBLESHOOTING 9 TYPES OF OUTOFMEMORYERROR
TROUBLESHOOTING 9 TYPES OF OUTOFMEMORYERRORTROUBLESHOOTING 9 TYPES OF OUTOFMEMORYERROR
TROUBLESHOOTING 9 TYPES OF OUTOFMEMORYERROR
Tier1 app
 
Cracking the code review at SpringIO 2024
Cracking the code review at SpringIO 2024Cracking the code review at SpringIO 2024
Cracking the code review at SpringIO 2024
Paco van Beckhoven
 
Visitor Management System in India- Vizman.app
Visitor Management System in India- Vizman.appVisitor Management System in India- Vizman.app
Visitor Management System in India- Vizman.app
NaapbooksPrivateLimi
 
Strategies for Successful Data Migration Tools.pptx
Strategies for Successful Data Migration Tools.pptxStrategies for Successful Data Migration Tools.pptx
Strategies for Successful Data Migration Tools.pptx
varshanayak241
 
Multiple Your Crypto Portfolio with the Innovative Features of Advanced Crypt...
Multiple Your Crypto Portfolio with the Innovative Features of Advanced Crypt...Multiple Your Crypto Portfolio with the Innovative Features of Advanced Crypt...
Multiple Your Crypto Portfolio with the Innovative Features of Advanced Crypt...
Hivelance Technology
 
Webinar: Salesforce Document Management 2.0 - Smarter, Faster, Better
Webinar: Salesforce Document Management 2.0 - Smarter, Faster, BetterWebinar: Salesforce Document Management 2.0 - Smarter, Faster, Better
Webinar: Salesforce Document Management 2.0 - Smarter, Faster, Better
XfilesPro
 
Lecture 1 Introduction to games development
Lecture 1 Introduction to games developmentLecture 1 Introduction to games development
Lecture 1 Introduction to games development
abdulrafaychaudhry
 
Into the Box 2024 - Keynote Day 2 Slides.pdf
Into the Box 2024 - Keynote Day 2 Slides.pdfInto the Box 2024 - Keynote Day 2 Slides.pdf
Into the Box 2024 - Keynote Day 2 Slides.pdf
Ortus Solutions, Corp
 
Globus Connect Server Deep Dive - GlobusWorld 2024
Globus Connect Server Deep Dive - GlobusWorld 2024Globus Connect Server Deep Dive - GlobusWorld 2024
Globus Connect Server Deep Dive - GlobusWorld 2024
Globus
 
Corporate Management | Session 3 of 3 | Tendenci AMS
Corporate Management | Session 3 of 3 | Tendenci AMSCorporate Management | Session 3 of 3 | Tendenci AMS
Corporate Management | Session 3 of 3 | Tendenci AMS
Tendenci - The Open Source AMS (Association Management Software)
 

Recently uploaded (20)

2024 RoOUG Security model for the cloud.pptx
2024 RoOUG Security model for the cloud.pptx2024 RoOUG Security model for the cloud.pptx
2024 RoOUG Security model for the cloud.pptx
 
How Does XfilesPro Ensure Security While Sharing Documents in Salesforce?
How Does XfilesPro Ensure Security While Sharing Documents in Salesforce?How Does XfilesPro Ensure Security While Sharing Documents in Salesforce?
How Does XfilesPro Ensure Security While Sharing Documents in Salesforce?
 
Why React Native as a Strategic Advantage for Startup Innovation.pdf
Why React Native as a Strategic Advantage for Startup Innovation.pdfWhy React Native as a Strategic Advantage for Startup Innovation.pdf
Why React Native as a Strategic Advantage for Startup Innovation.pdf
 
Gamify Your Mind; The Secret Sauce to Delivering Success, Continuously Improv...
Gamify Your Mind; The Secret Sauce to Delivering Success, Continuously Improv...Gamify Your Mind; The Secret Sauce to Delivering Success, Continuously Improv...
Gamify Your Mind; The Secret Sauce to Delivering Success, Continuously Improv...
 
In 2015, I used to write extensions for Joomla, WordPress, phpBB3, etc and I ...
In 2015, I used to write extensions for Joomla, WordPress, phpBB3, etc and I ...In 2015, I used to write extensions for Joomla, WordPress, phpBB3, etc and I ...
In 2015, I used to write extensions for Joomla, WordPress, phpBB3, etc and I ...
 
First Steps with Globus Compute Multi-User Endpoints
First Steps with Globus Compute Multi-User EndpointsFirst Steps with Globus Compute Multi-User Endpoints
First Steps with Globus Compute Multi-User Endpoints
 
Enhancing Research Orchestration Capabilities at ORNL.pdf
Enhancing Research Orchestration Capabilities at ORNL.pdfEnhancing Research Orchestration Capabilities at ORNL.pdf
Enhancing Research Orchestration Capabilities at ORNL.pdf
 
How to Position Your Globus Data Portal for Success Ten Good Practices
How to Position Your Globus Data Portal for Success Ten Good PracticesHow to Position Your Globus Data Portal for Success Ten Good Practices
How to Position Your Globus Data Portal for Success Ten Good Practices
 
De mooiste recreatieve routes ontdekken met RouteYou en FME
De mooiste recreatieve routes ontdekken met RouteYou en FMEDe mooiste recreatieve routes ontdekken met RouteYou en FME
De mooiste recreatieve routes ontdekken met RouteYou en FME
 
Exploring Innovations in Data Repository Solutions - Insights from the U.S. G...
Exploring Innovations in Data Repository Solutions - Insights from the U.S. G...Exploring Innovations in Data Repository Solutions - Insights from the U.S. G...
Exploring Innovations in Data Repository Solutions - Insights from the U.S. G...
 
TROUBLESHOOTING 9 TYPES OF OUTOFMEMORYERROR
TROUBLESHOOTING 9 TYPES OF OUTOFMEMORYERRORTROUBLESHOOTING 9 TYPES OF OUTOFMEMORYERROR
TROUBLESHOOTING 9 TYPES OF OUTOFMEMORYERROR
 
Cracking the code review at SpringIO 2024
Cracking the code review at SpringIO 2024Cracking the code review at SpringIO 2024
Cracking the code review at SpringIO 2024
 
Visitor Management System in India- Vizman.app
Visitor Management System in India- Vizman.appVisitor Management System in India- Vizman.app
Visitor Management System in India- Vizman.app
 
Strategies for Successful Data Migration Tools.pptx
Strategies for Successful Data Migration Tools.pptxStrategies for Successful Data Migration Tools.pptx
Strategies for Successful Data Migration Tools.pptx
 
Multiple Your Crypto Portfolio with the Innovative Features of Advanced Crypt...
Multiple Your Crypto Portfolio with the Innovative Features of Advanced Crypt...Multiple Your Crypto Portfolio with the Innovative Features of Advanced Crypt...
Multiple Your Crypto Portfolio with the Innovative Features of Advanced Crypt...
 
Webinar: Salesforce Document Management 2.0 - Smarter, Faster, Better
Webinar: Salesforce Document Management 2.0 - Smarter, Faster, BetterWebinar: Salesforce Document Management 2.0 - Smarter, Faster, Better
Webinar: Salesforce Document Management 2.0 - Smarter, Faster, Better
 
Lecture 1 Introduction to games development
Lecture 1 Introduction to games developmentLecture 1 Introduction to games development
Lecture 1 Introduction to games development
 
Into the Box 2024 - Keynote Day 2 Slides.pdf
Into the Box 2024 - Keynote Day 2 Slides.pdfInto the Box 2024 - Keynote Day 2 Slides.pdf
Into the Box 2024 - Keynote Day 2 Slides.pdf
 
Globus Connect Server Deep Dive - GlobusWorld 2024
Globus Connect Server Deep Dive - GlobusWorld 2024Globus Connect Server Deep Dive - GlobusWorld 2024
Globus Connect Server Deep Dive - GlobusWorld 2024
 
Corporate Management | Session 3 of 3 | Tendenci AMS
Corporate Management | Session 3 of 3 | Tendenci AMSCorporate Management | Session 3 of 3 | Tendenci AMS
Corporate Management | Session 3 of 3 | Tendenci AMS
 

The Scoop on the Incurred Cost Submission

  • 1. INCURRED COST SUBMISSIONS (ICS) WEBINAR Presented By: Tetiana Gervis, CPA Senior Associate, Industry Specialty Services, BDO Hosted By: Kim Koster VP of Corporate Strategy, Unanet
  • 2. AGENDA 2 Overview of Presentation I. Background II. Timeline and Submission III. Preparation Techniques and Best Practices IV. ICS Audit Trends V. Questions
  • 3. BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. BACKGROUND
  • 4. WHAT IS AN INCURRED COST SUBMISSION (ICS)? 4  Formally known as an Indirect Cost Rate Proposal (ICP, ICRP or ICS); used interchangeably.  Purpose is to establish final annual indirect cost rates and determine over/under billing for the period covered by the ICS (presented on Schedule I)  The submission includes the direct and indirect expenses incurred by the contractor during its fiscal year.  ICS schedules show the detailed calculations of indirect pool(s) and base(s), a summary of costs incurred by contract, other supporting schedules, and the Certificate of Final Indirect Costs.  Rates developed from this submission are used for a variety of purposes, typically as the source or starting point for calculations such as Provisional Billing rates, Forward Pricing rates, etc.
  • 5. REQUIREMENTS 5  FAR 52.216-7 - Allowable Cost and Payment requires Government contractors to “submit an adequate final indirect cost rate proposal to the Contracting Officer (or cognizant Federal agency official) and auditor within the 6-month period following the expiration of each of its fiscal years.”  Reasonable extensions may be requested in writing by the Contractor and granted in writing by the Contracting Officer.  The proposed rates shall be based on the Contractor’s actual cost experience for that period.  The Allowable Cost and Payment clause applies to cost-reimbursement type and T&M contracts (FAR 16.307).  All federal contracts should be included and reported individually. It is permissible to lump or group all commercial and fixed price work together. In total, all contract costs should reconcile to the Trial Balance and other books of record. • For Subcontractors: Refer back to your subcontract agreement to ascertain whether the Allowable Cost and Payment clause has been flowed-down; thus requiring subcontractors to prepare and provide an incurred cost submission.
  • 6. WHY IS AN ICS SIGNIFICANT? 6  Finalized indirect cost rates provide for a timely settlement of costs under cost-reimbursement and T&M contracts. • The establishment of final rates shall be used for contract closeout (unless quick-closeout procedures are used).  The ICS is the contractor’s final opportunity to voluntarily disallow costs (pre-audit) that could be perceived or determined to be unallowable.  Adjusts provisional or interim billing rates as necessary to establish the final indirect cost rates after year end.  Final indirect cost rates are used in negotiating the final price of Federal contracts and in other situations requiring that indirect costs be settled before contract prices are established.  An ICS can provide a historical basis for the determination of final rates and which can be used to forecast provisional rates.  Contractors must update billings on all contracts to reflect the final indirect cost rates and update the schedule of cumulative direct and indirect costs claimed and billed within 60 days after settling final rates (per FAR 52.216-7(d)(2)(v)).
  • 7. WHY IS AN ICS SIGNIFICANT? (CONT.) 7  Concluding the audit of an ICS, the contractor and contracting officer will execute a written understanding specifying the terms and finalization of indirect rates, which would include: • The agreed-upon final indirect cost rates, • The bases to which the rates apply, • The periods for which the rates apply, • Any specific indirect cost items treated as direct costs in the settlement, and • The affected contract and/or subcontract, identifying any with advance agreements or special terms and the applicable rates.  The written agreement does not change any monetary ceiling, contract obligation, or specific cost allowance or disallowance provided for in the contract.
  • 8. BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. TIMELINE AND SUBMISSION
  • 9. TIMELINE FOR AN INCURRED COST SUBMISSION 9  Per FAR 52.216-7, an incurred cost submission is due within six (6) months after the contractor’s fiscal year end (FYE).  If the contractor does not submit the proposal within six (6) months of its FYE the DCAA may send reminder letters to the contractor.  Once the submission becomes six (6) months overdue (one year after the end of the fiscal year) and no extension has been granted by the Contracting Officer, the DCAA auditor may provide the CO with unilateral rate recommendations. As a result, the Contracting Officer can make a unilateral determination as authorized by FAR 42.703-2(c)(1) and FAR 42.705(c)(1).  Delinquent ICS’ result in rate recommendations that will be based on either (1) a decrement factor applied to indirect rates using relevant contractor historical data or (2) a company-wide decrement factor based on questioned costs at high risk contractors applied to total contract costs, if no relevant historical data exists.  The rate recommendation will apply to active contracts, as well as physically complete contracts for the overdue fiscal year end.
  • 10. INCURRED COST SUBMISSION AUDIT 10  After submission, and the determination has been made that a contractor’s incurred cost submission is adequate, then typically the cognizant DCAA Field Audit Office (FAO) will initiate the incurred cost audit within six months after receipt of an adequate proposal.  The audit is guided by DCAA’s Post Year End Incurred Cost Audit Program  During the course of the audit, the DCAA auditor should discuss audit findings with the government contractor as they arise.  The contractor is expected to provide timely feedback on these issues to ensue prompt resolution of audit findings and facilitate an efficient and effective audit process.  An exit conference will be held to summarize issues and resolutions identified during the audit process when significant audit findings are found.
  • 11. INCURRED COST SUBMISSION AUDIT (CONT.) 11  The contractor will be given a final opportunity to respond to the audit findings and comments submitted by the contractor will be included in the audit report (as comments should have been relayed during the audit process as questioned costs were identified).  The DCAA office provides the final report to the contracting officer (CO) (or cognizant Federal agency official) for establishing the final indirect cost and billing rates.  The Contracting Officer may provide the government contractor an opportunity to personally address the results of the audit report during “Negotiations.”  During negotiations the contractor’s position and supporting documentation is presented and considered prior to the CO issuing its final decision regarding questioned costs and final indirect cost rates. DCAA auditors can be extended the invitation to attend negotiations.  Within 120 days, or longer if approved in writing by the CO, after settlement of the final annual indirect cost rates for all years of a physically complete contract, the contractor must submit a completed invoice or voucher reflecting the settlement amount and rates (e.g., “ICS True-up”).
  • 12. WHAT DCAA LOOKS FOR… 12  An adequate incurred cost submission: use of the ICE Model (or similar format) containing all of the required schedules.  Schedule N is signed by an authorized party (usually CFO or above).  A contractor’s submission of all claimed costs incurred for cost type and/or T&M reimbursable government contracts, including adjustments and explanatory notes.  Identification of unallowable costs (voluntary deletions) and expressly unallowable costs with notes accompanying adjustments.  Identification, by contract, of awards containing FAR 52.242-3 - Penalties for Unallowable Costs (penalty clause).  If costs are reasonable, allocable, and allowable in accordance with GAAP, CAS, FAR, and contract provisions.
  • 13. WHAT DCAA LOOKS FOR…(CONT.) 13  Certain “trigger” accounts that may contain unallowable costs. The process for identifying accounts with a higher probability of being selected for testing consists of, but is not limited to: • If there have been any changes to the indirect cost rate structure between the last audited fiscal year and the year in review. Both direct and indirect costs will be evaluated • The results of performing a comparative analysis between the CFY and prior fiscal year pool expenses and direct costs • New accounts • Prior years incurred cost audit or other audit findings • Audit Leads • Fraud Risk Indicators • Audit history/experience with the government contractor • Auditor judgment
  • 14. BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. PREPARATION TECHNIQUES AND BEST PRACTICES
  • 15. PREPARATION TECHNIQUES 15 Use of DCAA ICE Model  The purpose of the DCAA ICE Model is to assist contractors in meeting its requirement for submitting an adequate final indirect cost rate proposal as required by FAR 52.216-7(d).  The ICE Model schedules present the minimum information needed to begin an audit and can be obtained at: http://www.dcaa.mil/ice_model.html.  The required content of the proposal and the supporting data will vary depending on the size of the firm, complexity of the accounting system, and type of business. Verify that the latest model is being used or downloaded.  Use of the Model is preferred, although not mandatory, as long as the submission includes the required schedules and support.  The company name and fiscal period should be included on all schedules submitted.  A separate schedule needs to be prepared for each final and intermediate indirect expense pool. If pool costs are accumulated by department, departmental expenses should be identified within each pool.  DCAA prefers that contractors include an index, similar to that used in the model, and note if certain schedules are not applicable.  Contractors are encouraged to submit their proposal in electronic format.
  • 16. REQUIRED VS. SUPPLEMENTAL 16  Required Schedules • To be completed and provided to DCAA at the time of submission, if applicable. • Some schedules, while identified as required, do not have to be completed if the schedule does not apply to the company (i.e., Capital Cost of Money, Intermediate Schedules).  Supplemental Schedules • Additional schedules which are not required to be provided at the time of submission for the determination of an adequate submission; however, may be required during the audit process. • Can be requested to be provided at the entrance conference to help determine audit risk, preliminary and field audit steps. • Federal contractors should consider completing and including the supplemental schedules at the time of submission to decrease delays in facilitating the audit.
  • 17. REQUIRED SCHEDULES 17  Per FAR 52.216-7(d)(2)(iii) An adequate indirect cost rate proposal shall include the following data unless otherwise specified by the cognizant Federal agency official: Indirect Cost Pools • Schedule A – Summary of all Claimed Indirect Expense Rates • Schedule B – General and Administrative (G&A) Expenses (final) • Schedule C – Overhead Expenses (final) • Schedule D – Intermediate/Occupancy Expenses (e.g., Facilities, Homogeneous Service Centers, Home Office) • Schedule E - Claimed Allocation Bases by element of cost used to distribute indirect costs • Fringe* - Schedule of Fringe Benefit Expenses • Schedule F – Facilities Capital Cost of Money Factors Computation *Although not individually listed as a required schedule for adequacy, a separate schedule for these expenses are normally created. An alternative is to include the fringe expenses on Schedule D-x.
  • 18. REQUIRED SCHEDULES (CONT.) 18 Contract Costs • Schedule G – Reconciliation of Books of Account and Claimed Direct Costs by Major Cost Element • Schedule H – Schedule of Direct Costs by Contract/Subcontract and Indirect Expense Applied at Claimed Rates (as well as a subsidiary schedule of Government Participation percentages in each of the allocation base amounts) • Schedule I – Cumulative Direct and Indirect Costs Claimed and Billed by Contract and Subcontract • Schedule J – Subcontract Information • Schedule K – Summary of Time-and-Materials and Labor-Hours contract, including labor categories, labor rates, hours, direct materials, other direct costs, and indirect expenses applied at claimed rates Other Schedules • Schedule L – Reconciliation of Total Payroll per IRS Form 941 to Total Labor Distribution Costs • Schedule M – Listing of Decisions/Agreements/Approvals and Description of Accounting/Organizational Changes • Schedule N – Certificate of Final Indirect Costs • Schedule O – Contract Closing Information for Contracts Completed in this Fiscal Year
  • 19. KEY SCHEDULES 19 Schedule B is linked to the following SCHEDULE B schedules: ICE (version 2.0.1g) Sched D (x), Intermediate Allocations Sched E, Bases Sched H, Contract Costs General and Administrative (G&A) Expenses (Final Indirect Cost Pool) Summary Sch H Sched P, IR&D/B&P ICE MANUAL RECHECK FORMULAS AND LINKS AFTER COMPLETING SCHEDULE TOTAL PER ACCOUNT G/L, F/S NUMBER DESCRIPTION Amount & TRIAL BAL. ADJUSTMENT CLAIMED NOTES Reference - - - - - - SUBTOTAL - - - - Intermediate Allocations: SUBTOTAL - - - - IR & D Mat'l,Trvl,ODC(Sum SCH H) - - SUM SCHED H IR & D Labor (Sum SCH H) - - SUM SCHED H IR & D Overhead(Sum SCH H & SCH E) - - - 1 SUM SCHED H SCHED E B & P Mat'l,Trvl, ODC(Sum SCH H) - - SUM SCHED H B & P Labor (Sum SCH H) - - SUM SCHED H B & P Overhead(Sum SCH H & SCH E) - - - 1 SUM SCHED H SCHED E - TOTAL G & A EXPENSE POOL - - - Acct Balances Enter Company Name Here Enter Company Location Here General and Administrative (G&A) Expenses Fiscal Year End - mm/dd/yyyy Insert rows as needed here, then copy data (Account Number, Desc, Amount by Dept) from accounting records. Delete this textbox. Schedule B  G&A costs broken down by account name and number (before intermediate allocations)  Any intermediate allocation amounts from Service Center, Home Office, Fringe, etc.  B&P costs broken out separately into Labor, Fringe, Overhead, and ODC’s  Total expense pool amount  All unallowable costs should be deducted out in the adjustments column in the schedule
  • 20. KEY SCHEDULES (CONT.) 20 Schedule C  Schedule of Overhead claimed expenses by element of cost as identified in accounting records for each final indirect cost pool  Calculates overhead expenses, those costs that are closely associated with contract performance • Support functions for direct labor, subcontractors, etc.  Schedule includes details of costs by account name and number (before intermediate allocations) • One schedule per O/H Pool (e.g., Manufacturing, Engineering, Onsite, Offsite, FCCOM) • Any intermediate allocation amounts from Service Center, Fringe, etc. Schedule C is linked to the following SCHEDULE C (1) schedules: ICE (version 2.0.1e) Schedule D(x) ICE MANUAL RECHECK FORMULAS AND LINKS AFTER COMPLETING SCHEDULE ACCOUNT TOTAL PER G/L NUMBER DESCRIPTION Amount & TRIAL BAL/FS ADJUSTMENTS CLAIMED Notes Ref. - - - - - - Subtotal - - - - Intermed Pool-1 - - - - Sched D (1) ADD: Fringe Allocation - - - Fringe Total Overhead Pool - - - Enter Company Name Here Acct Balances Enter Company Location Here Overhead Fiscal Year End - mm/dd/yyyy Overhead Expenses (final indirect cost pool) Insert rows as needed here, then copy data (Account Number, Desc, Amount by Dept) from accounting records. Delete this textbox.
  • 21. KEY SCHEDULES (CONT.) 21 Schedule D  Intermediate pools, containing costs not specifically associated with any one pool  Types of intermediate pools include: • Home Office expenses* • Service Centers • Fringe Benefits *Home Office allocations generally require a separate ICS to be formally prepared and submitted. This Schedule does not contain any links to SCHEDULE D (1) other schedules. ICE (version 2.0.1e) ICE MANUAL IMPORT DATA FROM ACCOUNTING RECORDS RECHECK FORMULAS AND LINKS AFTER COMPLETING SCHEDULE ACCOUNT PER G/L NUMBER DESCRIPTION & TRIAL BAL/FS ADJUSTMENT CLAIMED NOTES REFERENCE - - 1 - Total - - - ADD: Fringe Allocation - - - Fringe Total W / Alloc. - - - TO Sched A Allocation of Expenses Based on Square Feet Utilized ( Preparation Note 4 & Sample Note 2) Claimed Allocation Base % of Expense of Amts per (i.e. Sq. Ft.) Total Adjustments Allocation G/L See Preparation Note 4 G & A TO Sched B Amount 0.00% - - 2 O/H - OH TO Sched C (1) Amount 0.00% - - O/H - F_Pool-6 TO Sched C (6) Amount 0.00% - - - 0.00% - - TO Sched A Enter Company Name Here Enter Company Location Here Intermed Pool-1 (Intermed. Pool) Fiscal Year End - mm/dd/yyyy Intermediate Indirect Cost Pool Insert rows as needed here, then copy data (Account Number, Desc, Amount) from accounting records. Delete this textbox.
  • 22. FRINGE FRINGE BENEFITS POOL Account Account Name Year to Date Per G/L Adjustments Claimed Amount Notes Ref. 4510 Health and Life Insurance 550,000 - 550,000 4520 401(k) Contributions 158,000 - 158,000 4530 Payroll Taxes 37,500 - 37,500 4540 Holiday Leave 34,654 - 34,654 4550 Disability Leave 32,675 - 32,675 Total Pool 812,829 - 812,829 Total Base 3,678,302 - 3,678,302 Sch. E Fringe Rate 22.10% Fringe Allocated Labor Dollars % of Total Direct Labor 2,998,724 81.52% 662,656$ To Sch. H Overhead Labor 257,036 6.99% 56,800$ To Sch. C G&A Labor 275,675 7.49% 60,918$ To Sch. B Technology Service Center Labor 146,867 3.99% 32,455$ To Sch. D Total Labor 3,678,302 100% 812,829 Fringe Allocated ABC, LLC Anywhere, VA FISCAL YEAR ENDED 12/31/2014 FRINGE 22 Schedule D  Missing allocation tables on both Fringe and Intermediate allocation schedules. The allocation table must include: • Allocation base by recipient (i.e., direct labor, overhead, G&A, subcontract costs); • The percentage of the total base for each recipient; and • The total dollars allocated to each recipient. A B B A KEY SCHEDULES (CONT.)
  • 23. KEY SCHEDULES (CONT.) 23 Schedule E is linked to the following SCHEDULE E schedules: ICE (version 2.0.1e) Summary Sched H Sched H, Contract Costs Schedule C(x), Overhead Schedule B, G&A ICE MANUAL RECHECK FORMULAS AND LINKS AFTER COMPLETING SCHEDULE PER G/L, F/S PER G/L Fringe Pool & TRIAL BAL/FS ADJUSTMENTS CLAIMED Notes Ref. Fringe Pool -$ -$ -$ Fringe Fringe Base: G&A Labor -$ -$ Fringe Direct Labor - - " Indirect Labor (Overhead Pools) - - " Indirect Labor (Intermediate Pools) - - " Total Fringe Base -$ -$ -$ Fringe Rate 0.00% 0.00% Fringe Base* - Straight time direct and indirect labor dollars. PER G/L, F/S PER G/L & TRIAL BAL/FS ADJUSTMENTS CLAIMED Notes Ref. G&A Pool -$ -$ -$ Sched B G & A Base: Contract Labor -$ Summary Sched H Contract Travel - " Contract Material - " Other Direct Costs - " Subcontracts - " Subtotal = DIRECT COSTS -$ General Ledger Overhead (before adjustments) - Sched C (x) Less: IR&D/B&P O/H transferred to G & A pool. IR &D O/H (at G/L rate) - SCHED B B&P O/H (at G/L rate) - " Less: Material related costs to arrive at Value Added base. Direct Material - Subcontracts - Other Misc Adjustments to G&A Base (provide detailed support) - G&A Base - Value Added (exludes IR&D/B&P and COM) -$ G&A Rate 0.00% Enter Company Name Here Enter Company Location Here Fiscal Year End - mm/dd/yyyy Claimed Allocation Bases by element of cost used to distribute indirect costs Schedule E  Calculates the allocation bases for all final indirect pools
  • 24. KEY SCHEDULES (CONT.) 24 Schedule E  Costs in each base should be broken down and by line item and entered as a link to other inputs in the ICS, such as schedules H or otherwise  Schedule A should reference base amounts included on Schedule E  Adjustments should be thoroughly explained via footnotes  No information should be hardcoded  Allocation bases for intermediate pools are sometimes incorporated as well*  Example allocations bases include: • G&A: Total Cost Input (TCI) or Value Added (TCI less direct subcontracts and direct materials) • Subcontracts and Material Handling (SM&H): direct subcontracts and direct materials • Overhead: direct labor, and fringe, plus B&P/IR&D labor and B&P/IR&D fringe • Fringe: total labor, FTE, headcount • Facilities: square footage or headcount *The intermediate allocation bases will also need to be included on Schedule D
  • 25. KEY SCHEDULES (CONT.) 25 Schedule E  Explanation of all allocation bases must be included and match its description. SCHEDULE E DESCRIPTION Allowable Costs Unallowable Costs Total NOTES Fringe Pool: 765,398$ - 765,398$ Sch. Fringe Fringe Base: Total Labor Dollars 6,754,398$ -$ 6,754,398$ Sch. E-1 Fringe Cost Base is total labor dollars for all full and part-time employees. G&A Pool: 987,543$ -$ 987,543$ Sch. B G&A Base: Contract Direct Costs Labor 777,568$ 777,568$ Sch. H Fringe 136,353 136,353 Sch. H ODCs 4,743,088 4,743,088 Sch. H Materials & Subcontracts 126,582 126,582 Sch. H Indirect Expenses 159,868 159,868 Sch. H Total Direct Costs 5,943,459$ - 5,943,459$ Overhead Before Adjustments 140,785$ 140,785$ Sch. C Value Add Base 6,084,244$ - 6,084,244$ Sch. B G&A Base is total direct and indirect costs, except G&A, material and subcontract costs (value-added cost input). CLAIMED ALLOCATION BASES BY COST ELEMENT OF COST USED TO DISTRIBUTE INDIRECT COSTS FISCAL YEAR ENDED 12/31/14 ABC, LLC Anywhere, VA
  • 26. KEY SCHEDULES (CONT.) 26 Schedule F  Facilities Capital Cost of Money (FCCM) • Costs associated with facilities capital used to perform a contract • Cost of money rate is the arithmetic mean of the interest rates (most recent) specified by the Secretary of the Treasury (CAS 414) • Applies the cost of money to the capital used, as long as it is allocated correctly and is allowable Schedule F is linked to the following schedules: SCHEDULE F Schedule F-1, Net Book value of Assets ICE (version 2.0.1e) Summary Schedule H, Contract Costs Schedule E, Bases FACILITIES CAPITAL ICE MANUAL COST OF MONEY FACTORS COMPUTATION Computing COM Rate: Treasury Rate Mos. COM Rate Jan - Jun 6.00 0.000% Jul - Dec 6.00 0.000% 0.000% RECHECK FORMULAS AND LINKS AFTER COMPLETING SCHEDULE NBV BASES Sched F-1 Sched E 1. Applicable 2. Accumulation 3. Allocation of 4. Total Net 5. COM for Cost 6. Allocation 7. Facilities Company 1 Cost of Money & Distribution of Undistributed Book Value Accounting Base For Capital COM Cost Accounting Period 20xx Rate NBV Period Period Factors Recorded 0.00% - (Basis Of Allocation) (Column 2+3) (Column 1*4) In units (Column 5/6) Business Leased Property - of measure Unit Corporate/Group Facilities Total - Capital Undistributed - Distributed - Overhead Unused - - - - - 0.00000 Pools Unused - - - - - 0.00000 LESS: COM on IR&D/B&P Labor: Unused - - 0.00000 Sum Sched H Unused - - 0.00000 Subtotal - G&A G & A - - - - Expense Pools ADD: COM on IR&D/B&P Labor - Subtotal: - - 0.00000 TOTAL - - - - Enter Company Name Here Enter Company Location Here Fiscal Year End - mm/dd/yyyy Months percentage added for demonstration purposes - adjust as needed
  • 27. KEY SCHEDULES (CONT.) 27 Schedule H is linked to the following schedules: SCHEDULE H Schedule A - Applied Overhead, G&A, & COM Rates ICE (version 2.0.1e) Summary Schedule H Schedule H-1 Govt Participation ICE MANUAL INPUT DATA FROM ACCOUNTING RECORDS RECHECK FORMULAS AND LINKS AFTER COMPLETING SCHEDULE Sched A Total Claimed Direct G&A Claimed JOB SUBCONTRACT Labor Total Sub- Direct O/H Costs Plus Base G &A Total Total Grand ORDER CONTRACT NUMBER NUMBER OH Labor Travel Material ODC Contracts Costs OH O/H (Value Added) Applied Costs COM Total XX. CONTRACT TYPE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - XX. TOTAL CONTRACT TYPE: - - - - - - - - - - - - - - TOTAL CONTRACT COSTS - - - - - - - - - - - - - - IR & D - - - - B& P - - - - TOTAL IR & D/B & P - - - - - - - - - GRAND TOTAL - - - - - - - - Enter Company Name Here Enter Company Location Here Fiscal Year End - mm/dd/yyyy Schedule of Direct Costs by Contract/Subcontract and Indirect Expense Applied at Claimed Rates Sched A Schedule H  This schedule is one of the most important and the basis for a large portion of the submission  Calculates actual incurred costs by contract, broken out by contract type and element of cost
  • 28. KEY SCHEDULES (CONT.) 28 Schedule H  Project status reports or detailed project ledgers are traditionally used to compile direct costs for each contract  Indirect rates (as calculated in Schedule A) are applied to the direct contract costs to determine the total indirect expenses for each contract  Only Flexibly Priced Federal awards are required to be separately identified on Schedule H (at billing level), commercial or other non-Federal contracts can be aggregated as one line item  Best Practices: • Include federal agency/customer name, by award • Differentiate between claimed and unclaimed (non-billable) direct costs by cost element and applied indirect costs • Include a column which totals both claimed and unclaimed amounts, by cost element • Reconcile total costs incurred on Schedule H to Trial balance or detailed General Ledger • Include attributes of clients accounting structure (i.e., project codes) into schedule to allow for simple edits • Calculate indirect rate caps on this schedule for greatest efficiency and easy linkage to Schedule I • Use commercial ‘plug’ to save time, if appropriate
  • 29. 29 Schedule H  Prime/Sub Contract numbers must be included on the Schedule H and be consistent across Schedules H, I,J, and K.  Prepared at the billing level  Best Practice: Include customer name/federal agency, by award. SCHEDULE H Sch. A Sch. A Sch. A Sch. A 20.56% 15.45% 8.35% 4.56% Award Type Customer Name Project No. Project Name Contract No. Subcontract No. Direct Labor Travel ODCs Total Direct Costs - Value Add Materials Subcontracts Allowable Fringe Allowable Overhead Value Add Direct Costs Plus Fringe & OH G&A Total M&S M&S Handling Grand Total COSTTYPE CPAF (Agency) 100 ABC ABC-123-000 3,255 5,554 6,644 15,453 - - 669 606 16,729 1,397 - - 18,125 CPFF (Agency) 101 DEF ABC-234-000 STU 4,523 4,344 55,533 64,400 4,663,000 344,422 930 842 66,172 24,592 5,007,422 228,338 5,326,525 COSTTYPE TOTAL 7,778 9,898 62,177 79,853 4,663,000 344,422 1,599 1,449 82,901 25,988 5,007,422 228,338 5,344,650 T&M (Agency) 200 GHI CDE-456-000 VWX 345,435 43,533 6,332 395,300 - 553,322 71,021 64,343 530,664 46,417 553,322 25,231 1,155,635 345,435 43,533 6,332 395,300 - 553,322 71,021 64,343 530,664 46,417 553,322 25,231 1,155,635 Fixed Price (Agency) 300 JKL EFG-678-000 15,345 2,567 664 18,576 55,633 - 3,155 2,858 24,589 2,265 55,633 2,537 85,024 FIXEDPRICE TOTAL 15,345 2,567 664 18,576 55,633 - 3,155 2,858 24,589 2,265 55,633 2,537 85,024 COMMERCIAL 500 MNO HIJ-932-029 125,555 13,000 1,409 139,964 - - 25,814 23,387 189,165 15,795 - - 204,960 IR&D/B&P 900 PQR 34,229 986 283 35,498 - - 7,037 6,376 48,911 - - - 48,911 GRANDTOTAL 528,342 69,984 70,865 669,191 4,718,633 897,744 108,627 98,412 876,230 90,466 5,616,377 256,107 6,839,180 Sch. C Sch. B Sch. C-1 5,616,377 Sch. E- Mat. & Sub Handling T&M TOTAL SCHEDULE OF DIRECTCOSTS BY CONTRACT/SUBCONTRACT FISCALYEARENDED12/31/14 Anywhere, VA ABC, LLC. ANDINDIRECTEXPENSE APPLIEDATCLAIMEDRATES KEY SCHEDULES (CONT.)
  • 30. 30 Schedules B through E to H  Pool and Base amounts on Schedules B through E must tie to Schedule H. A A B B Schedule C OVERHEADPOOL Account AccountName YeartoDate PerG/L Adjustments ClaimedAmount 7000 OverheadLabor 53,892 - 53,892 7010 LaborNonAllowable 2,494 - 2,494 7020 Travel 14,632 - 14,632 7030 Professional Fees 17,932 - 17,932 Subtotal OverheadPool 88,950 - 88,950 Intermediate Allocation TechSvcCenterAllocation 9,462 - 9,462 Total OverheadPool 98,412 - 98,412 BASETOTAL 636,900 - 636,900 OverheadRate 15.45% ABC,LLC Anywhere,VA FISCALYEARENDED12/31/2014 CONTRACTORSITEOVERHEAD SCHEDULE H Sch. A Sch. A Sch. A 15.45% 8.35% 4.56% Award Type Customer Name Allowable Overhead Direct Costs Plus Fringe & OH G&A Total M&S M&S Handling Grand Total COST TYPE CPAF (Agency) 606 16,729 1,397 - - 18,125 CPFF (Agency) 842 66,172 24,592 5,007,422 228,338 5,326,525 COST TYPE TOTAL 1,449 82,901 25,988 5,007,422 228,338 5,344,650 T&M (Agency) 64,343 530,664 46,417 553,322 25,231 1,155,635 64,343 530,664 46,417 553,322 25,231 1,155,635 Fixed Price (Agency) 2,858 24,589 2,265 55,633 2,537 85,024 FIXED PRICE TOTAL 2,858 24,589 2,265 55,633 2,537 85,024 COMMERCIAL 23,387 189,165 15,795 - - 204,960 IR&D/B&P 6,376 48,911 - - - 48,911 GRAND TOTAL 98,412 876,230 90,466 5,616,377 256,107 6,839,180 Sch. C Sch. B Sch. C-1 ABC, LLC. Anywhere, VA FISCAL YEAR ENDED 12/31/14 SCHEDULE OF DIRECT COSTS BY CONTRACT/SUBCONTRACT AND INDIRECT EXPENSE APPLIED AT CLAIMED RATES T&M TOTAL KEY SCHEDULES (CONT.)
  • 31. KEY SCHEDULES (CONT.) 31 Schedule K  Breaks out all T&M contracts to calculate labor hour and costs  Ensure that T&M rates are current and be aware of potential mid-year rate changes (due to escalation or an exercised option year)  Material and travel costs then added, and loaded with the claimed G&A rate, if applicable  For each contract the total costs and task ceilings should be calculated This Schedule is linked to schedule A for the G&A rate. SCHEDULE K Any changes in data will affect Schedule I. ICE (version 2.0.1e) Other than G&A rate, only manual or externally imported entries Schedule A - Applied Overhead, G&A, & COM Rates ICE MANUAL RECHECK FORMULAS NOTE: Hidden rows have been inserted that will allow for automatic adjustment of the column totals when additional rows are inserted Contract Labor Contract No. Contract No. Contract No. Contract No. Category (1) Task: Task: Task: Task: LABOR Rate (2) Hrs Amount Rate (2) Hrs Amount Rate (2) Hrs Amount Rate (2) Hrs Amount Program Manager - - # - - Senior Engineer - - - - Engineer - - - - Analyst - - - - Technical Typist - - - - TOTAL - - - - - - - - OTHER COSTS Material Costs (3) - - - - Sched A Material Overhead 0.00% - - - - Travel Costs (3) - - - - Sched A G&A @: 0.00% (4) - - - - Subtotal - - - - TOTAL - - - - Task Ceilings Enter Company Name Here Enter Company Location Here Summary of Hours and Amounts on Time and Material/Labor Hour Contracts Fiscal Year End - mm/dd/yyyy
  • 32. KEY SCHEDULES (CONT.) 32 Schedule K  Details are in the same level used for billing.  All contracts identified as T&M on Schedule H are reported on Schedule K.  ODCs and Travel costs tie to Schedule H. Same level detail as used for billing Must Match Sch H SCHEDULE K Contract No. 120-434 Task: A123 Contractor Labor Category Rate Hrs Amount LABOR Labor- Category I 54.09 45.00 2,434$ Labor- Category II 79.54 132.00 10,499$ Labor Support I 66.56 35.00 2,330$ Labor Support IV 71.87 67.50 4,851$ 20,114 OTHER COSTS Material Costs - Material Overhead - Other Direct Costs 740 Travel Costs 20,654 21,394 G&A Rate 16.54% Sch A 6,865 Sub-total 28,259 Total 48,374$ Task Ceiling 50,000$ SUMMARY OF HOURS/AMOUNTS ON T&M/LABOR HOURS CONTRACTS FISCAL YEAR ENDED 12/31/2014 Anywhere, VA ABC, LLC
  • 33. KEY SCHEDULES (CONT.) 33 Schedule I is linked to the following schedules: SCHEDULE I Schedule H, Contract Costs ICE (version 2.0.1e) Schedule K, T&M RECHECK FORMULAS ICE MANUAL Schedule of Cumulative Direct and Indirect Costs Claimed and Billed by Contract and Subcontract Unsettled/Claimed Direct Prior And Indirect Costs Using Subject Years Total Less Net To Settled Prior Year Current Year Cumulative Contract Cumulative Date Cost Over Physically Penalty Total Costs Costs Settled or Limitations Settled or Billed (Under) Complete Order Clause Costs FYE FYE Claimed Rebates/Credits Claimed PV No. Through Amount Billing (Note 7) Contract No. Subcontract No. No. Note (2) Note (3) Note (4) Note (4) Note (5) Note (6) SCHED H SCHED H Cost Type & Flexibly Priced: (note 1) - - - - Subtotal-Cost & Flexibly Priced Contracts - - - - SCHED K SCHED K Time & Material - - - - Subtotal-Time & Material Contracts - - - - Total- Cost/Flexibly Priced and Time & Material Contracts - - - - Cumulative Cost Billed (Manual Entry)Claimed Enter Company Name Here Enter Company Location Here Fiscal Year End - mm/dd/yyyy Schedule I  Determines the costs claimed versus those billed for all Federal cost reimbursement and T&M awards (subcontracts are traditionally included)  All cost reimbursement and T&M contracts are identified separately on schedule and should be sorted by Federal Agency  Information on Schedule I should be presented at the billing level for each award
  • 34. KEY SCHEDULES (CONT.) 34 Schedule I  Current year claimed costs are linked from Schedule H (cost reimbursement) and Schedule K (time and materials) and added to prior year settled/claimed costs  Billed costs are determined from the final invoice of the Contractor's fiscal year and should be the cumulative billing figure for the award  Intent of Schedule I is to calculate the total over or (under) billing on all Federal awards  Other considerations: • ‘Contract Limitations, Rebates, Credits’ column should be used for adjustments to claimed costs such as:  Excess costs above contract ceiling rates/amounts,  Unallowable costs per contract terms,  Cost incurrence outside of the period of performance, • ‘Net Cumulative Settled or Claimed’ column should not exceed the total contract ceiling • Indicate whether awards are ‘physically complete’ and reported on Schedule O • Cumulative Billings should identify Fee amounts, where appropriate, and not include these amounts ‘Over/Under Billing’ column
  • 35. SCHEDULE I Less: Total Contract Cumulative Subject Prior Years Cumulative Limitations, Net Cumulative Costs Billed OVER Physically CONTRACT Subcontract Order to Penalty Settled Total Settled or Rebates & Settled or AMOUNT (UNDER) Complete TYPE CONTRACT NO. No. No. Clause Costs FYE 12/31/10 FYE 12/31/12 FYE 12/31/13 FYE 12/31/14 Claimed Credits Claimed (LESS FEE) BILLED SCH H Cost Type Contracts CPFF ABC-123 007643 345 N - 56,744 55,673 556,778 123,400 792,595 0 792,595 792,600 5 YES CPFF DEF-456 347 Y - - 635,422 876,662 454,688 1,966,772 0 1,966,772 1,966,772 - NO CPFF GHI-789 007645 586 Y - - 8,765,422 5,533,322 6,677,888 20,976,632 0 20,976,632 20,977,600 968 YES CPFF JKL-654 647 N - 600,703 2,333,400 4,455,673 557,774 7,947,550 0 7,947,550 7,947,500 (50) YES CPFF MNO-321 007647 737 Y - 4,556,555 6,664,334 5,666,633 637,655 17,525,177 0 17,525,177 17,525,177 - NO Subtotal CPFF Contracts -$ 5,214,002$ 18,454,251$ 17,089,068$ 8,451,405$ 49,208,726$ -$ 49,208,726$ 49,209,649$ 923$ SCH K Time & Material Contracts T&M PQRS 227 N - 45,622 5,552 224 4,442 55,840 0 55,840$ 55,840 - YES T&M TUVW 619 N - - 5,443 555 33,345 39,343 0 39,343$ 39,343 - NO Subtotal T&M Contracts -$ 45,622$ 10,995$ 779$ 37,787$ 95,183$ -$ 95,183$ 95,183$ -$ ABC, LLC Anywhere, VA FISCAL YEAR ENDED 12/31/2014 SCHEDULE OF CUMULATIVE DIRECT AND INDIRECT COSTS CLAIMED AND BILLED ON COST / FLEXIBLY PRICED AND TIME AND MATERIAL CONTRACTS 35 Schedule I  Fiscal Year current dollars should reconcile to Sch. K for T&M contracts and Sch. H for cost type contacts.  Contracts identified as physically complete are reported on Schedule O.  Contracts subject to penalty provision are identified.  Prior FYEs’ costs should carried forward from and reconcile to prior FYE ICS’.  Cumulative billed costs should exclude fee amounts for cost-type contracts.  Inclusion of contract limitations to prevent overstating claimed costs. KEY SCHEDULES (CONT.)
  • 36. KEY SCHEDULES (CONT.) 36 Schedule J  Subcontracts under any T&M or cost reimbursement prime contract  Intent is to provide identification of subcontracts you have awarded to companies for which you are the prime or upper-tier contractor, including inter-divisional effort  Information that must be included: • Subcontract number • Prime contract number • Subcontractor name and address • Subcontractor point of contact and phone number • Total value of subcontract • Costs incurred in that fiscal year • Award type  Costs incurred on Schedule H must agree with the amounts reported on Schedule J Schedule not linked to SCHEDULE J other schedules. ICE (version 2.0.1e) ICE MANUAL <Insert Subcontract Type> subcontracts issued under flexibly priced prime contracts – Yes ___ No ___ PRIME SUBCONTRACTOR'S SUBCONTRACTOR'S POINT OF CONTACT SUBCONTRACT INCURRED AWARD SUBCONTRACT NO. PRIME CONTRACT NO. CONTRACT VALUE NAME & ADDRESS DUNS NUMBER AND PHONE NO. VALUE From To IN FY 2009 TYPE Enter Company Name Here Enter Company Location Here Fiscal Year End - mm/dd/yyyy Subcontract Information Performance Period
  • 37. 37 Schedule J  Period of Performance and Subcontract Numbers must be included.  Inclusion of all subcontracts awarded to flexibly-priced contracts (detailed out).  Best Practice: Lump fixed-price and commercial awards and tie to schedule H.  Total subcontracts presented on Schedule J must tie to Schedule H. SCHEDULE J 2014 TOTAL COSTS SUBCONTRACT NO. PRIME CONTRACT NO. Project Code NAME AND ADDRESS POINT OF CONTACT VALUE START DATE END DATE INCURRED AWARD TYPE Cost-type subcontracts issued under flexibly priced prime contracts – Yes _X__ No ___ 654-777-765-000 ABC-1213 123 Name and Address POC Name Address Phone Number 16,750$ Jan/23/2010 Jan/22/2016 6,753$ CPFF 763-654-879-001 STU-5055 124 Name and Address POC Name Address Phone Number 78,150$ Jul/23/2012 Oct/22/2017 76,321$ CPFF 764-888-653-007 EDG-4987 125 Name and Address POC Name Address Phone Number 236,000$ Mar/15/2011 Mar/14/2019 98,765$ CPFF T&M/LH subcontracts issued under flexibly priced prime contracts – Yes _X__ No ___ 283-458-298-294 MRY-8392 293 Name and Address POC Name Address Phone Number 15,000$ Apr/06/2012 Dec/31/2018 45,500$ T&M Incentive subcontracts under flexibly priced prime contracts: Yes _____ No __X__ Subcontract orders based on cost issued under IDIQ prime contracts: Yes_____ No_X___ Subcontract orders based on cost issued under IDIQ prime contracts: Yes_____ No_X___ Inter-divisional/intercompany and FFP effort issued under flexibly priced prime contracts: Yes_____ No_X_ Total Subcontract Costs Reported on Schedule J 227,339$ Total FFP Subcontract Costs Presented on Schedule H 181,839 Total Commercial Subcontract Costs Presented on Schedule H 715,905 Total 1,125,083$ Sch H 1,125,083 Sch H Recon -$ ABC, LLC Anywhere, VA FISCAL YEAR ENDED 12/31/14 SUBCONTRACT INFORMATION KEY SCHEDULES (CONT.)
  • 38. KEY SCHEDULES (CONT.) 38 Schedule L  Reconciliation of Total Payroll to Total Labor Distribution • Ties total labor expense to IRS Form 941's • Payroll information should be entered directly from Form 941 • Labor distribution information is entered using links from schedule H (for direct labor) and schedules B, C, and D (indirect labor expenses) • Total 941 amount needs to reconcile to the labor totals from the rest of the ICS Schedule O  Contract Closing Information • Use only for contracts ‘physically’ completed the fiscal year of ICS • Includes the following information on each closed contract, broken out by contract type: o Contract Number o Performance Period o Whether or not it is ready to close o Contract ceiling amount o Contract fee o Level of Effort cumulative hours, actual and required
  • 39. KEY SCHEDULES (CONT.) 39 Schedule L Schedule L is linked to the following schedules: SCHEDULE L Schedule C, Overhead ICE (version 2.0.1e) Schedule B, G&A RECHECK FORMULAS Schedule D, Occupancy Schedule H, Claimed Allocation Bases ICE MANUAL NOTE: Hidden rows have been inserted that will allow for automatic adjustment of the column totals when additional rows are inserted NOTE: Links not established for indirect costs because they have to be linked to account numbers inserted by contractor. General Acct No. Description Ledger Reference Direct Labor - Summary SCHED H General & Administrative: SCHED B Salaries - link from Schedule B Holiday Wages - Vacation Wages - Sick Leave - Personal Absence - Overhead Pools (incl Fringe): SCHED C (x) Wages - link from Schedule C Holiday Wages - Vacation - Sick Leave - Severance Pay (in full) - Intermediate Pools: Occupancy Wages - SCHED D (x) Overtime Premium (in ODCs) - link from schedule D Overtime Premium - - TOTAL LABOR DISTRIBUTION - PER IRS FORM 941 1ST QTR. 2ND QTR 3rd QTR. 4th QTR. Plus: Current Year Accrual Minus: Prior Year Accrual Other Adjustments TOTAL PAYROLL - Other Adjustment to arrive at Total Payroll Distributed (Provide detailed support) Enter Company Name Here Enter Company Location Here Fiscal Year End - mm/dd/yyyy to Total Labor Costs Distribution Reconciliation of Total Payroll per IRS form 941
  • 40. Schedule L General Acct No. Description Ledger Reference Direct Labor 528,342 Sch H General & Administrative: 8000 Labor 265,766 Sch B Fringe: 4100 Health and Life Insurance 550,000 Sch Fringe 4200 401(k) Contributions 158,000 Sch Fringe 4300 Payroll Taxes 37,500 Sch Fringe 4400 Holiday Leave 34,654 Sch Fringe 4500 Disability Leave 32,675 Sch Fringe Total 1,606,937 PER IRS FORM 941 1ST QTR. 450,890 2ND QTR 325,966 3rd QTR. 276,989 4th QTR. 350,987 Plus: Current Year Accrual 156,777 Minus: Prior Year Accrual 38,997 Other Adjustments: Medical FSA 5,654 TOTAL PAYROLL 1,606,260 Variance 677 0.04% (variance % of total payroll costs) ABC, LLC Anywhere, VA FISCAL YEAR ENDED 12/31/14 Reconciliation of Total Payroll per IRS to Total Labor Costs Distribution 40 Schedule L  Salary and Wages reported on Schedule L must reconcile to corresponding pools.  Acceptable variance regarded as “immaterial” varies depending on auditor judgment. KEY SCHEDULES (CONT.)
  • 41. KEY SCHEDULES (CONT.) 41 Schedule O This Schedule does not contain any links to SCHEDULE O other schedules. ICE (version 2.0.1e) MANUAL ENTRIES ICE MANUAL Ready Performance Period To Contract Ceiling Contract No. Order No. From To Close(1) Amount (2) Fee(3) Required Actual Notes Cost Type: Time & Material Level of Effort Cumulative Hours Schedule of Contract Closing Information Enter Company Name Here Enter Company Location Here Fiscal Year End - mm/dd/yyyy (if applicable) for those Contracts which Work Effort was Completed During
  • 42. SCHEDULE O Contract Type Order No Contract No. From To Required Actual CPFF 7643 ABC-123-456 Feb/12/2010 Oct/16/2014 YES 800,600 875,000 N/A N/A [1] T&M 8645 DEF-789-101 Mar/20/2012 Oct/01/2014 YES 20,980,000 - 167,235 167,235 T&M 8646 GHI-112-131 Jun/15/2010 May/31/2014 YES 7,955,500 - 64,832 64,899 Notes: [1] Level of Effort does not apply to these contracts. ABC, LLC Anywhere, VA FISCAL YEAR ENDED 12/31/2014 SCHEDULE OF CONTRACT CLOSING INFORMATION Notes FOR THOSE CONTRACTS WHICH WORK EFFORT WAS COMPLETED DURING FISCAL YEAR Level of Effort - Cummulative HoursPerformance Period Ready to Close Contract Ceiling(Value) Fees 42 Schedule O  Contracts identified as physically complete on Schedule I are reported on Schedule O (and vice versa, should reconcile).  Schedule O should contain LOE information, period of performance and ceiling information, where applicable. KEY SCHEDULES (CONT.)
  • 43. SUPPLEMENTAL SCHEDULES 43  Below is a list of supplemental schedules: Supplemental Schedules • Supplemental A – Comparative Analysis of Indirect Expense Pools Detailed by Account with Prior Year and Budgetary Data • Supplemental B – General Organization and Executive Compensation Information • Supplemental C – Identification of Prime Contracts Under Which the Contractor Performs as a Subcontractor • Supplemental D – Description of Accounting System • Supplemental E – Procedures for Identifying and Excluding Unallowable Costs from the Costs Claimed and Billed • Supplemental F – Certified Financial Statements and Other Financial Data • Supplemental G – Management Letter from Outside Certified Public Accountants (CPAs) Concerning any Internal Control Weaknesses • Supplemental H – Actions that have been and/or will be implemented to correct the weaknesses described in the Management Letter
  • 44. SUPPLEMENTAL SCHEDULES (CONT.) 44  Below is a list of supplemental schedules: Supplemental Schedules • Supplemental I – List of all internal audit reports issued since the last disclosure of internal audit reports to the Government • Supplemental J – Annual internal audit plan of scheduled audits to be performed in the fiscal year when the final indirect cost rate submission is made • Supplemental K – Federal and State Income Tax Returns • Supplemental L – Securities and Exchange Commission 10-K Annual Report • Supplemental M – Minutes from Board of Directors (or Trustees) meetings • Supplemental N – Listing of delay claims and termination claims submitted which contain costs relating to the subject fiscal year • Supplemental O – Contract Briefings; which generally includes a synopsis of all pertinent contract provisions
  • 45. TOTAL COST RECONCILIATION 45 Amount Reference Notes Total Costs per ICS: Total Claimed Costs 11,743,498 Sch H Unbillable Direct Costs 314,811 Sch H G&A Adjustments (6,080,424) Sch B Total Costs per ICS 5,977,885 Costs per TB: Costs per TB 5,977,885 TB to ICS Variance - NOTES: Reconciliation of Total Costs per ICS to TB ICS FY 2016 Reconciliation of Total Costs per ICS to TB  Purpose is to ensure total costs per the trial balance reconcile to total cost claimed
  • 46. RECONCILIATION OF ICS RATES 46 Reconciliation of ICS Rates between Schedules FY2016 Diff from Diff from Sch H-1 Diff from Cost Element Schedule A Schedule E Sch A Description Schedule H Sch A Description Amount Sch A Fringe Pool Fringe on Direct Labor 483,508 Fringe Base Fringe on OH Labor 10,698 Direct Labor 1,044,349 Fringe (Full) Fringe on G&A Labor 44,245 G&A Labor 95,566 POOL 538,450 538,450 - 538,450 - Indirect Labor 23,107 BASE 1,163,022 1,163,022 - 1,163,022 - FRINGE RATE 46.30% Fringe (Limited) POOL 142,208 142,208 - Fringe Pool 142,208 - BASE 625,223 625,223 - Fringe Base 625,223 - FRINGE RATE 22.75% Fringe (Other) POOL - - - Fringe Pool - - BASE 1,523 1,523 - Fringe Base 1,523 - FRINGE RATE 0.00% Fringe (SCA) POOL 700,714 700,714 - Fringe Pool 700,714 - BASE 1,913,100 1,913,100 - Fringe Base 1,913,100 - FRINGE RATE 36.63% Overhead Expenses POOL 109,252 109,252 - Overhead Pool 109,252 - BASE 4,910,624 4,910,624 - Overhead Base 4,910,624 - O/H RATE 2.22% General and Administrative (G&A) Expenses POOL 1,803,762 1,803,762 - G&A Pool 1,803,762 - BASE 10,254,547 10,254,547 - G&A Base 10,254,547 - G& A RATE 17.59%  Purpose is to ensure the rates identified on Schedule A reconcile to: • Schedule E • Schedule H • Schedule H-1
  • 47. TRIAL BALANCE TO ICS RECONCILIATION 47 Fringe (Full) Fringe (Limited) Fringe (Other) Fringe (SCA) Schedule B Schedule C Schedule H Account Number Account Description Balance Fringe Fringe Fringe Fringe G&A Overhead Direct Costs Total Variance Notes 0400-000-00 PTO EXPENSE - - - - - - - - - - 0400-039-00 PTO EXPENSE 94,697.01 94,697 - - - - - - 94,697 - 0400-040-00 PTO EXPENSE 33,807.09 - 33,807 - - - - - 33,807 - 0400-042-00 PTO EXPENSE 55,338.17 - - - 55,338 - - - 55,338 - 0425-042-00 VISION INSURANCE 43.40 - - - 43 - - - 43 - 0427-039-00 BENEFIT ADMIN FEES 301.85 302 - - - - - - 302 - 0427-040-00 BENEFIT ADMIN FEES 13.00 - 13 - - - - - 13 - 0427-042-00 BENEFIT ADMIN FEES 112.29 - - - 112 - - - 112 - 0500-301-00 OVERHEAD LABOR - DIV 1 1,009.47 - - - - - 1,009 - 1,009 - 0521-001-00 BUSINESS INSURANCE 40,657.03 - - - - - 40,657 - 40,657 - 0523-000-00 OFFICE SUPPLIES 3,368.83 - - - - - 3,369 - 3,369 - 0523-301-00 OTHER FACILITIES COST 7,013.00 - - - - - 7,013 - 7,013 - 0524-000-00 POSTAGE AND DELIVERY 655.13 - - - - - 655 - 655 - 0525-000-00 UTILITIES 47.05 - - - - - 47 - 47 - 0580-301-00 SC ALLOCATION IN - DIV 1 1,058.31 - - - - - 1,058 - 1,058 - 0700-001-00 G&A LABOR 95,565.71 - - - - 95,566 - - 95,566 - 0702-001-00 CONSULTANTS 5,802.50 - - - - 5,803 - - 5,803 - 0921-001-00 INTEREST INCOME (8.97) - - - - (9) - - (9) - 0922-001-00 CFSS ALLOCATION - UNALLOW 6,698.41 - - - - 6,698 - - 6,698 - SFX ACCT 39 DIRECT LABOR - FULL 1,043,747.18 - - - - - - 1,044,349 1,044,349 601 1 SFX ACCT 40 DIRECT LABOR-LIMITED 625,133.30 - - - - - - 625,223 625,223 89 2 SFX ACCT 41 DIRECT LABOR-OTHER 1,523.04 - - - - - - 1,523 1,523 - SFX ACCT 56 UNBILLABLE COSTS 10,163.24 - - - - - - 10,163 10,163 - SFX ACCT 39 DIRECT LABOR -FULL 601.36 - - - - - - - - (601) 1 SFX ACCT 40 DIRECT LABOR-LIMITED 89.47 - - - - - - - - (89) 2 SFX ACCT 44 NAVAR ODC'S 65,273.59 - - - - - - - - (65,274) 4 5,977,885.05 538,450 142,208 - 700,714 (4,491,633) 98,553 8,989,592 5,977,885 (0) Trial Balance  Purpose is to ensure total costs per the trial balance reconcile to direct and indirect schedules before adjustments and intermediate allocations
  • 48. DCAA INCURRED COST SUBMISSION ADEQUACY CHECKLIST 48  Best Practice: Use the DCAA Incurred Cost Submission Adequacy Checklist as an basis for internally reviewing the submission prior to forwarding it to the Contracting Officer and auditor. It can be found at: http://www.dcaa.mil/Guide_for_Determining_Adequacy_of_Contractor_Incurred_Cost_Proposal.pdf
  • 49. UNALLOWABLE COSTS 49  Review submission for proper exclusion of unallowable expenses in accordance with the cost principles found at FAR Part 31 (46 cost principles)  Types of Unallowable costs: • Expressly unallowable costs (7 of 46; i.e., Alcohol) • Costs with limitations • Mutually agreed to be unallowable costs (i.e. per contract terms) • Directly associated costs  If a cost is not specifically identified in FAR Part 31, could still be unallowable if it doesn’t meet the allowability criteria: • Reasonable? • Allocable? • Complies with contract terms? • GAAP/CAS compliant? • Adequately Supported?  Following penalties (FAR 42.709-1) may apply for including unallowable costs in billings, claims, or proposals: • Disallowance of cost plus the amount equal to disallowance • Interest on the paid portion, if any, of the disallowance • If the indirect cost was determined to be unallowable for that contractor prior to the submission of Incurred Cost Proposal, the penalty is 2x the disallowed amount.  The unallowable costs do not have to have been paid in order to assess a penalty
  • 50. KEY TAKEAWAYS 50  Purpose is to establish final annual indirect cost rates and determine over/under • Required to submit within 6-months of each of its fiscal year end (FAR 52.216-7)  Schedules B, E, and H are where the most common errors occur  Scrub unallowable activity from high risk accounts (“trigger accounts”) • Ensure proper documentation is maintained for costs incurred! • Leverage Salary Surveys to the maximum extent practicable  Ensure unallowable overhead expenses are included in the G&A base  Perform reconciliations and check your work!  2018 Report to Congress Coming Soon!
  • 51. BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. AUDIT TRENDS
  • 52. AUDIT TRENDS 52  Consultants • Standardize documentation required from consultants (e.g., consulting agreements, sufficient detail for invoices) • Market analysis of billing rates should help support agreements • Substance of the documentation is key to supporting cost incurred  Executive Compensation • Ensure your HR Department has a standard processes for developing “compensation bands” (Written Compensation Plan/Policy) • Utilize salary surveys to the maximum extent practicable (e.g., Towers Watson, ERI, Mercer, Radford) • Approximately $540,000, for FY19, based on applied escalation factors from the Bureau of Labor Statistics (BLS)1,2  Bonuses • Documented bonus plan establishing parameters (e.g., who is eligible, timing of payouts, and how bonuses are calculated) • Employment agreements outlining potential compensation Notes: 1. Section 702 of the Bipartisan Budget Act of 2013 (BBA; Pub. L. 113-67, December 26, 2013) established a $487,000 cap on the reimbursement of compensation costs for contractor employees, adjusted annually to reflect the change in the Employment Cost Index for all workers as calculated by the Bureau of Labor Statistics (BLS) 2. Current FY Cap Amount = Prior FY Cap Amount x Change in Employment Cost Index for all workers [i.e., BLS Table 4. Compensation (Not Seasonally Adjusted) Employment Cost Index for total compensation, for civilian workers, by occupational group and industry. (Twelve Months Ended September 30)]
  • 53. AUDIT TRENDS, CONT. 53  Medium and small contractors will receive more attention from DCAA  Quicker contract close outs • Contracting officers can avoid negotiations and go straight to closing out contracts using rates established by DCAA  Continued use of multi-year audits (less favorable for Contractors)  Commercially Accepted Standards for Risk and Materiality • Provide for both qualitative and quantitative considerations • Auditors encouraged to discuss quantitative and qualitative materiality considerations with contracting officers or other government customers  Statute of Limitations (6 years per FAR 33.206(b)) • DCMA may establish rates with the option of a unilateral cost decrement (FAR 42.703‐2(c)(1) & 42.705(c)(1)) • The current rate, updated in 2016, is 16.4 percent
  • 54. 2017 REPORT TO CONGRESS 54  Incurred cost audits continued to be a top priority, reducing the backlog to an average age of 14.3 months • DCAA expects to be fully compliant with Congress’s NDAA mandate that audit backlog inventory must not exceed one year  Examined nearly $281B in defense contractor costs across 3,581 audit reports  Currently taking DCAA 143 days from the time an ICS audit starts to the time the audit report is issued
  • 55. 2017 REPORT TO CONGRESS 55  Major contractors made up a significant proportion of examined. 6,786 incurred cost years were closed.  Only 2,860 incurred cost audits in backlog at the close of 2017  Goal is to eliminate ICS backlog by FY2020 but on track for GFY 2018
  • 56. Integrates with 3rd Party Payroll Providers Plan Execute Monitor Recognize Account • CRM & Pipeline Mgmt. • Purchase Requisition • Budgeting & Revenue Forecasting • Resource Scheduling • Skills Mgmt. • Scenario Planning • Pricing • Timesheets • Expense Reports & Per Diems • Purchase Orders • Approvals • Collaboration and Notes • Contract Mgmt. • Real-Time Dashboards & KPIs • Project Status, Utilization, & Burn Rate • Open Commitments • Gross & Net Margin • % Complete & EVM • Backlog • GAAP Compliance • T&M, FP, and CP • Revenue Recognition – As Worked, % Complete & Schedules • General Ledger • Accounts Payable • Accounts Receivable • Cost Pools • Indirect Rates • PO Match: 2-Way or 3-Way Match One Software for Projects, People & Financials
  • 57. QUESTIONS? TETIANA GERVIS, CPA SENIOR ASSOCIATE, BDO TGERVIS@BDO.COM KIM KOSTER VICE PRESIDENT OF CORPORATE STRATEGY, UNANET KKOSTER@UNANET.COM

Editor's Notes

  1. In FY16, took on average ~140 days to complete ICP audit (from entrance conference to report issuance), ~885 days elapsed on average between ICP receipt and audit commencement
  2. Types of intermediate base include: Labor dollars or hours Square footage # of Computers
  3. Although a required Schedule, contemporary contractors rarely utilize a FCCM rate
  4. Best Practice: Include running list of all previously held contracts on bottom of schedule to allow for easy YoY reconciliations/tracking
  5. Best Practice: Include running list of all previously held contracts on bottom of schedule to allow for easy YoY reconciliations/tracking
  6. DCAA Annual Report to Congress - Report highlights DCAA's audit performance, recommendations to improve the audit process, industry outreach activities, and key accomplishments for a given year - Provides valuable statistics regarding incurred cost years closed, backlog, dollars examined and questioned costs - DCAA does not consider an audit to be backlogged until the submission has been pending for two or more years - Focus will shift to forward pricing rates and business systems Commercially Accepted Standards for Risk and Materiality Auditors may be informed by contracting officers of the importance of a certain aspect of the information, such as a cost element or account, which auditors may take into consideration in their determination of materiality For Incurred Cost Proposal Audit Subject Matter from $1 to $1,000,000,000 use:  Materiality Threshold = $5,000 x ((Total Subject Matter / $100,000) ^ .75) For Incurred Cost Proposal Audit Subject Matter greater than $1,000,000,000 use:  Materiality Threshold percentage of 0.50 percent
  7. Sustention rates “are calculated based on contracting officer negotiation decisions” and do not account for successful contract appeals or settlements after a Contracting Officer’s Final Decision; DCAA only considers an audit to be backlogged if it is “older than two fiscal years”; and The backlog reduction has occurred, at least in part, because of what DCAA calls “innovative techniques for more efficient incurred cost audits,” i.e., “multi-year vs. single-year audits and sampling low risk audits based on materiality thresholds.” DCAA estimates that it will have eliminated the incurred cost backlog by GFY 2018, even though it is taking (on average) 808 days to complete an incurred cost audit and issue a report. But that metric is old math; in the old math scenario the clock starts ticking when the contractor’s proposal is received. Using the new math metric, it only takes DCAA 143 days from the time the audit starts to the time the audit report is issued. So: 143 days it is. That’s much faster.