Friday, June 27, 2014

Annual Incurred Cost Submissions are Due in a Three Days

Government contractors with cost-type contracts and whose accounting period is the calendar year, have just a couple of more days to submit their final incurred cost submissions for 2013. According to FAR 52.216-7(d)(2) contractors are required to submit their annual submissions within six months after year end. If you are uncertain as to whether the requirement applies to you, check your contract(s) to see if the aforementioned clause is included.

Many contractors are now in the position of needing an extension for submitting their final incurred cost rate proposals. Some have and will mistakenly make a request for an extension to DCAA (Defense Contract Audit Agency). That would be wrong. FAR 42.302 and FAR 42.705-1(b)(1)(ii) give that responsibility to the Administrative Contracting Officer (ACO). ACOs for DoD are typically part of DCMA (Defense Contract Management Agency). If you are uncertain who your ACO is, contact DCMA.

Any request for extension should include the rationale for requiring additional time. There is no guarantee that the ACO will accept the rationale or grant an extension. Based on our experience however, ACOs have routinely granted reasonable extensions of 30 or 60 days.

Even though the Government may not get around to auditing your incurred cost proposal for several years, the submission is still important from the Government's perspective to adjust provisional billing rates to the final rates. Differences should be reflected in the next billing cycle.

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