DCAA Updates its Incurred Cost Model

DCAA quietly revised its ICE (Incurred Cost Electronically) Model last month to require additional information on Schedule J. Schedule J contains information on subcontracts awarded under flexibly priced contracts. Schedule J in DCAA's ICE Model is its interpretation of the requirement in FAR 52.216-7(d)(2)(iii)(J) which requires a -

Listing of subcontractors awarded to companies for which the contractor is the prime or upper-tier contractor (include prime and subcontract number, subcontract value and award type, amount claimed during the fiscal year, and the subcontractor name, address, and point of contact information.

The "new" Schedule adds the following data elements:

• Prime contract value
• Subcontractor's DUNS number
• Subcontract performance period

DCAA did not explain why the additional information is necessary. It certainly is not required by the FAR clause we quoted above. DCAA mentioned that it was in the process of updating its ICE User's Guide so perhaps that revision will provide some clarity as to why the information is deemed necessary. Also, DCAA will need to update its Incurred Cost Proposal Adequacy checklist because as the checklist is currently written, it does not address the added data elements.