Tuesday, April 24, 2018

Due Date for Annual Incurred Cost Submissions Approaching

For Government contractors whose fiscal years end on December 31st, the June 30th due date for submitting required annual incurred cost proposals is rapidly approaching.

If you need more time, you can always request an extension from your administrative contracting officer. Do not request an extension from DCAA (Defense Contract Audit Agency) - they have no authority to grant extensions (refer to FAR 42.302 and FAR 42.705-1(b)(1)(ii)).

Some administrative contracting officers (ACOs) perfunctorily approve such requests. Others expect the requests to include justification for the extension. All ACOs will expect the request to be in writing. Before submitting any due date extension request, we suggest you contact you ACO and find out their expectations.

The Government is definitely tightening up its practices for handling these submissions. Once received, DCAA's got only 60 days to figure out whether the submissions are adequate and only a year to complete the audit (see Policy Shift for DCAA Adequacy Reviews).

If you need an extension and don't know who your ACO is (surprisingly many contractors don't know) you can find him or her by performing a search at DCMA's (Defense Contract Management Agency) Contract Management Team Search. You need a contract number or your company's CAGE code.

If you need assistance in preparing your incurred cost submission, give us a call at 866-849-4887, extension 2 (for Bill Vermie) or extension 3 (for Doug McAlpine).

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