Incurred Cost Proposals

Too Many DCAA Auditors Continue to Bully Contractors

Too Many DCAA Auditors Continue to Bully Contractors About ICPs/ICE Despite Clear Regulations Defining an Adequate Cost Proposal

A couple of examples:

  1. Too many DCAA auditors tell Contractors that they are required to submit Incurred Cost Proposals (ICPs) utilizing DCAA’s own Model ICE. This is simply not true:
  2. The regulation outlining the information required for an adequate contractor submission came after DCAA created their own version. The regulation can be argued as a refutation of the complexity DCAA wanted.
  3. If contractors were required to use the Model ICE, DCAA’s version would be approved by the OMB and/or the GSA—IT IS NOT. The Paperwork Reduction Act prohibits government employees to force the use of unapproved forms.
  4. DCAA’s Model ICE is a complicated form designed by committee with poorly implemented objectives, invalid functions, and a promised support manual overdue by years. Contractors, especially small businesses, are better off using a simplified version that looks like the schedules DCAA dreams about.
  5. DCAA requires contractors to report at the CLIN even though the regulations state the contractor is to report at the contract level, exponentially complicating both the submission and the audit of the submission.
  6. Each DCAA Auditor seems to create their own idea of what is an adequate submission. One auditor recently demanded that the contractor complete the schedules for ALL contracts to include those without any current year activity (Schedules I, K, and O). Another told a contractor to prepare the schedules as she directed with no explanation beyond her assertion that if they did not need revision, she would not ask for it.

 All of this costs contractors money, too much of it. Not to mention the stress and arguments.

As DCAA desperately attempts to address its backlog on incurred cost submissions, especially after Congress limited their activities (and budget) due to the backlog, contractors enjoy a rare opportunity to help DCAA limit and reduce their audit work by submitting clean and adequate cost proposals that DCAA can sign off on as “low risk”.

The trick is simple, too simple. All a contractor really needs is to know more about incurred cost submissions and the regulations than the DCAA auditor. This is easier than one would think; but if you have better things planned, just use the contact form to touch base with us.. We will be happy to review or even just check your submission.