FAR Part 31 governs every dollar on your cost-reimbursable contracts. The Incurred Cost Submission is your annual proof of FAR Part 31 compliance. We make sure it's adequate, compliant, and defensible to any cognizant federal auditor.
FAR Part 31 is the rulebook. Your Incurred Cost Submission is the annual proof you played by it. We sit at the intersection of both — bringing director-level government finance experience to contractors who need their costs documented, allocated, and defended correctly the first time.
Our principal brings 12+ years of director-level experience in government contract finance and compliance — spanning cost-reimbursement, fixed-price, and hybrid contract structures across some of the most heavily scrutinized federal programs in the country.
Whether you're filing your first ICS or defending indirect rates in a DCAA audit, we provide the senior-level FAR Part 31 guidance typically reserved for large contractors — with the responsiveness of a dedicated advisor.
End-to-end compliance support for government contractors navigating cost accounting and indirect rate requirements.
Optimizing indirect and direct cost rate structures to maximize allowable recovery, ensure allocability, and position your rates for both billing and audit defense.
Complete preparation of your annual Incurred Cost Submission per FAR 52.216-7, including all required schedules and supporting documentation.
Pre-audit readiness assessment and active support during agency audits — from initial document requests through final resolution.
Ongoing compliance advisory covering cost allowability, allocability, and reasonableness standards under FAR Part 31 and applicable CAS standards.
End-to-end close-out support including final rate negotiations, quick-close eligibility assessment, and coordination with contracting officers.
Pre-award and post-award accounting system assessments to ensure your system meets federal adequacy standards.
Every contractor's situation is different. Schedule a free 30-minute consultation and we'll identify exactly where you need support — no obligation, no guesswork.
From initial assessment to final submission, we manage every step with precision and keep you informed throughout.
We review your contract portfolio, accounting system, and prior submissions to scope the engagement and identify risk areas upfront.
We provide a structured data request and work with your team to pull the right cost data, labor records, and supporting documentation.
We prepare all required schedules, perform internal quality review, and walk you through the submission before it goes to the government.
We support the submission process and remain available for any follow-up questions from DCAA or your contracting officer post-submission.
We don't just know the regulations — we know what auditors actually look for. With experience on both the industry and consulting side, we bring perspective most advisors don't have.
Every recommendation is grounded in FAR and CAS. Defensible positions, documented clearly, every time.
ICS submissions have hard deadlines — and missing them has consequences. We build our engagements around your timeline and deliver on schedule, every time.
Multi-contract portfolios, layered cost structures, multiple subcontractors — we're built for the contractors others find too complicated to serve well.
"Every government agency is different. Every rate structure is different. But the standard for getting it right is the same — and the cost of getting it wrong is always too high."
FAR 31 Advisory
Clear answers to the questions every government contractor should understand before their first audit.
FAR Part 31 — Cost Principles — is the section of the Federal Acquisition Regulation that governs what costs the federal government will and will not reimburse on cost-reimbursable contracts. It establishes the three core standards every cost must meet to be allowable: it must be allowable, allocable, and reasonable.
Allowable means the cost is not specifically prohibited under FAR 31.205 and is consistent with the terms of the contract. Allocable means the cost is assignable to the contract in accordance with the benefit received. Reasonable means the cost does not exceed what a prudent person would incur under similar circumstances.
FAR Part 31 is the foundation of every Incurred Cost Submission, every indirect rate structure, and every cost-reimbursable billing. Understanding it — and applying it consistently — is the difference between a clean audit and questioned costs.
An Incurred Cost Submission — also called an Incurred Cost Proposal (ICP) — is an annual filing required of contractors with cost-reimbursable or time-and-materials contracts containing FAR clause 52.216-7, Allowable Cost and Payment. It is due within six months of the close of your fiscal year.
The ICS reconciles the indirect costs you billed throughout the year using provisional billing rates against what you actually incurred. It gives the government — and your cognizant audit agency — the basis to establish your final indirect cost rates and close out your cost-type contracts. An inadequate or late submission can result in payment delays, unilateral rate determinations, and increased audit scrutiny.
Indirect rates are the mechanism by which a contractor allocates indirect costs — costs that benefit multiple contracts and cannot be directly charged to a single contract — across its government work. Common indirect cost pools include fringe benefits, overhead, and general & administrative (G&A) expenses.
Your indirect rates are expressed as a percentage of an allocation base — typically direct labor dollars, total direct costs, or total cost input. How you structure your pools and bases has a direct impact on your contract pricing, billing, and audit exposure. Rates that are poorly structured or inconsistently applied are one of the most common sources of audit findings under FAR Part 31 and CAS.
A DCAA-adequate accounting system is one that meets the criteria outlined in the SF 1408 — the Pre-Award Survey of Prospective Contractor Accounting System. At a minimum, an adequate system must be able to segregate direct costs from indirect costs, identify and exclude unallowable costs, accumulate costs by contract, and produce data that is consistent with your disclosed accounting practices.
An inadequate accounting system is a significant risk — it can prevent contract award, trigger a billing system disapproval, and expose you to questioned costs during an incurred cost audit. Accounting system adequacy is not a one-time check. It must be maintained consistently throughout contract performance.
Whether you have an overdue ICS, an upcoming DCAA audit, or just need to get your indirect rates structured correctly — reach out for a free 30-minute consultation.
We typically respond within 1 business day. All inquiries are confidential.
Key tools and references every government contractor working with cost-reimbursable contracts should have bookmarked.
The official Incurred Cost Electronically (ICE) Model — the standard submission package for preparing your annual ICS. Now updated with Power Query automation for 2025.
The official DCAA checklist used to determine whether your Incurred Cost Submission is adequate for audit. Every submission should be reviewed against this before filing.
The 2025 allowable compensation cap is $671,000 per FAR 31.205-6(p). Applies to the five most highly compensated employees — compensation above this threshold is unallowable on cost-type contracts.