The Season for the Incurred Cost Submission (ICE)

The Federal Acquisition Regulations (FAR Para 52.216-7) require that the Federal Contractor submit an "adequate final indirect cost rate proposal" to their Contracting Officer within 6 months of the end of the Contractor's fiscal year.  For most small businesses, the fiscal year coincides with the calendar year which means the submission is due at the end of the following June.  Well, here we are at the end of June!  I must say that we are experiencing a heavy workload in helping clients comply with this regulation at this time.  But what if you just can't get it done in time, or realized too late that it is due now?  What recourse do you have?  The government will grant extensions to file these submissions if requested in writing to the CO and support their request with adequate supporting data. 

We have had some clients ask if they must use the government's ICE Model that is published on the DCAA website.  That is not an absolute requirement but it could help when the DCAA audits the submission.  It could help because the DCAA is familiar with that model and format and this will most certainly result in fewer questions from the auditor.  It also may help to make sure that the contractor does not forget some of the required data to be included.  This is defined in FAR part 52.216-7 (d) and includes at least 15 major requirements.  In using custom or "homemade" models it could be easy to forget or not include sufficient information.  It is usually helpful to have someone that has experience in using the model to also prevent errors, omissions and mis-interpretations. 

Well the ICE season is almost over for contractors with fiscal years ending on December 31 but it is just starting for companies with fiscal years ending on March 31.  Happy Ice Skating!


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