The Defense Contract Audit Agency (DCAA) has just released an updated version of the Incurred Cost Electronically Model (the standard ICE submission) for contractors preparing adequate incurred cost proposals in accordance with FAR 52.216-7.
This new version, 2.0.1e, can be downloaded from the DCAA’s ICE Model page on their website. It is important to note that there were no computational changes made to this latest version, however, there were some other changes made.
Schedule J changes:
With ICE version 2.0.1e, additional information will now be required for Schedule J (as a refresher, Schedule J provides DCAA with the Subcontract Information such as contact information, subcontract value, period of performance, costs incurred for each subcontractor, and award type). In the latest version, additional information including the prime contract value and subcontractor’s Duns number will now be required.
Schedule C changes:
ReliAscent would like to note that contractors should be aware of the change to Supplemental Schedule C (which requires the identification of prime contracts under which the contractor performs as a subcontractor). The change includes the identification of subcontract efforts awarded to your company at the pricing action level (your delivery order, CLIN) for all subcontract efforts (i.e. cost-type, incentive contracts, T&M/LH, FFP and others). This is different from Schedule J because Supplemental Schedule C is requiring contractors to include ALL contracts in which the company is a subcontractor (no matter the prime contract type). This means that any FFP or commercial contracts that your company is a subcontractor on, would be included on this schedule (as you may remember, these types of contracts are usually excluded for audit purposes, but per FAR 52.216-7, “Allowable Cost and Payment” states that supplemental information is not required to determine if a proposal is adequate, but may be required during the audit process).
What Does This Mean to your Business?
As we noted above, there were no computational changes to the ICE model but there are some informational changes that each contractor should be aware of. It means you should complete Schedules C & J completely and have it on file in the case of a future DCAA audit. Based on previous experience with the DCAA, all contractors should begin using the new version of the ICE immediately as the DCAA always has a bias towards the most recent model.