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Provisional Rates - A potential DCAA focus area in 2012

Posted by Mike Anderson on Tue, Jan 24, 2012 @ 03:01 PM

Provisional Rates

Over the last year or so the DCAA has focused attention on larger government contractors.  Many smaller businesses may feel left out since they have not been visited by the DCAA.  More likely, they may feel that everything is "ok" since for most of us "no news is good news".  Our Account Managers here have been hearing bits of news from various sources that this might change in 2012.  First, the DCAA is apparently going to focus more on completing Incurred Cost Proposal audits in 2012, especially from smaller contractors.  The backlog of Incurred Cost audits was estimated to have quadrupled over the last 10 years but even DCAA Director Fitzgerald didn't know the exact number in a meeting with Senators Brown (R-MA) & McCaskill (D-MO) in  February last year.  Rest assured the number is huge.  We have recently seen clients that have received letters from the DCAA that demand the Provisional Billing Rates for Jan. 1, 2012 thru Dec. 31, 2012 be completed and turned in to the DCAA by February 1, 2012.  So we are seeing focus not only on the provisional rates (Ref Far 42.704(b)) but we expect to see a focus on cleaning up the backlog of Incurred Cost Proposals.  Both of these efforts will affect small business contractors.  The Provisional rates affect your ability to bill the government in the near future.  Once the DCAA audits the Incurred Cost Proposals the provisional rates become final rates.  The government is bound to payment based on the final indirect rates so these are very important numbers.  If your final indirect cost rates are lower than your provisional indirect cost rates, then the contractor could be liable for repayment to the government.  The important message for all government contractors is twofold: 1) it is important that your provisional rates are calculated correctly so that they come as close as possible to the final rates and 2) it is important that your Incurred Cost Reports are correctly done and accurate.  We envision spending a lot of time on those two areas this year.  It would be wise for all government contractors to do the same.

Topics: DCAA, Indirect billing rates, Year end indirect rates, DCAA audit, Provisional rates