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If you have FAR clause 52.216-7 in your award, you have a cost reimbursable award and therefore you are required to submit a final indirect cost rate proposal also know as the incurred cost submission, in accordance with FAR 52.216-7(D)(2)(i), within 180 days after your fiscal year end.

Incurred Cost Submissions: Text


A valuable resource to tap into in times of need.

  • In this capacity I work as a staff member of the CPA firm or Consulting firm who has hired me to help them prepare incurred cost submissions for their clients.  This works great for the CPA firms and Consulting firms, especially during their busy times, as they bring me on board for a temporary period of time for specific engagements.  This is a cost effective way to bring on experienced staff to help meet demands and deadlines.  I typically take on the role of preparer only.


I provide a discounted price for clients who have adopted the g2 Accounting and Compliance Model.

  • If your accounting systems adheres to the g2 Accounting and Compliance Model and you have a periodic review, the incurred cost submission is a much more efficient and effective process and is more likely to be compliant and pass audit.  In this case I can help prepare and submit this for you.

  • I can also help respond to auditor questions if they arise after submission, during the adequacy check.

  • If your incurred cost submission is selected for audit, I can help.   


The first year of preparation is the most complicated and time consuming and as a result is unfortunately the most expensive, however you should see a discount in subsequent years.

  • It's all about having a compliant accounting system.  Therefore it is imperative you do a thorough assessment of your system prior to hiring someone to prepare your incurred cost submission.  You can download the g2 Accounting and Compliance Adequacy Checklist to help you do the assessment.

  • I typically recommend doing a risk and compliance analysis in advance of preparing the incurred cost submission so that you can identify and fix matters before the preparation begins and especially before the auditors look at it. 

  • I tend to shy away from taking on the preparation of the incurred cost submission for companies who have not adopted the g2 Accounting and Compliance Model, as it becomes complicated for me to sort things out and to get you into compliance should there be a need.


I explain below what the process looks like.

  • It starts with a compliant accounting system.  If you don't have a compliant accounting system it becomes very difficult to file a compliant incurred cost submission.  I suggest you download the g2 accounting and compliance adequacy checklist to determine where you stand.

  • If you don't have a compliant accounting system, we can arrange for a risk and compliance analysis to determine the full extent of what steps would be necessary to get you into compliance.

  • Assuming you have adopted the g2 Accounting and Compliance Model and you have a periodic review, the next step is to gather all the documents necessary to prepare the incurred cost submission.  I can send you a list of the required information.

  • The next step would be to prepare the incurred cost submission.  In my experience it takes somewhere between 20 to 30 hours to prepare, if you have between 1 and 5 contracts.

  • When complete, it is then submitted to DCAA or to DFAS in the case of NIH.

  • DCAA has a much more strict process for determining adequacy and you have a 100% chance of being selected for audit.

  • DFAS is much more laid back.

  • When deemed adequate, audited and finalized, your rates become final. You can now true up your rate in the accounting system and update your billing and/or submit final invoices. 

Incurred Cost Submissions: Services
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