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IN-HOUSE TRAINING
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In-House
This 2 day program will be an depth discussion on the ICP.The program topics will include discussions around the regulations within the FAR clauses, CAS and DFARs that are applicable.You will learn about the government’s administration and oversight of ICPs and responsibilities of both the DCMA and DCAA,the use of IPA’s for auditing.

Attendees will walk away with understanding of the alternative risk strategies,actions to take after an ICP submission and how to prepare for a government audit. Learn how to get to a quick close out final rate as well as understanding the statute of limitations on ICP. During the audit process, learn how to anticipate the inquiries and challenges and how to best respond and communicate.

At the end of the program, you should be prepared and have answers to questions such as:

  • What are my alternative risk strategies I can employ?
  • How do I best anticipate and prepare for the ICP audit?
  • What are the alternative rate settlement procedures?
  • What are the limitations to ICPs?
  • What are typical audit issues I can expect from the DCAA?
  • How do I respond to the draft audit results?
  • What are the issues around contract closeout that I should be aware of?
Dates and Locations

This course will be scheduled soon. Please enter your information below to receive a notification when the class is scheduled.

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Life Cycle of an Indirect Rate Cost Proposal
1.     Introductory Comments

a.     Course faculty and course objectives

b.    Contractor Alternative Risk Strategies: i) Maximizing Cost Recovery, ii) Avoiding All Compliance Issues, iii) Achieving Target Rates

2.     Government Contract Regulations:  Listing of relevant FAR, CAS, DFARS

a.     52.216-7: Allowable Cost and Payment Clause including (d) adequate ICP, rate agreement letter, actions after rate agreement letter, (e) billing rates, (f) quick close-out rates and (h) final payment

b.    52.215-2: Audit and Records—Negotiations

c.     52.232-7:  Payments under Time and Materials (T&M) Contracts

d.    52.242-4: Certification of Final Indirect Cost Rates

e.     52.242-3: Penalties for Unallowable Costs

f.     31.201-205: Contract Cost Principles and Procedures

g.    42.704:    Billing Rates

h.     42.705:    Final Indirect cost rates,  Contracting Officer Determination or Auditor Determination procedures

i.      4.703-705: Contractor records retention

j.      33.206: Statute of Limitations on claims (Initiation of a claim):  33.206

k.    52-216-7(d)(5) and 42.202(d)(2): .Prime Contractor responsibility for subcontracts

l.      Part 30:   Cost Accounting Standards Administration

m.   DFARS 252.242-7006:  Accounting System Administration (business system)

3.     Government Contract Administration and Contract Oversight/Audit

a.     Cognizant Federal Agency

b.    Defense Contract Management Agency (DCMA); responsibilities and relevant agency policies

c.     Defense Contract Audit Agency (DCAA); responsibilities and relevant agency policies including the ICP adequacy checklist (2016) the ICP backlog and strategies to reduce the backlog including DCAA’s low risk sampling plan

d.    Civilian Agencies including their use of DCAA or IPAs (Independent Public Accounting firms)

e.     GSA Schedules (potentially audited, but not by DCAA)

4.     Contractor actions after ICP submission and before a government audit

a.     Updating provisional billing rates and re-invoicing

b.    Rescinding a previously submitted ICP

1.     Audit results & resolutions (prior year) and the penalty clause applicable to rescinded ICPs

2.     Correcting errors and omissions---DCAA Adequacy rejection notice

3.     Correcting errors and omissions---contractor self-initiated

4.     Re-certification

 

5.     Alternative rate settlement procedures

a.     Quick close-out final rates

b.    Low risk sampling or final rate agreement settlement offer (decremented or
 un-decremented rates) implicating “no audit”

c.     Far 33.206 Statute of Limitations:  Does the six year statute of limitations apply to ICPs; if yes, when does the clock start?

6.     The Audit

a.     Notification of audit or review: government agency or third party?

b.    Entrance conference, audit coordination ground-rules, tracking data requests, access to employees, status of subcontracts’ audits.

c.     Audit scope, “auditable” contract types, direct contract costs, indirect costs/rates, and audit reliance on systems/prior audits.

d.    Statistical sampling and DCAA Variable Statistical Sampling Policy and EZQuant

e.     Anticipating audit inquiries/challenges

1.     Prior audit transaction testing and results

2.     Comparative analysis of accounts (52-216-7(d)(iv)(a)) including significant rate variance (provisional billing rates vs. certified ICP rates)

3.     Changes: cost accounting practices, organizational, types of contracts, product lines, new commercial business lines.

4.     Interim results/auditor communications

 

7.     Typical audit issues (DCAA audit examples)

a.     Determining allowability (FAR 31.201-2) including (d) adequate records including proof of payment as well as directly associated unallowable costs

b.    Reasonableness (31.201-3) including brief discussion of two KBR CoFC cases

c.     Allocability (31.201-4)  including out-of-period costs and potential for CAS non-compliance

d.    Direct costs FAR 31.202 and 31.201-2(d)) including T&M issues (52.232-7)

e.     Compensation (31.205-6) including reasonableness, the statutory cap, bonuses, severance, back-pay and deferred compensation

f.     Public relations/advertising, direct selling, marketing, business development (31.205-1 & -38)

g.    Employee morale and welfare (31.205-13) vs. Entertainment (31.205-14)

h.     Organizational costs (31.205-27)

i.      Professional and consultant costs (31.205-33) including lobbying (31.205-22)

j.      Trade, business, technical and professional activity costs (31.205-43)

k.     Travel costs (31.205-46)

l.      Legal costs (31.205-47)  

8.     The process for issue resolution

a.     Responding to DCAA draft audit results

1.     Compressed response times

2.     Concurring to rates, but not in principle & projecting old year issues into all remaining “open” years

3.     Engaging on all fronts or key points in reserve holding in reserve

4.     Interjecting contract disputes’ decisions (case law)

5.     Probability of issue resolution with DCAA:  the unintentional impact of government auditing standards/auditor independence

6.     Final rate agreement letters: final or not final including contract disputes’ decisions impacting “finality” and auditors re-opening prior year audits

      1. Direct costs and the lack of a final direct cost agreement letter

  1. Responding to Administrative Contracting Officer rate settlement offers, letters or requests for contractor response to DCAA audit reports
    1. Overall strategy:  issue resolution or agree to disagree
    2. Direct costs (not necessarily resolved along with final rates)---subcontract issue resolution “passed” to the prime and prime ACO.
    3. Agreement without agreement in principle
    4. Contract Disputes Act
    5. Penalties (52.242-3) and actions after final rate agreement including revised invoices (60 days)

  2. Contract close-out
    1. Timing for final vouchers (120 days after the rate agreement letter)
    2. Contents of a final voucher including expectations that amounts match the cumulative schedule in the ICP
    3. Requirements for subcontract closeout including the regulatory requirement for prime contractors to establish final costs and rates for their cost-type subcontracts
    4. Contract close-out and future Cost Accounting Standards (CAS) non-compliances or why a CAS covered contract is never fully closed
Michael Steen, CPA
Mike Steen is a Senior Director with Redstone Government Consulting, Inc. and a specialist in complex compliance issues to include major contractor cost accounting & business system regulations, financial compliance, resolution of DCAA audit issues, Cost Accounting Standards application, litigation support, and claims preparation. Prior to joining Redstone Government Consulting, Mike served in a number of capacities with DCAA for over thirty years, and upon his retirement, he was one of the top seven senior executives with DCAA. Mike Served as a Regional Director for two DCAA regions, and during that time was responsible for audits of approximately $25B and 800 employees.
In October 2001, he was selected for the Senior Executive Service and in 2006 he received the Presidential Rank Award. During Mike’s tenure with DCAA, he was involved in conducting or managing a variety of compliance audits, to include cost proposals, billing systems, Cost Accounting Standards, claims, defective pricing, and then-evolving programs such as restructuring, financial capability and agreed-upon procedures. He directly supported the government litigation team on significant contract disputes and has prepared and presented various lectures and seminars to DCAA staff and business community leaders.
Since joining Redstone Government Consulting in June 2007, Mike has developed and presented training and seminars on Government Contracts Compliance to NCMA, Federal Publications Seminars and various clients. Mike also is a prolific contributor of written articles to government contracting publications, as well as to our own Government Insights Newsletter. Mike also serves as the director of our training service offerings, with responsibilities for preparing and developing course content as well as instructing our seminars to clients and general audiences throughout the U.S. Mike also serves as a faculty instructor for the Federal Publications Seminars organization.

EDUCATION
Mike has a BS Degree in Business Administration from Wichita State University. He is also a graduate of the DCAA Director’s Fellowship Program in Management, and has a Masters Degree in Administration from Central Michigan University. Mr. Steen also completed a number of OPM’s management and executive development courses.
MEET YOUR CONTINUING EDUCATION CREDIT REQUIREMENTS
SEE INDIVIDUAL COURSES FOR AVAILABLE CREDITS
Certificates of Completion are provided to all seminar participants who attend Federal Publications Seminars courses following the event, upon request.
NCMA: CONTRACT MANAGER CERTIFICATION
All Federal Publications Seminars courses meet the course requirements of the National Contract Management Association’s certification programs. We are a proud Education Partner of the NCMA.
CPE: CONTINUING PROFESSIONAL EDUCATION
Federal Publications Seminars is part of West Professional Development, which is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.learningmarket.org.
CPE HOURS
This Program is eligible for: 11.00 (CPE) hours of credit
Program Level: N/A
Program Prerequisite: N/A
Advance Preparation: N/A
Method: N/A
CLP: CONTINUOUS LEARNING POINTS
APPROVED FOR CLP BY
DEFENSE ACQUISITION UNIVERSITY
Defense Acquisition Workforce members must acquire 80 Continuous Learning Points (CLP) every two years from the date of entry into the acquisition workforce for as long as the member remains in an acquisition position per DoD Instruction 5000.66. We will provide you with documentation of points awarded for completing the event.
CLP HOURS
This Program is eligible for: 11.00 (CLP) hours of credit
CLE: CONTINUING LEGAL EDUCATION
States have widely varying regulations regarding MCLE credit. LegalEdcenter is an approved provider in AL, AK, AR, CA, GA, IL, ME, MO, MS, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, PA, RI, SC, TN, TX, UT, VA, VI, VT, WA, WI, and WV. Credit may be applied for in other jurisdictions on request and in accordance with state MCLE rules.
** Please note that because some states are changing their policy on CLE reporting, you will need to fill out the request for credit from Federal Publications Seminars within 10 business days, or we may not be able to issue credits for the program.
CLE HOURS
This Program is eligible for: 11.0 (60 minutes),
100
Basic or fundamental subject matter is covered. Courses are geared to general knowledge or can be taken as a refresher.
200
Specific topics or issues within a topic area are covered. Students should be familiar with terms of art and general concepts concerning the course topic.
300
Workshops and class discussions cover specific subject matter in-depth, and participation is strongly encouraged. Attendees should have at least 2-3 years' experience in the area of study.
400
Courses build upon students' knowledge and experience, and cover complex issues within the subject matter. Should have 4-5 years' mastery of subject for in-depth analysis.
500
Masters-level programs designed for professionals with 5+ years' experience. Courses cover in-depth and technical analysis on specific subjects and updates on current issues.
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Life Cycle of an Indirect Cost Rate Proposal
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