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DCAA Incurred Cost Audit Support for Northern Virginia & DC Government Contractors
ICP preparation, FAR Part 31 allowability review, and DCAA audit defense for cost-type government contractors. Meeting the June 30 deadline — and defending your submission if DCAA selects it for audit.
What is a DCAA incurred cost audit and who is required to file?
Government contractors with cost-type contracts (CPFF, CPAF, T&M) must submit an Incurred Cost Proposal (ICP) to DCAA within 6 months of fiscal year-end per FAR 52.216-7. DCAA audits the proposal to verify that costs were allowable, allocable, and reasonable under FAR Part 31. Contractors with over $15 million in flexibly-priced contracts undergo mandatory audits; smaller contractors may use an alternative ICP submission.
ICP Problems We Solve
ICP deadline missed — now facing contract closeout penalties and disputes with the contracting officer
DCAA selected your ICP for full audit — unallowable costs buried in your G&A pool could trigger significant repayment
Your incurred cost submissions are years behind (the "ICP backlog") — DCAA is threatening to freeze new contract awards
Cost-type contract just ended and you don't know how to calculate the final settlement
You're a small GovCon that just crossed the $15M threshold — first ICP submission due and you don't know the format
Key Terms
- Incurred Cost Proposal (ICP)
- An annual submission required by FAR 52.216-7 from contractors with cost-reimbursable contracts. The ICP reconciles estimated costs used for billing during the year with actual allowable costs incurred, establishing the final contract settlement.
- FAR Part 31
- Federal Acquisition Regulation Part 31 — the cost principles that define which costs are allowable and reimbursable under government contracts. Costs must be allowable, allocable, and reasonable to be included in an ICP.
- Flexibly-Priced Contracts
- Contracts where the government reimburses actual costs (plus fee) rather than a fixed price. Includes Cost-Plus-Fixed-Fee (CPFF), Cost-Plus-Award-Fee (CPAF), Time-and-Materials (T&M), and Labor-Hour contracts.
DCAA Incurred Cost Services
From first-time ICP preparation to multi-year backlog remediation and active audit defense.
ICP Preparation and Review
Complete preparation of the Incurred Cost Electronically (ICE) model in DCAA's required format. Includes schedule preparation, rate calculations, and reconciliation to financial statements.
Allowability Analysis (FAR Part 31)
Pre-submission review of all claimed costs against FAR Part 31 allowability standards. Identify and segregate unallowable costs before DCAA does — preventing findings and repayment demands.
Direct vs Indirect Cost Classification Review
Verify proper cost classification between direct and indirect pools. Misclassification is a leading cause of DCAA audit findings and can trigger multi-year lookbacks.
DCAA Audit Defense and Representation
CPA representation during DCAA fieldwork. We respond to information requests, defend allowability positions, and negotiate settlements on your behalf.
ICP Backlog Remediation
Catching up on multiple years of unfiled ICPs. We prioritize submissions by risk, negotiate with DCAA for efficient resolution, and help clear the backlog before it affects new awards.
Final Contract Settlement Calculation
When a cost-type contract ends, the final settlement reconciles all billings to actual allowable costs. We calculate the amount owed (or refundable) and prepare the documentation for closeout.
Types of DCAA Audits — Which Applies to You?
| Feature | Incurred Cost Audit | Forward Pricing Audit | Accounting System Audit |
|---|---|---|---|
| Trigger | Annual ICP submission required | Bidding on new cost-type contracts | New contractor or system change |
| FAR reference | FAR 52.216-7 | FAR 42.1701 | DFARS 252.242-7006 |
| Timing | Annual; ICP due 6 months after FYE | Pre-award; before contract execution | One-time; periodic re-evaluation |
| Risk | Disallowed costs, contract underpayment | Lower rates accepted; competitive disadvantage | System disapproval; ineligible for cost-type contracts |
| CPA role | ICP preparation + audit defense | Rate proposal support + negotiations | System documentation + gap remediation |
ICP Preparation Process — 5 Steps
Contract Review
Analyze all active cost-type contracts; identify billing rates used vs. actual rates. Determine which contracts require ICP settlement and calculate the exposure.
Cost Pool Analysis
Organize costs into proper pools (direct, fringe, overhead, G&A) and identify potentially unallowable costs per FAR Part 31 before they appear in the submission.
ICP Preparation
Prepare the Incurred Cost Electronically (ICE) model in DCAA's required format. All schedules, rate calculations, and reconciliations to your financial statements.
Pre-Submission Review
Internal audit for unallowable costs, mathematical accuracy, and rate reconciliation before submission. Catch issues before DCAA does.
Audit Support
Provide DCAA with requested documentation; defend allowability positions; negotiate settlements. CPA representation throughout the audit process.
Serving the DMV GovCon Community
The DC, Maryland, and Virginia area has the highest concentration of government contractors in the United States.
Northern Virginia Defense Corridor
Tysons Corner, Reston, Herndon, Falls Church — the densest concentration of defense IT and professional services contractors in the US. DCAA has a regional office in Springfield, VA serving this corridor.
Maryland Government Agencies
Fort Meade (NSA, Cyber Command), Bethesda (NIH, DARPA), Aberdeen Proving Ground. Contractors supporting these agencies frequently hold cost-type contracts requiring annual ICP submissions.
DC Federal Headquarters
DoD, GSA, DHS, and other federal agency headquarters are in DC proper. Contractors supporting these agencies often have the most complex cost structures and highest DCAA audit risk.
DCAA Regional Coverage
DCAA has regional offices in Rockville, MD and Springfield, VA specifically serving the DMV contractor community. We know the local DCAA offices and their audit priorities.
Related Services
Government Contractor Audit
Full DCAA compliance services overview.
DCAA Forward Pricing Rate Audit
Forward pricing rate proposals and FPRA negotiation.
Attestation Services
SOC 1, SOC 2, and SSAE 18 engagements.
SOC 2 Audit
Security controls attestation for tech companies.
Virtual CFO Services
Strategic financial oversight for growing GovCons.
Book a Consultation
Talk to a DCAA specialist about your ICP.
DCAA Incurred Cost Audit FAQs
Common questions from government contractors in Northern Virginia, DC, and Maryland about ICP filing and DCAA audits.
ICP Deadline Approaching? Let's Get It Done.
Whether you're filing your first ICP or catching up on years of backlog, we prepare defensible incurred cost proposals and stand by you through DCAA audit.
Serving government contractors in Reston, Herndon, Tysons, Chantilly, McLean, Rockville, Bethesda, and across the DC metro area.