ICP Dashboard - The Many Names of the Incurred Cost Submission

01 — Terminology

One Filing, Many Names

The FAR calls it one thing. DCAA calls it another. Auditors, Contracting Officers, and consultants each have their favorite label. Here is the full list — all refer to the same annual deliverable under FAR 52.216-7.

ICP

Incurred Cost Proposal

A DCAA-derived term — not found in the FAR itself, but used extensively in the DCAA Contract Audit Manual (Chapter 6), the standard Incurred Cost Audit Program, and the ICE model. The FAR’s own term is “final indirect cost rate proposal.”

ICS

Incurred Cost Submission

The label DCAA uses for the package itself — the Incurred Cost Submission Adequacy Checklist is named after it. Inside that checklist and the Contract Audit Manual, DCAA uses “incurred cost proposal” interchangeably to refer to the same deliverable.

ICE

Incurred Cost Electronically

Emphasizes the electronic filing format — usually the completed DCAA ICE Model workbook transmitted by email or agency portal.

FICRP

Final Indirect Cost Rate Proposal

The exact term used in FAR 52.216-7(d)(2)(i), which requires the contractor to submit an adequate final indirect cost rate proposal to the Contracting Officer (or cognizant Federal agency official) and auditor within the six-month period following the expiration of each of its fiscal years. This is the regulatory anchor every other label points back to — ICP, ICS, ICE, FIRP, and ICRP all describe the same FICRP package.

What “final” means — the rates are computed from the closed-book general ledger after fiscal year-end, replacing the provisional billing rates that were used during the year. Once the Contracting Officer and contractor agree, the rates become the final, audited indirect rates for that FY.
What “adequate” means — the package must satisfy the DCAA 47-question Adequacy Checklist before audit work begins. An inadequate proposal is returned and is treated as not submitted — with the six-month clock effectively still running.
Penalty exposure — FAR 42.709 imposes penalties (disallowed cost plus interest, and in some cases a matching penalty) for expressly unallowable costs included in a final indirect cost rate proposal. The penalty regime attaches specifically to the FICRP — this is the document the FAR is policing.
Where it shows up — ACO rate-agreement letters, FAR 52.242-4 Schedule N certification, and the closeout of every flexibly-priced contract for the covered fiscal year.

Takeaway

Do not let the terminology trip you up. If a Contracting Officer, DCAA auditor, or consultant references any of the terms above — they mean the same annual package: schedules, reconciliations, and supporting data that true up your indirect rates for a single fiscal year.

02 — The Core Mechanic

What It Actually Does

Strip away the acronyms and this filing does one thing: it compares what you billed the government (provisional rates) against what you should have billed (actual rates) — and trues up the difference.

What You Billed

Provisional Indirect Costs

Costs invoiced during the year using estimated (provisional) rates approved at contract start per FAR 42.704.

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What You Should Have Billed

Actual Indirect Costs

Costs computed from the closed-book general ledger after fiscal year-end. These are the final indirect rates for that FY. (FAR 42.705)

Result — The True-Up

Overbilling or Underbilling on Each Flexibly-Priced Contract

Overbillings (you invoiced too much) are credited back to the government. Underbillings (you invoiced too little) may be invoiced up to the contract funding limit. That reconciliation — at the contract level — is the purpose of the ICS.

Plain-English

Provisional rates are a guess you live on during the year. Actual rates are the truth you compute after the year closes. The ICS exists so the government gets paid on truth, not on guesses.

03 — Timing

Six Months After Fiscal Year End

FAR 52.216-7(d)(2)(i) requires submission within six months after the end of the contractor’s fiscal year — the single firm deadline that drives everything else.

Fiscal Year End

Day 0

Books close. Trial balance reconciled. General ledger locked for the year.

Data Assembly

Months 1–3

GL extracted, payroll reconciled, contract data compiled, unallowables screened.

Schedules Built

Months 3–5

Schedules A–O prepared; executive comp analyzed; adequacy walkthrough completed.

Submission Due

Month 6

Package submitted to DCAA cognizant office. Calendar-year contractor? Due June 30.

Consequences of Late Filing

Failing to submit on time can trigger the DCAA adequacy process on an unfavorable footing, delay contract closeout, block release of retentions, and create exposure under FAR 42.709 for unallowable costs discovered in any later-submitted package. The ACO may also impose unilateral final rates if the contractor remains non-compliant.

Call It What You Want. File It on Time.

ICP Dashboard prepares a submission-ready package — Schedules A through O, reconciled, adequacy-checked, and formatted for DCAA.

IncurredCostProposal.com

The Many Names of theIncurred Cost Submission