Incurred Cost Submissions Still Due June 30 for Contractors with December 2019 Year End

April 23, 2020

There has been no “blanket extension” of time for government contractors to submit incurred cost filings due to the COVID-19 pandemic. Unless a specific extension of time is requested in accordance with the Federal Acquisition Regulations (FAR), contractors will be expected to file on June 30, 2020 in accordance with contract terms and conditions, specifically the allowable cost and payment clause:

52.216-7 Allowable Cost and Payment

(d)(2)(i) The Contractor shall submit an adequate final indirect cost rate proposal to the Contracting Officer (or cognizant Federal agency official) and auditor within the 6-month period following the expiration of each of its fiscal years. Reasonable extensions, for exceptional circumstances only, may be requested in writing by the Contractor and granted in writing by the Contracting Officer. The Contractor shall support its proposal with adequate supporting data.

Aronson advises federal contractors to either submit the filing on time, or, if the filing deadline cannot be met, to request an extension of time in writing to the contracting officer. Since we are in unprecedented times and contractors are dealing with many contract issues, the likelihood of an approval of the extension is favorable.

For additional resources, please see Aronson’s guide on preparing an adequate incurred cost submission.