GovCon Wednesday’s
A Guide for Indirect Rates
Estimated Read Time: 8 minutes
Government contractors operating under cost-type or Time & Materials (T&M) contracts are expected to recover not only their direct project costs but also indirect costs expenses like rent, benefits, and admin support that keep the business running.
But here’s the catch: unless you have an approved Provisional Billing Rate (PBR), you may not be able to bill those indirects at all. That can delay payments, hurt your margins, and expose your company to compliance risk.
This guide—Part 1 of VSINGH CPA’s 10-part series on indirect rate strategy breaks down exactly what PBRs are, why they’re essential, and how they’re governed under FAR 42.704 and DCAA oversight.
What Is a Provisional Billing Rate?
A Provisional Billing Rate (PBR) is a temporary indirect cost rate submitted by a contractor—or established by the DCAA or contracting officer that allows for the interim reimbursement of indirect costs during contract performance.
Indirect costs may include:
- Fringe benefits
- Overhead
- General & Administrative (G&A) expenses
These costs can’t be billed to the government unless there is an approved rate in place. Instead of waiting until year-end for a final audited rate, the contractor can use a PBR to recover these expenses monthly or as work is performed.
Per FAR 42.704, contractors must submit PBRs at the start of each new fiscal year or when required by the terms of the contract. The government then reviews prior audit data, current cost trends, and other documentation to approve or assign a rate.
If the contract value is low, the auditor or contracting officer may determine that a billing rate proposal isn’t required. In those cases, they will establish the PBR themselves often using last year’s indirect cost experience, while removing nonrecurring or unallowable expenses.
Contractors can also choose to submit a voluntary billing rate proposal to support their case and ensure the most accurate rate is approved. This should be discussed with the assigned DCAA auditor or contracting officer to confirm requirements
Why Are PBRs So Important?
PBRs are a crucial part of any contractor’s compliance and billing framework.
Without one, you simply cannot bill for indirect costs on flexibly priced contracts. That means you’re likely covering thousands if not hundreds of thousands of dollars in real expenses out of pocket.
For small and mid-sized GovCons, this can create serious cash flow issues. Invoices may be delayed or denied entirely, and the lack of a current PBR could raise red flags during a DCAA audit or pre-award review.
Let’s say you’re awarded a $1.2M cost-type contract in Q1. You’ve staffed up, paid for new software licenses, and leased office space. Without a PBR in place, your first invoice is returned because there’s no basis for your indirect costs. That reimbursement delay could stall operations or even payroll.
On the compliance side, submitting and supporting a PBR shows that your business understands federal cost principles and is committed to transparent billing practices. It also protects you from misbilling and major reconciliations at year-end.
When properly implemented, your PBR becomes more than just a rate it’s a tool that supports smoother invoicing, stronger forecasting, and cleaner audit outcomes.
What’s Next in the Series?
This is just the beginning. The full VSINGH CPA PBR education series includes:
✅Part 1: Intro to PBR
2️⃣Part 2: Do I Need a PBR? And How Do I Get One Approved?
3️⃣Part 3: What Goes Into a PBR? Breaking Down the Numbers
4️⃣Part 4: How Do I Calculate My Provisional Billing Rate?
5️⃣Part 5: What Happens After I Submit My PBR?
6️⃣Part 6: Common PBR Mistakes – And How to Avoid Them
7️⃣Part 7: How PBRs Impact My Invoicing and Cash Flow
8️⃣Part 8: Year End ICS
9️⃣Part 9: Can I Update My PBR During the Year?
🔟Part 10: Are You Audit-Ready? Supporting Your PBR with Documentation
Protect your cash flow now. Work with us here at VSINGH CPA to ensure your Provisional Billing Rates are accurate, compliant, and submitted on time. Let’s get started!
👉 Check out our YouTube Short for a quick explainer on Provisional Billing Rates (PBRs): https://youtube.com/shorts/Lx56YXsSvys?si=svjLnSZ2Skhpktyc&utm_source=chatgpt.com