GovCon Wednesday’s
Understanding the DCAA Review Process
Estimated Read Time: 8 minutes
Submitting your Provisional Billing Rate (PBR) is a major milestone but it’s not the finish line.
Many government contractors assume the hard part is over once the proposal is submitted. In reality, the post-submission phase can determine whether your rate is approved quickly, delayed for weeks, or adjusted in a way that affects your margins.
This article Part 5 of VSINGH CPA’s 10-part educational series explains what happens after your PBR submission, how DCAA or your contracting officer evaluates it, and what you can do to ensure the process runs smoothly.
What Happens After You Submit Your PBR?
Once your billing rate proposal is submitted, the Defense Contract Audit Agency (DCAA) or your agency’s contracting officer begins the evaluation process. Their goal is to determine whether your proposed indirect rates are reasonable, well-supported, and compliant with FAR 42.704.
Here’s what they’ll typically review:
- Prior year indirect cost rates and incurred cost submissions
- Historical audit data
- Projected cost trends and supporting documentation
- The logic behind your indirect rate calculations
If the proposed rate appears reasonable and complete, DCAA may approve it as submitted. If they find gaps or inconsistencies, they may request clarification or recommend adjustments.
In some cases, especially for lower-dollar-value contracts, DCAA or the contracting officer may simply establish the rate themselves using available historical data. If a formal billing rate proposal isn’t required, they’ll still base their decision on documented costs, removing unallowable or one-time expenses.
Why the Review Process Matters
A smooth review process can lead to:
- Faster invoice approvals
- Reduced audit risk
- Stronger cash flow predictability
But if your submission is vague, inconsistent, or unsupported, you risk:
- Billing delays
- Audit flags
- Retroactive rate adjustments
You might think you’re billing correctly, only to find out months later that your indirect rate has been lowered forcing you to repay the difference.
Proactive GovCons don’t just submit they engage. Schedule early conversations with your auditor, confirm what documentation is needed, and respond quickly to any questions. This shows good faith, builds trust, and can lead to more favorable outcomes.
Compliance Tip: Keep Documentation Tight
FAR 42.704 and DCAA guidance emphasize documentation. Your proposal should clearly show how each rate was calculated, what base you used, and why your projections are reasonable.
Don’t wait for DCAA to come back with questions. Pre-emptively answering them in your submission sets the tone for a smoother review.
What’s Next in the Series?
Stay tuned for the next part in our GOV CON Wednesdays series:
✅Part 1: Intro to PBR
✅Part 2: Do I Need a PBR? And How Do I Get One Approved?
✅Part 3: What Goes Into a PBR? Breaking Down the Numbers
✅Part 4: How Do I Calculate My Provisional Billing Rate?
✅Part 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
You did the hard work of preparing your PBR. Let VSINGH CPA help you get it across the finish line.
Our team will walk you through the DCAA review process, respond to clarification requests, and ensure your rate gets approved as fast as possible. Connect with us to get your PBR finalized with confidence.
👉 Check out our YouTube Shorts: https://youtube.com/shorts/3VTbRWhg-Oo?si=PkjVMfPy8Yas7CSF