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ICS Essentials #2: Who Must Submit an ICS? (Contract Types & Exemptions)

January 7, 2026 by Vik Singh

Determining ICS submission requirements for cost-reimbursable vs fixed-price contracts under FAR 52.216-7 and commercial item exemptions.

GovCon Wednesdays Estimated Read Time: 5 minutes Not every contractor is required to file an Incurred Cost Submission but if your contracts include cost-reimbursable elements, the ICS becomes an annual compliance requirement under FAR 52.216-7. Understanding whether your contract requires an ICS is essential for staying compliant and avoiding unilateral rate determinations from your ACO. This article explains exactly who must submit an ICS and which contracts are exempt.   Core Concept:… Read More

Filed Under: ICS Tagged With: Contract Types, Cost-Reimbursable Contracts, DCAA Compliance, FAR 52.216-7, GovCon Accounting, Government Contracting, ICS Exemptions, ICS Requirements, Incurred Cost Submission, T&M Contracts

ICS Essentials #1: What Is an Incurred Cost Submission (ICS)?

December 31, 2025 by Vik Singh

What is an Incurred Cost Submission (ICS)? Reconciling actual costs vs provisional billing rates for FAR 52.216-7 compliance.

GovCon Wednesdays Estimated Read Time: 5 minutes If your business has flexibly priced contracts, cost-reimbursable or certain T&M agreements, you are required to submit an Incurred Cost Submission (ICS) each year under FAR 52.216-7. An ICS ensures that every cost billed to the government is reasonable, allowable, and allocable, and that final contract costs reflect what your business actually incurred during the fiscal year. This first installment of the ICS… Read More

Filed Under: ICS Tagged With: Audit Readiness, Contract Closeout, DCAA Compliance, FAR 52.216-7, GovCon Accounting, Government Contracting, ICS GovCon, ICS Requirements, Incurred Cost Submission, Indirect Rates

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