When you hear DFAS do you think “Defense Finance & Accounting Services” or do you think “Division of Financial Advisory Services?” One is a DOD agency and the other is an NIH agency. Both use the acronym DFAS and both deal with indirect rates.
Government agencies use different terminology and acronyms for indirect rate proposals or submission. For defense contractors you have the Incurred Cost Submission (ICS), for NIH contractors you have Indirect Cost Rates (IDC) submission, and for the Department of Labor you have Indirect Cost Rates (ICR) and Cost Allocation Plans (CAPs).
It is easy to find information about indirect rates that relate to the Department of Defense, but what of the other government agencies? Most government contractors use the ICE Model from the DCAA website to submit their Incurred Cost Proposals. The Office of Acquisition Management and Policy at National Institutes of Health (OAMP) has a different model for the Indirect Cost Submission, but will accept the ICE Model. The Department of Labor has a guide to indirect rates as well as USAID, and EPA.
All indirect rate proposals need to follow the FAR regulations and OMB Circulars. Each agency has its nuances and preferences. NIH has a lower salary cap than DOD. Both NIH and DOL prefer subcontractor and material cost in the G&A base to be capped on $25K, but it is not mandatory.
If you have questions about regulations relating to your indirect rates don’t be afraid to ask your cognizant officer or post it on Aronson’s blog.
Your indirect rate submission should be easy to follow, match your proposals, and mirror your accounting practices. It is best to address any issues during the acceptance of your rate proposal rather than during an audit of your rates.