Time to Crack the Code: Preparing an Incurred Cost Submission

Time to Crack the Code: Preparing an Incurred Cost Submission

Donna Dominguez & Aisha Mian | March 3, 2016

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Agenda

• Filing Requirements for an Incurred Cost Submission

• Ramifications of Non-Compliance

• Statute of Limitations

• DCAA Adequacy & Risk Assessment

• DCAA Updates to the Submission

• Incurred Cost Audit Top 5 Tips

• Example of Schedule H & I

• Q&A Session







Filing Requirements for an Incurred Cost Submission







The Four W’s for an ICS

• WHAT: When a contract contains the following FAR Clause 52.216-7, Allowable Cost and Payment, normally found in solicitations/contracts that are cost-reimbursement (flexibly priced) or a time-and-materials contract (other than a contract for commercial items).



https://www.acquisition.gov/far/html/52_216.html






• WHEN: Per FAR 52.216-7(d)(1)(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 Administrative Contracting Officer








• WHERE: To your cognizant DCMA and DCAA Representative

• WHY: Balancing your Checkbook – To settle up on the amount the Government owes you or the amount you owe the Government







Quick Summary Reference on Incurred Cost Submission

• It begins with a contract FAR Clause 52.216-7, Allowable Cost & Payment – Can be found in Prime and Subcontracts– Applicable to Cost Type (flexibly priced) and T&Ms

• A submission to “True-up” Provisional Rates to Actual Rates

• Prepared Annually – Due 6 months after company year-end







Background on Incurred Cost Submissions







Background on Incurred Cost Submission

Commonly asked questions• What if I have a T&M contract (prime or subcontract) with

no “M”s?

• What if I have a T&M prime or subcontract and did not apply G&A on the pass through?

Skilled contract personnel are hard to find!







Who Does NOT Need to File an ICS

• Fixed Price Contracts• Labor Hour Contracts• Commercial Contracts

– GSA Contract & Task Orders• Contracts closed out under the quick close out procedure.

When conditions under FAR 42.708(a) are satisfied Contracting Officer can settle indirect costs in advance of final indirect cost rate.







Ramifications of Non-Compliance








• The DCAA released an MRD(Memorandum for Regional Directors) on the Treatment of Delinquent Incurred Cost Submissions

– The DCAA will only provide a single late notification letter when an Incurred Cost Submission is 30 days late

– The DCAA will provide the DCMA with a list of contractors that have Incurred Cost Submissions that are either 6 months overdue without valid extension, or considered inadequate for audit








Associated Risk for non-compliance:

• Administrative Contracting Officer (ACO) can unilaterally decrement your rates up to 16.2% if submissions are not on time! (FAR 42.703-2(c)(2))

• Rates established unilaterally will be:̶� Based on audited historical data or other available data as long

as unallowable costs are excluded; and ̶� Set low enough to ensure that unallowable costs will not be

reimbursed.

Be timely with your submissions!








Failure to provide an Incurred Cost Submission can also compromise the status of your accounting system.

Failed accounting system affects your ability to win new/follow-on work







Unallowables and PenaltiesUnallowable Cost• DCAA’s guidance on Identifying Expressly Unallowable Costs!! Penalties• Penalties for claiming unallowable costs FAR 42.709-1. • If the indirect cost is expressly unallowable under a cost principle in the FAR, the

penalty is equal to— – Deemed Unallowable during Audit

• The amount of the disallowed costs allocated to contracts that are subject to this section; plus

• Interest on the paid portion, if any. – Deemed Unallowable prior to ICS

• Two times the amount of the disallowed costs allocated to contracts that are subject to this section; plus

• Interest on the paid portion, if any.

These penalties are in addition to other administrative, civil, and criminal penalties provided by law.







Statute of Limitations








• In October, 1994, the Federal Acquisition Streamlining Act (FASA) established a six (6) year Statute of Limitations for claims under the Contract Disputes Act (CDA).

• FAR Clause 33.206 Initiation of a claim• (b) The contracting officer shall issue a written decision on any

Government claim initiated against a contractor within 6 years after accrual of the claim, unless the contracting parties agreed to a shorter time period. The 6-year period shall not apply to contracts awarded prior to October 1, 1995, or to a Government claim based on a contractor claim involving fraud.








• “Accrual of a claim” means the date when all events, that fix the alleged liability of either the Government or the contractor and permit assertion of the claim, were known or should have been known. For liability to be fixed, some injury must have occurred. However, monetary damages need not have been incurred.

• Historically this was thought by the Government to start tolling on the date the audit was complete. However, based on 2 recent court decisions (Boeing and Raytheon) it is in fact per the date of submission (were known or should have been known).








This means there are 3 areas contractors need to be aware of:

1. This is encouraging DCAA to deem contractors ICS as inadequate and have them recertify.

2. Contractors should not recertify unless the revisions change the indirect rates proposed. This will restart the clock.

3. Contracting Officers not likely to negotiate with contractors when the clock is running out. It’s accept the terms or else I’ll unilaterally determine the rates.







DCAA Adequacy & Risk Assessment







DCAA’s Low Risk Sampling

• All incurred cost proposals will be evaluated upon receipt for adequacy in accordance with FAR 52.216-7 – Incurred Cost Adequacy Checklist

• All adequate incurred cost proposals exceeding $250 million in auditable dollar value (ADV) will be audited.

• Are there audit leads or other significant risks identified (e.g. any known business system deficiencies that would have a significant impact on the final indirect rate proposal for this FY, significant risk identified by the contracting officer, etc.)?

• Is this a new “incurred costs” contractor? (i.e., a contractor where we have no incurred cost audit experience).

• Were there significant questioned costs in the prior year’s audit

• With a “YES” response to ANY of these questions = the High-Risk pool







DCAA’s Risk Assessment

Low-Risk Adequate Proposals by ADV

Low-Risk Sampling

PercentagesLess Than $1Million 0%

$1Million to $50 Million 5%$50 Million to $100 Million 10%

$100 Million to $250 Million* 20%Greater than $250 Million 100%

Auditable Dollar

Value (ADV) Policies and Procedures Changes

<$1MQuestioned cost is > 10% of the last completed incurred cost audit’s ADV

$1M-$5M

Questioned cost is > 5% of the last completed incurred cost audit’s ADV or $100K, whichever is greater

$5M-$250MQuestioned cost is >$250K in the last completed incurred cost audit







DCAA’s Audit Selection

• All high-risk adequate incurred cost proposals will be audited (oldest to newest).

• Low-risk adequate incurred cost proposals will be sampled for audit using risk criteria.

• Low-risk adequate incurred cost proposals not selected for audit will be dispositioned with a memorandum to the contracting officer.

• DCAA new Incurred Cost Audit program – Post Year End Incurred Cost Audit (January 2015) (audit program #10100).







DCAA’s Paid Voucher Review

DCAA’s proactive response to assist with incurred cost submissions and review in real time. Aid in being deemed low risk and receive letter of memorandum

Paid voucher review (AP11015)• Purpose is to perform limited current period tests on selected paid

vouchers.• This is different than interim voucher review• This review is designed to test the contractor’s compliance with the

contract terms. DCAA will also use the results of the testing to support the incurred cost audit for the period.

• This includes all contractors even those not using WAWF







DCAA Updates to the Submission







DCAA ICE Model UPDATES

DCAA ICS Model Version 2.0.1e (DEC/2015)• Modifications to Schedule J – Subcontractor Information- to

require additional information be entered– Prime Contract Value– Subcontractor’s DUNS No.

DCAA ICS Model Version 2.0.1d (AUG/2015)• Modifications made to columns on Supplemental C – Where

Contractors performs as Subcontractor – to clarify what information is to be entered.– Updated headers to provide Prime’s information where the

contractor is a sub







Data Gathering Checklist

• Trial Balance (in excel format)• Payroll Reconciliation

– Year-end payroll summary report– W-2 Summary– 941 Quarterly Tax Returns

• Statement of Indirect Expenses OR Final FY Indirect Rate Calculation

• Job/Project Summary Reports (at billing level)– Flexibly priced government contracts– Government T&M (normally GSA N/A)

• General Ledger Detail• A/R History • Contract Revenue by contract type








• Year-end or last invoices (if contract ended prior to fiscal year) with cumulative for all flexibly priced and T&M government contracts with the applicable FAR 52.216-7 clause.

• List of contract limitations for all contracts subject to ICS.• List of total hours booked by labor category for each

applicable Federal Government T&M contract (usually GSA task orders N/A).

• Contract Briefs all for all contracts subject to ICS.








• Note if each project listed on the ICS is DoD or Non-DoD and if Prime or Subcontract.

• Note if each project listed on the ICS has physically ended as of the year. (Yes/No)

• Note if subject to the penalty clause FAR 52.242-3. • Subcontractor & Consultant information (for those that worked

on any contracts subject to ICS)• Review General Ledger to ensure all unallowable costs have

not been claimed.







Supplemental Information

• Comparative analysis of indirect expense detailed by account (Supplemental As)

• General Organization and Executive Compensation information (Supplemental B)

• Identification of Prime contracts which Contractor perform as a Subcontractor (Supplemental C)

• Contract Briefs (Supplemental O)








• Certified Financial Statements• Management Letter from CPA concerning any internal control

weaknesses• Actions that have been and/or will be implemented to

correct the weakness described in management letter

• List of all Internal Audit Reports Issues since the last disclosure of the Internal Audit Reports

• Annual Internal Audit plan of scheduled audit to be performed in the fiscal year when final indirect cost rate submission is made








• Federal and State Tax Returns• Securities & Exchange Commission 10K report• Minutes from Board of Directors meetings• Listing of delay claims and termination claims• Description of accounting system• Procedures for identifying and handling unallowable costs • List of work sites and the number of employees assigned

to each site








Written Policies – At time of Audit• Segregation of Unallowables• Bonus Policy• Labor & Timekeeping• Subcontractor/Vendor procurement and payments• Travel Policy• Billing Policy

– Handling of withholds– Contract Limitations– Labor Category & Qualifications







Tips for Surviving an ICS Audit







TIP #1

Adequate Incurred Cost Submission• Proof Trial Balance to Submission• Verify that all unallowables have been removed• Go to each Tab and validate information ties to related schedules• Verify formulas and hyperlinks throughout• Make sure to sign AND date Schedule N• Save all data used to develop ICS• Pull DCAA’s checklist and verify before submission







TIP #2

Compiled Data for AuditStephen Covey’s, The 7 Habits of Highly Effective People

“Begin with the End in Mind”

• Have support data available, accessible and with copy of submission.– The audit of the incurred cost submission will likely occur at a later

date (often much later).– The individual who prepared the submission or support data may

not be accessible or even working for your organization– Appoint a point of contact who will manage the audit, review all data

provided and follow up on all requests.







TIP #3

Common Pitfalls to Avoid• Lack of adequate documentation to support cost• Lack of description of work provided by subcontractors &

consultants• Reclassification of time without proper description &

approval• Out of period costs claimed• Forgetting to put certain Unallowables in the base of G&A• Forgetting to account for Indirect Rate Ceilings







TIP #4

Common Questioned Costs• Business Meetings• Employee Moral• Executive Compensation• Bonuses• Credit Card Expenses (Travel & Per Diem)• Marketing Costs• Leased Autos• Legal Fees• Management Fees







TIP #5

Common Mistakes Found on ICS Schedules• Schedule H • Schedule I







Schedule H

SFX 39 SFX 42 SFX 43 SFX 48 & 50 SFX 56 SFX 55 SFX 57

Internal No. Contract No. Direct Labor -

Home Direct Labor -

Client Travel

Other Direct Costs & Non-

Billable Consultants Subcontracts Materials Total Direct

Costs US Gov't CPFF ContractsAs a Prime

1000-001 ABC1 60,133.00 174,294.00 46,745.00 44,293.00 161,756.00 5,445.00 492,666.00 2000-001 ABC2 322,153.15 2,334,575.18 85,834.00 15,768.00 158,468.48 231,867.86 10,139.00 3,158,805.67 3000-001 ABC3 15,351.15 531,858.55 9,378.26 9,543.50 566,131.46 4000-001 ABC4 12,085.58 1,563,186.00 53,430.00 153,733.00 163,448.11 247,992.74 2,193,875.43 6000-001 ABC6 78,180.00 1,022,674.00 34,518.00 46,896.89 15,643.00 1,197,911.89 7000-001 ABC7 51,531.48 1,518,641.45 86,545.00 15,353.00 164,893.54 1,836,964.47

As a Subcontractor5000-001 ABC5 150,847.80 2,568.88 153,416.68

- Subtotal US Gov't CPFF 690,282.16$ 7,145,229.18$ 316,450.26$ 288,156.27$ 483,672.59$ 660,397.14$ 15,584.00$ 9,599,771.60$

US Gov't T&M ContractsAs a Prime

T006-001 TMK5 27,097.20 84,435.00 4,838.00 68,744.48 185,114.68 As a Subcontractor

T002-001 TMK1 28,776.25 45,354.49 1,845.25 75,975.99 T003-001 TMK2 47,726.86 15,687.00 1,567.00 64,980.86 T004-001 TMK3 10,548.17 23,548.00 3,584.85 250.75 37,931.77 T005-001 TMK4 73,317.00 18,634.25 91,951.25

- Subtotal US Gov't T&M 187,465.48$ 187,658.74$ 8,422.85$ 3,663.00$ -$ 68,744.48$ -$ 455,954.55$

Total Commercial T&M, GSA & FFP $ 356,396.61 $ 76,434.85 $ 1,124,992.54 $ 19,739.78 $ 144,548.41 $ 16,930.84 1,739,043.03$

877,747.64$ 7,689,284.53$ 401,307.96$ 1,416,811.81$ 503,412.37$ 873,690.03$ 32,514.84$ 11,794,769.18$

Total B&P/IR&D $ 115,730.18 $ - $ - $ 35,348.49 $ - $ - $ - 151,078.67$

993,477.82$ 7,689,284.53$ 401,307.96$ 1,452,160.30$ 503,412.37$ 873,690.03$ 32,514.84$ 11,945,847.85$

TOTAL CONTRACT COSTS

TOTAL ALL COSTS

ARONSON LLC.Schedule H- Direct Cost by Contract/Subcontract, IR&D/B&P Direct Incurred, and Indirect Expense Applied at Claimed Rates (USE

SUMMARY SCHEDULE H to summarize direct costs used in bases to compute rates)FOR THE YEAR ENDED 12/31/14







\Schedule H

30.67% 85.09% 30.67% 14.63% 3.15% 10.67%

Fringe Home OH Fringe Client-Site OH Direct Costs &

Overhead SM&H G&A Total Costs

Less: SM&H Over Ceiling

Amount

Less: G&A Over Ceiling

Amount Total Claimed

Costs

18,442.79 66,860.14 53,455.97 33,319.82 664,744.72 5,266.83 53,649.89 723,661.44 (250.80) (12,085.15) 711,325.49 98,804.37 358,192.75 716,014.21 446,301.23 4,778,118.23 12,614.97 468,440.51 5,259,173.72 5,259,173.72 4,708.20 17,068.50 163,121.02 101,675.51 852,704.68 - 90,983.59 943,688.27 943,688.27 3,706.65 13,437.61 479,429.15 298,834.60 2,989,283.43 12,960.39 276,438.68 3,278,682.49 3,278,682.49

23,977.81 86,926.08 313,654.12 195,504.80 1,817,974.69 492.75 192,361.37 2,010,828.82 2,010,828.82 15,804.70 57,296.36 465,767.33 290,319.00 2,666,151.87 5,194.15 267,438.48 2,938,784.50 2,938,784.50

46,265.02 167,723.30 - - 367,405.00 - 39,202.11 406,607.11 406,607.11 - - - - - - - - -

211,709.54$ 767,504.74$ 2,191,441.79$ 1,365,954.96$ 14,136,382.63$ 36,529.09$ 1,388,514.63$ 15,561,426.35$ (250.80)$ (12,085.15)$ 15,549,090.40$

8,310.71 30,128.59 25,896.21 16,141.46 265,591.65 2,165.45 21,234.65 288,991.75 288,991.75

8,825.68 31,995.48 13,910.22 8,670.43 139,377.79 - 14,871.61 154,249.40 154,249.40 14,637.83 53,066.11 4,811.20 2,998.89 140,494.89 - 14,990.80 155,485.70 155,485.70 3,235.12 11,728.20 7,222.17 4,501.68 64,618.95 - 6,894.84 71,513.79 71,513.79

22,459.48 81,519.41 5,715.12 3,562.31 205,207.58 - 21,895.65 227,103.23 227,103.23 - - - - - -

57,468.82$ 208,437.80$ 57,554.94$ 35,874.76$ 815,290.87$ 2,165.45$ 79,887.55$ 897,343.87$ -$ -$ 897,343.87$

-$ -$ 109,306.84$ 68,132.41$ 1,916,482.29$ 5,708.40$ 185,761.68$ 2,107,952.36$ 2,107,952.36$

269,178.36$ 975,942.53$ 2,358,303.57$ 1,469,962.14$ 16,868,155.78$ 44,402.94$ 1,654,163.86$ 18,566,722.58$ (250.80)$ (12,085.15)$ 18,554,386.63$

35,490.91$ 128,677.08$ -$ -$ 315,246.66$ -$ 315,246.66$ 315,246.66$

304,669.27$ 1,104,619.62$ 2,358,303.57$ 1,469,962.14$ 17,183,402.44$ 44,402.94$ 1,654,163.86$ 18,881,969.24$ (250.80)$ (12,085.15)$ 18,869,633.29$ [Schedule E] [Schedule C] [Schedule E] [Schedule C-1] [Schedule B-1] [Schedule B]

ARONSON LLC.Schedule H- Direct Cost by Contract/Subcontract, IR&D/B&P Direct Incurred, and Indirect Expense Applied at Claimed Rates (USE

SUMMARY SCHEDULE H to summarize direct costs used in bases to compute rates)FOR THE YEAR ENDED 12/31/14







Schedule I

PV No.

Date Cost Billed

Through AmountOver (Under)

Billing Note(s)

Physically Complete

Y/N Contract Value Remaining

Funding

1000 06/15/13 13,475,000.00$ (14,271.36)$ YES 14,000,000.00 525,000.00 1001 09/15/13 43,000.00 (2,925.24) YES 75,000.00 32,000.00 1002 10/15/13 1,700,000.00 50,000.00 YES 1,650,000.00 Over Funding Limit(50,000.00) 1003 10/15/13 550,000.00 (9,117.51) YES 600,000.00 50,000.00 1009 12/31/13 213,000.00 (348.60) YES 263,000.00 50,000.00 1010 12/31/13 4,100,000.00 (6,908.18) NO 4,150,000.00 50,000.00 1014 12/31/13 9,430,000.00 (18,113.39) NO 9,480,000.00 50,000.00 1018 12/31/13 155,428.01 1,571.18 NO 205,428.01 50,000.00 1021 12/31/13 126,000.00 (728.54) NO 176,000.00 50,000.00 1022 12/31/13 391,000.00 (503.26) NO 441,000.00 50,000.00 1023 12/31/13 3,860,000.00 (4,715.76) NO 3,910,000.00 50,000.00 1027 12/31/13 3,210,000.00 (8,395.03) NO 3,260,000.00 50,000.00

- 37,253,428.01$ (14,455.68)$

-

2000 09/15/13 3,775,044.26$ 600.00$ YES 3,825,044.26 50,000.00 2001 12/31/13 2,202,222.00 600.00 NO 2,252,222.00 50,000.00 2003 12/31/13 4,088,698.78 600.00 NO 4,138,698.78 50,000.00 2004 12/31/13 586,570.67 600.00 NO 636,570.67 50,000.00 2008 12/31/13 808,559.60 600.00 NO 858,559.60 50,000.00 2009 12/31/13 1,165,702.10 - NO 1,215,702.10 50,000.00

- 50,000.00 50,000.00 -

12,626,797.42$ 3,000.00$

49,880,225.43$ (11,455.68)$

WORKSHOP EXAMPLESchedule I - Schedule of Cumulative Direct and Indirect

For The Year Ended 12/31/13

CUMULATIVE BILLED







DCAA Resources & Audit Programs

Go to DCAA web site http://www.dcaa.mil/ Under Guidance

• Contract Audit Manual (CAM) – Chapter 6 Incurred Cost Audit Procedures• FAR Cost Principles Guide

Directory of Audit Programs• Risk Assessment Checklist• Audit Program for Incurred Costs - Post Year End Incurred Cost Audit – AP 10100

(Feb 2016) Audit Process Overview

• Information for Contractors Under Checklist and Tools

• Incurred Cost Electronically (ICE) (customize to contractor indirect rate structure)• Incurred Cost Adequacy Checklist



http://www.dcaa.mil/





About Aronson LLC

Aronson LLC provides a comprehensive platform of assurance, tax, and consulting solutions to today’s most active industry sectors and successful individuals. For more than 50 years, we have purposefully expanded our service offerings and deepened our industry specialties to better serve the needs of our clients, people, and community. From startup to exit, we help our clients maximize opportunity, minimize risk, and unlock their full potential.







About Aronson LLC

• Thinking ahead for clients for more than 50 years• 225+ professionals located in Rockville, MD• 80+ professionals dedicated to supporting government contractors • Aronson helps clients rethink the way they approach their business

through innovative, industry-specific services and advice:– Audit, Assurance and Tax– Deltek Systems and Outsourcing– Financial and Contract Compliance– GSA Schedules

• www.aronsonllc.com/blogs/fedpoint/ – News and trends and insight for today’s savvy government contractor



http://www.aronsonllc.com/blogs/fedpoint/





Awards / Accolades / Affiliations

The Gazette of Politics & Business Exceptional 53 Business Award In 2012, Aronson received the PB53 award for the third year in a row. The program acknowledges the top businesses and organizations in Maryland based on criteria that includes the company’s annual revenue, employee growth, noteworthy product or service innovations, community service efforts and more.

Accounting Today Top Firm In 2013, Aronson was once again named to Accounting Today’s list of the top 100 firms in the country. Accounting Today is a leading provider of online business news for the tax and accounting community.

Washington Business Journal Top 25 Aronson is ranked #12 on the Washington Business Journal’s Top 25 Accounting Firms in the DC Metropolitan area.

INSIDE Public Accounting Top 100 Once again, Aronson has earned a spot in the top 100 of this prestigious list, released by INSIDE Public Accounting. This is the longest running, most comprehensive and accurate independent analysis focusing on management and operations of America’s large local, regional and national firms.

Washington Business Journal Best Places to Work Aronson has been recognized five times as one of the Metro area’s “Best Places to Work.” The award recognizes a company’s achievements in creating a positive work environment that attracts and retains employees through a combination of employee satisfaction, working conditions and company culture.

Montgomery County Chamber Corporate Social Responsibility AwardIn 2010, Aronson was honored to receive the MCCC’s Corporate Social Responsibility Award based on the depth and breadth of the company’s energetic commitment to support young people, in the areas of education, housing and health.







Donna Dominguez is a principal consultant in Aronson LLC’s Government Contract Services Group, where she provides a wide range of financial compliance advisory services for government contractors. She is experienced in matters related to Federal Acquisition Regulations (FAR), cost accounting standards (CAS), incurred cost submissions, DCAA/cognizant audit support, provisional billing rates, establishing/revising indirect rate structures and cost proposal support. Donna works with contractors to help them grow their business while keeping their accounting systems adequate in the eyes of the government and their billing systems current and relevant. She is also involved in supporting the government contracting community as a frequent guest speaker on a variety of compliance topics. Donna earned her bachelor’s degree in accounting from the University Maryland and has completed additional coursework in contracts administration. She is a contributor to Aronson’s Fed Point blog and has co-authored articles for NCMA Contract Management Magazine.

Principal Consultant, Government Contract Services Group

301.222.8232

[email protected]

Donna M. Dominguez







Aisha N. Mian is a managing consultant in Aronson LLC’s Government Contract Services Group. She has more than eight years of experience in the government contracting industry, with expertise in both project control and financial compliance. Her professional skills include contract/project financial analysis and various areas of financial compliance, including preparation of incurred cost submissions; support in evaluating, preparing and advising appropriate indirect rate structures; preparation of disclosure statements; and analysis and impact of cost accounting standards (CAS). She has also worked alongside in-house DCAA auditors supporting audits for incurred cost submissions during her time in the industry. Aisha has been a guest speaker on financial and government contracting topics at the GWSCPA Government Contracting Conference and has hosted Aronson LLC webinars related to government contracting topics. She earned her bachelor’s degree in finance from George Mason University and her MBA from the Robert H. Smith School at the University of Maryland College Park.

Managing Consultant, Government Contract Services Group

240..364.2614

[email protected]

Aisha N. Mian







301.222.8232

Contact Donna Dominguez / Aronson LLC

[email protected]

https://www.linkedin.com/in/donna-dominguez-664b26b








240.364.2614

Contact Aisha Mian / Aronson LLC

[email protected]

https://www.linkedin.com/in/aishamian







Time to Crack the Code: Preparing an Incurred Cost Submission

Government & Nonprofit

Transcript of Time to Crack the Code: Preparing an Incurred Cost Submission