Incurred Cost Submissions, CAS, and WAWF
Lightbridge ERP defines the incurred cost submission as a government contractor's annual reconciliation of claimed costs against actual costs on flexibly-priced contracts, filed using the DCAA Incurred Cost Electronically (ICE) model. This guide also explains Cost Accounting Standards applicability and how contractors invoice the government through Wide Area Workflow in PIEE.
The incurred cost submission reconciles a contractor's claimed costs to actual costs each year.
On flexibly-priced government contracts, cost-reimbursable and time-and-materials work, a contractor bills throughout the year using provisional indirect rates. The incurred cost submission, sometimes called the incurred cost proposal, is the annual true-up. It is required by the Allowable Cost and Payment clause at FAR 52.216-7 and is generally due within 6 months after the contractor's fiscal year-end. The submission computes final indirect rates from actual costs and becomes the basis for settling the difference against what was billed.
Filing late or filing an inadequate submission carries real consequences, from returned packages to unilateral rate decrements imposed by the contracting officer. Specific deadlines, extension rules, and penalty mechanisms are set in the contract and the FAR, so verify them against the current text at acquisition.gov before acting on a general summary. A DCAA-compliant accounting foundation, covered in the DCAA-compliant accounting guide, is what makes the submission tie out.
The DCAA ICE model is the standard workbook for preparing the incurred cost submission.
ICE stands for Incurred Cost Electronically. The Defense Contract Audit Agency publishes the model as a set of interconnected schedules with built-in checks that flag where the numbers do not reconcile. Following it is the most reliable path through DCAA's adequacy review. These are the moving parts.
Schedules H, A, and B: claimed and actual cost
The ICE model walks a contractor through a connected set of schedules. Schedules A and B build the indirect rate pools and bases, Schedule H allocates costs to each flexibly-priced contract, and the supporting schedules tie back to the audited financial statements. The model is workbook-based, with internal cross-checks that flag where the schedules do not reconcile.
Direct and indirect cost reconciliation
The submission proves that costs billed during the year reconcile to costs actually incurred and recorded in the accounting system. Fringe, overhead, and general and administrative pools are computed at actual, then compared to the provisional billing rates used during the year, so over-billing and under-billing surface for settlement.
Adequacy and the audit that follows
DCAA first checks the submission for adequacy against a published checklist, then may select it for audit. An adequate, internally consistent submission, filed on time, is the contractor's strongest protection. Inadequate submissions are returned, and persistent late or missing filings can lead to unilateral rate decrements by the contracting officer.
The ICE schedules only tie out when the underlying accounting system segregates direct and indirect costs by contract. The mechanics of that structure are covered in the GovCon project accounting guide.
Cost Accounting Standards applicability turns on award size, history, and business type.
The Cost Accounting Standards (CAS), codified at 48 CFR 9904, are uniform rules for how contractors measure, assign, and allocate costs to government contracts. Whether they apply, and at what level, depends on a contractor's award values, prior CAS-covered award history, and business size. Coverage comes in two tiers, with several exemptions. The dollar triggers below are set by regulation and adjusted over time, so treat any specific figure as something to confirm at acquisition.gov.
Full CAS coverage
Full coverage applies to contractors above the statutory triggers and requires compliance with all of the Cost Accounting Standards at 48 CFR 9904, plus a disclosure statement describing the contractor's cost accounting practices. The award-size and prior-award triggers are set by regulation and change over time, so confirm current values before relying on them.
Modified CAS coverage
Modified coverage applies a defined subset of the standards rather than the full set. It generally attaches once a contractor crosses the CAS threshold but stays below the full-coverage trigger. The exact standards in the modified subset are specified in 48 CFR 9903, which is the controlling text.
CAS exemptions
Several categories of awards are exempt, including contracts and subcontracts with small businesses, awards based on adequate price competition without submission of certified cost or pricing data, commercial item acquisitions, and awards below the threshold. Exemption categories are listed in 48 CFR 9903.201-1 and should be checked award by award.
Several dollar figures interact here, and they are easy to conflate. A lower award-level threshold near the truth-in-negotiations level (historically around 2 million dollars) governs whether an individual award is exempt from CAS at all. A separate, higher single-award figure triggers coverage and, beyond it, the move from modified to full coverage, with a large net-awards figure (historically referenced around 50 million dollars) associated with full coverage. All of these are adjusted periodically and are easy to state out of date, so treat every figure as illustrative only: the controlling values live in 48 CFR 9903.201 and must be verified there.
Wide Area Workflow is how contractors invoice the Department of Defense, now inside PIEE.
Wide Area Workflow (WAWF) is the electronic system for submitting invoices and receiving documents to the Department of Defense. It was renamed iRAPT and now runs as a module within the Procurement Integrated Enterprise Environment (PIEE). Getting paid cleanly is mostly a matter of choosing the right document type and encoding accurate routing data. These are the core mechanics.
WAWF is now a module in PIEE
Wide Area Workflow was renamed Invoicing, Receipt, Acceptance, and Property Transfer (iRAPT) and now operates as a module inside the Procurement Integrated Enterprise Environment (PIEE). Contractors register in PIEE, then use the WAWF / iRAPT module to submit invoices and receiving documents to the Department of Defense.
Invoice and receiving report types
WAWF supports document types matched to the contract, including the Cost Voucher for cost-reimbursable work, the Invoice and Invoice 2-in-1 for services, and the Combo for goods that pair an invoice with a receiving report. Selecting the wrong document type is a common rejection cause, so the contract terms drive the choice.
Routing, acceptance, and payment
Once submitted, a document routes electronically to the inspector, acceptor, and pay office encoded in the contract. Acceptance in WAWF is what releases an invoice toward payment, typically through the Defense Finance and Accounting Service. Clean routing data and accurate contract line items are what keep payment from stalling.
Document types, routing roles, and registration steps in PIEE change as the platform evolves. Confirm current requirements through the official PIEE portal at piee.eb.mil before configuring an invoicing process.
Incurred cost, CAS, and WAWF are three linked obligations on the same flexibly-priced work.
These requirements are not independent. CAS governs how costs are measured and allocated, which determines the shape of the indirect rate structure. WAWF in PIEE is how a contractor invoices the government through the year at provisional billing rates. The incurred cost submission then reconciles a full year of those billings to actual costs and sets final rates, which can drive an adjusting invoice or credit back through WAWF. A single accounting system that handles all three without manual re-keying is the practical goal.
That is an ERP design problem. The system has to segregate direct and indirect costs, compute pools and bases, support provisional and final rate logic, and feed compliant invoices. The DCAA-compliant accounting guide covers the control environment, and the GovCon project accounting guide covers how the cost structure is modeled in the system itself.
Lightbridge ERP prepares government contractors for incurred cost, CAS, and WAWF obligations.
Lightbridge ERP is an independent, vendor-neutral ERP advisory firm. For government contractors, that means designing indirect rate structures, configuring the ERP system to produce ICE-ready schedules, supporting CAS applicability analysis, and establishing the controls behind clean WAWF invoicing. The framing is deliberate: this is readiness and advisory work. Lightbridge prepares organizations to meet these obligations and stays accountable for program outcomes, rather than asserting any certification status of its own.
Vendor neutrality keeps the advice honest. Lightbridge accepts no vendor kickbacks, no reseller quotas, and no partner-tier incentives, so a platform recommendation is driven by fit rather than commission. Whether the right system is built on a specialized GovCon platform or a broader ERP suite, the selection runs against weighted requirements first. For organizations weighing the path, the government contracting practice is the place to start.
This guide is general guidance, not legal, audit, or accounting advice. Regulatory thresholds, deadlines, and system requirements change, so verify current rules against the official sources, including acquisition.gov for the FAR and DFARS, the DCAA site for the ICE model, 48 CFR 9903 and 9904 for CAS, and the PIEE portal for WAWF. Product names such as Deltek, Costpoint, and Unanet, and cloud platforms such as AWS, Microsoft Azure, and AWS GovCloud, are trademarks of their respective owners; Lightbridge ERP is independent and is not affiliated with, endorsed by, or a partner-tier reseller of any of them.
Incurred cost, CAS, and WAWF: frequently asked questions
- What is an incurred cost submission?
- An incurred cost submission, sometimes called an incurred cost proposal, is a government contractor's annual report reconciling the costs it claimed during a fiscal year against the costs it actually incurred on flexibly-priced contracts, such as cost-reimbursable and time-and-materials work. It is required under the Allowable Cost and Payment clause at FAR 52.216-7 and is typically prepared using the DCAA Incurred Cost Electronically (ICE) model, a workbook of interconnected schedules. The submission sets final indirect rates for the year and is the basis for settling over-billing or under-billing against the provisional rates used during the period.
- When is the incurred cost submission due?
- Under FAR 52.216-7, the incurred cost submission is generally due within 6 months after the end of the contractor's fiscal year. A contractor with a December fiscal year-end would ordinarily file by the end of June. Extensions can be requested from the cognizant contracting officer, and specific contract terms can vary, so verify the deadline against your contract and the current FAR text at acquisition.gov rather than relying on a general rule alone.
- What is the DCAA ICE model?
- ICE stands for Incurred Cost Electronically. It is the standardized workbook that the Defense Contract Audit Agency (DCAA) publishes for preparing the incurred cost submission. The model strings together schedules for indirect rate pools and bases, contract-level cost allocation, executive compensation, and reconciliation to the financial statements, with built-in checks that flag where the numbers do not tie out. Using the ICE model is not strictly mandatory, but a submission that follows it is far more likely to pass DCAA's adequacy review. Confirm the current model version on the official DCAA site before filing.
- What are the Cost Accounting Standards and when do they apply?
- The Cost Accounting Standards (CAS), codified at 48 CFR 9904, are uniform rules governing how contractors measure, assign, and allocate costs to government contracts. Applicability turns on award size, the contractor's history of CAS-covered awards, and the business size. Coverage comes in two tiers: full coverage requires all the standards plus a disclosure statement, while modified coverage applies a defined subset. Several exemptions exist, including small business, adequate price competition, and commercial items. The dollar triggers and exemption categories are set in 48 CFR 9903 and change over time, so check current values at acquisition.gov.
- What is the difference between full and modified CAS coverage?
- Full CAS coverage requires compliance with every standard in 48 CFR 9904 and the filing of a disclosure statement that documents the contractor's cost accounting practices in detail. Modified coverage requires only a specified subset of the standards and generally no disclosure statement, applying to contractors who have crossed the CAS threshold but remain below the full-coverage trigger. Which tier applies depends on award values and prior CAS-covered award history under thresholds defined in 48 CFR 9903. Because those thresholds are periodically adjusted, treat any specific dollar figure as something to verify against the current regulation.
- What is WAWF and how does it relate to PIEE?
- Wide Area Workflow (WAWF) is the Department of Defense electronic system contractors use to submit invoices and receiving reports for payment. It was renamed Invoicing, Receipt, Acceptance, and Property Transfer (iRAPT) and now runs as a module inside the Procurement Integrated Enterprise Environment (PIEE). In practice, contractors register in PIEE and then use the WAWF / iRAPT module to create the right document type, route it to the inspector, acceptor, and pay office named in the contract, and move it toward payment through the Defense Finance and Accounting Service.
- How do incurred cost submissions, CAS, and WAWF fit together?
- They are three linked obligations on the same flexibly-priced work. CAS governs how costs are measured and allocated, which shapes the indirect rate structure. WAWF in PIEE is how the contractor invoices the government during the year using provisional billing rates. The incurred cost submission then reconciles a full year of those billings to actual costs and sets final rates, which can trigger an adjustment in WAWF for the difference. A DCAA-compliant accounting system is the foundation that makes all three work. See the guides on DCAA-compliant accounting and GovCon project accounting below.
- How does Lightbridge ERP help with incurred cost, CAS, and WAWF readiness?
- Lightbridge ERP is an independent, vendor-neutral ERP advisory firm. It helps government contractors design indirect rate structures, configure their ERP system to produce ICE-ready schedules, and establish the controls that support CAS applicability analysis and clean WAWF invoicing. The work is readiness and advisory: Lightbridge prepares organizations to meet these obligations and stands accountable for program outcomes, rather than asserting any certification or vendor partner status. Recommendations are driven by fit, because Lightbridge accepts no vendor kickbacks, reseller quotas, or partner-tier incentives.
From compliance obligation to a system that handles it.
When incurred cost, CAS, and WAWF become an ERP design problem, Lightbridge ERP runs a vendor-neutral assessment and prepares the system to meet the obligations.