The Cost Accounting Standards (CAS) team supports contracting officers in making CAS related determinations throughout the CAS lifecycle.

Cost Accounting Standards Team

How the CAS Team can assist:

Disclosure Statement Revision Adequacy and Compliance Determinations – assist contracting officer determinations as to whether the revisions to a Disclosure Statement are adequately described and compliant with FAR and CAS requirements
CAS Noncompliance Resolution – evaluating audit findings on alleged CAS noncompliances, evaluating contractor’s responses to the Notice of PotentialNoncompliances, and assisting contracting officers in making a determination of compliance or noncompliance in accordance with FAR and CAS requirements.
Assessment of Cost Accounting Practice (CAP) Changes – to determine whether a revision in a Disclosure Statement meets the definition of a CAP change, thereby invoking cost impact requirements.
Cost Impact Proposal Assistance – ensuring contractor’s cost impact proposals are adequate, calculate the cost impact to preclude increased costs paid by the Government in the aggregate, and assist in any remedies when there are impasses on negotiations.
Disclosure Statement Revision Adequacy and Compliance Determinations – assist contracting officer determinations as to whether the revisions to a Disclosure Statement are adequately described and compliant with FAR and CAS requirements.

Desirability Determinations – evaluating the contractor’s supporting rationale why CAP changes should be deemed desirable.
External Restructuring Support – We assist in navigating the requirements of DFARS 231.205-70, ensuring compliance with regulations surrounding restructuring costs. Our expertise focuses in areas such as the allowability and allocability of ERP costs, as well as supporting the analysis of contractor reported cost savings.
Immateriality Determinations – assist contracting officers in evaluating contractor’s immateriality assertions for either cost impacts or CAS standard interpretations in accordance with FAR and CAS requirements.
CAS Applicability – to determine contractual CAS coverage, type of CAS coverage, and whether Disclosure Statement requirements apply.

Protecting USG's Exposure to Paying Increased Costs Related to CAS

The value proposition of Cost Accounting Standards (CAS) to the Government is the ability to ensure fair and transparent pricing on government contracts by standardizing how contractors measure, allocate, and report costs, leading to consistent comparisons of pricing proposals and improved oversight in managing taxpayer funds.

Contractor’s are required to disclose and consistently follow their Cost Accounting Practices (CAPs) used to estimate, accumulate, and report on their CAS covered contracts. These contractors are afforded the opportunity to unilaterally change those CAPs; however, the Government shall not pay increased costs in the aggregate due to those accounting changes. Additionally, if the contractor violates a CAS standard or fails to follow their disclosed CAPs, and the Government pays increased costs in the aggregate as a result, the Government has the ability to recoup those overpayments plus compound interest.

Most DoD contracting officers have limited experience and exposure to executing CAS administration, either in the reviewing of changes to contractor’s CAS Disclosure Statements, the processing of CAS Noncompliances, or in the review of the associated cost impact proposals. The DCMA CAS Team exists to fill the void of expertise in the area of CAS administration, interpretation of the CAS standards, and execution of related processes.