DCAA’s October 6, 2026, memorandum addresses exemptions for nontraditional defense contractors from certain cost, pricing, and business system requirements. DCAA may still provide audit and advisory support, and contractors may still need to provide cost data. Questions remain about implementation and how individual exempt contracts will be reviewed.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Estimating System Compliance
Department of War’s (DoW) October 1, 2026, memorandum provides guidance on cost data requests, reporting, and profit expectations. Questions remain about how the direction will affect pricing negotiations, accounting requirements, and profit sharing. Government contractors should assess these expectations alongside existing contract terms and applicable regulations.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Estimating System Compliance, Commercial Determination
The FAR Council’s proposed revisions to FAR 52.216-7 would change several requirements used to determine whether an incurred cost submission is adequate. The changes would reorganize or remove certain schedules and add requirements for some fixed-price incentive contracts, creating important considerations for submission preparation, audit support, and contract closeout.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
DoW is pursuing significant acquisition reforms that could reshape CAS applicability, pricing, audits, and contractor business system oversight. The planned changes emphasize greater use of GAAP, reduced administrative requirements, and streamlined acquisition practices, with implementation actions scheduled over the next 30 to 120 days and additional regulatory changes potentially required.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Estimating System Compliance, Manufacturing Operations Consulting
The CAS Board has finalized significant changes to CAS thresholds and coverage requirements effective October 1, 2026. The rule raises the basic and full coverage thresholds while introducing new considerations for IDIQ contracts, existing awards, and Disclosure Statement requirements.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Estimating System Compliance
The FY 2026 NDAA raised the Truthful Cost or Pricing Data threshold to $10 million and made TINA Lite permanent for Department of War acquisitions. DCAA’s August 2026 guidance provides additional direction on proposal reviews and data expectations, making it important for government contractors to understand how these changes may affect proposal preparation and negotiations.
Topics: Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), REAs, Claims & Terminations
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On August 18, 2026, DoW issued a memorandum calling for broader access to contractor and subcontractor cost data, greater pricing transparency, and increased scrutiny of profit. The direction could significantly affect pricing practices, negotiations, system access, and compliance expectations across the defense industrial base.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance
DCAA has ended planned compliance audits for CAS 404, 408, 409, and 411 following their removal from CAS effective August 7, 2026. While standalone audits for these standards are being discontinued, government contractors should expect continued scrutiny of compliance with Generally Accepted Accounting Practices (GAAP), accounting practice changes, CAS 401 compliance, and disclosure statements through other DCAA audit activity.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Material Management & Accounting System (MMAS)
Government contracting disagreements can reach an impasse when the parties dispute which requirements apply. Legal counsel may offer another avenue for documenting the contractor’s position and seeking clarification. An OTA termination matter illustrates how a legal show cause notice clarified FAR Part 31 applicability, even though DCAA retained its audit report.
Topics: Litigation Consulting Support, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), REAs, Claims & Terminations
