Redstone Government Consulting Blog | Cheryl Anderson

Many new government contractors are frustrated by being told they have a CAS 401 noncompliance, especially if they are not CAS covered. This is, of course, wrong terminology for non-CAS covered contractors, but is shorthand for saying the company is not estimating, accumulating, and reporting costs the same way. This is most frequently a difference between how a company estimates cost and then how the company accumulates and reports costs. This is not only important to the government, but to the company itself. A contractor cannot determine whether it is losing money on a contract if there is no way to compare what was bid to what was incurred. This is likely one of the first CAS standards a company encounters because even modified coverage calls this standard into play.

Importance of Basis of Estimate

The proposal is often the procurement parties’ first introduction to a company. It is important to remember that different readers are looking for different types of content from the proposal. From an auditor’s viewpoint, an important part of a contractor’s cost estimating process is preparing the basis of estimate (BOE).

If your company no longer qualifies as a small business or is a company that wants to move from commercial contracts to negotiated contracts with the Federal Government, then this Vlog is for you. This Vlog explains how to determine when Cost Accounting Standards (CAS) apply and what are the different levels of coverage. It also discusses how to determine your CAS-covered universe and why it is important. There are three significant dollar amounts when dealing with CAS: $7.5M, $2M and $50M. Watch to find out why these are important numbers in the world of negotiated Government contracts.

In previous blogs, we have recommended preparing a CAS Disclosure Statement (DS) soon after emerging from small business status. We also recommended reviewing your cost accounting practices prior to preparing a Disclosure Statement to prevent having to change afterwards and ending up requiring a cost impact statement. So, by now you are probably wondering what this mythical beast is and what is the big deal about preparing it.

Previously, we discussed how a company ends up with CAS covered contracts.  This month we are going to talk about some of the further fun with CAS.  We recommended preparing a CAS Disclosure Statement soon after emerging from small business status,

With a renewed focus on DCAA Estimating System Audits, Cheryl Anderson shares some advice on successfully navigating the process.

Slowly is the word that always describes Government change, and acquisition process change is no exception.  Some of you will remember that the 2017 NDAA required DCAA to reduce the backlog of DoD incurred cost submissions and suspend work for other Departments.  But how many of you remember that it also created an Advisory Panel on Streamlining and Codifying Acquisition Regulations, better known as the Section 809 Panel? 

Unless you have undergone a DCAA Accounting System audit under the criteria in DFARS 252.242-7006 (a.k.a. DFARS Accounting System Audit), you do not know what a comprehensive audit is.  To start with there are eighteen criteria, some of which are as broad as “Accounting practices in accordance with standard promulgated by the Cost Accounting Standards Board, if applicable, otherwise, Generally Accepted Accounting Principles.”  This leaves the door open to pretty much endless questions.  But don’t worry, DCAA has narrowed it down to only 27 questions. 

There are many presents one may enjoy receiving this holiday season. However, one present you do not want during the holiday season is a CAS Disclosure Statement (DS) surprise.  There are several surprises related to DS’s you can receive:

It seems like there are a lot of agencies being audited on what they are doing with DCAA audit findings. In September, the DoD-IG announced an audit of 26 contracts issued from FY 2014-2017 by Navy, DLA, Army and Air Force contracting officers. It’s stated objective is “to determine whether contracting officer actions during contract negotiations complied with acquisition regulations when contractor proposals were deemed inadequate by the Defense Contract Audit Agency (DCAA).”  At the same time, they announced an audit of DCMA with an audit objective “to determine the appropriateness of contracting officer actions to resolve and disposition compensation costs that the Defense Contract Audit Agency (DCAA) has questioned in audits of DoD contractor incurred cost claims submitted to the Government.