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.
What many companies don’t understand is that Federal Acquisition Regulation (FAR) 31.201-1(a) requires something similar to CAS 401 (and would be the correct regulation cited for non-CAS covered companies, if found to be in violation of this concept). It says: “The total cost, …of a contract is the sum of the direct and indirect costs allocable to the contract, incurred or to be incurred.” Incurred or to be incurred“ means actual cost or estimated cost. FAR goes on to say that in “ascertaining what constitutes a cost, any generally accepted method of determining or estimating cost that is equitable and is consistently applied may be used.” Note that this sentence addresses determining (accumulating) and estimating and mentions that it should be consistently applied. In essence, CAS 401 just expands on this FAR principle and gives examples.
CAS 401 Fundamental Requirements
The fundamental requirements boil down to two items:
- Cost accounting practices used in accumulating and reporting actual costs = practices used in estimating costs in pricing the related proposal
- Grouping homogenous (of a same or similar kind or nature) costs in estimates is acceptable when costs are accumulated and reported in greater detail on an actual cost basis during contract performance.
How Does a CAS 401 Noncompliance Occur?
Let’s look at how a CAS 401 noncompliance occurs under each of these scenarios.
Scenario 1: A contractor proposes cost for material scrap using a factor based on “industry standards,” however, actual accounting practices at that contractor do not segregate scrap from basic material costs. This is an inconsistency between the way cost were estimated and accumulated. Not only is this a CAS 401 noncompliance, but also there is no way to determine how accurate the scrap factor is if scrap is not separately accounted for.
Scenario 2: A company estimates total engineering labor by pay grade (Engineer I, Engineer II, and Engineer III.) However, it accounts for engineering labor by function (Electrical Engineer, Mechanical Engineer, and Structural Engineer). This is a CAS 401 noncompliance unless the company provides data that reconciles the pay grade estimate to the cost functions that are accounted for in books.
Since it is acceptable to accumulate and report costs in greater detail on an actual cost basis than costs were estimated, the amount of detail required in accumulating and reporting may vary significantly from company to company based on specific circumstances. However, costs estimated must be presented so that any significant cost can be compared with the actual cost reported with respect to classification of costs as direct vs. indirect, the indirect pool to which cost is charged and the method of allocating indirect costs to the contract. For example, if fringe is estimated based on direct labor hours, then it cannot be accumulated based on direct labor dollars.
The real emphasis of CAS 401 is consistency. The company cannot change its accounting methodology between the time of the estimate and the recording of costs. If for some reason it is necessary for your company to change your accounting methodology, give us a call to see what needs to be done. Even if you have questions on whether your proposal estimate is consistent with your accumulation and recording, we can help! Watch for our next blog on another common CAS standard, 402, Consistency in Allocating Costs Incurred for the Same Purpose.