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.
Highlights
- Threshold Increase. The FY 2026 NDAA increased the Truthful Cost or Pricing Data threshold from $2.5 million to $10 million for qualifying awards after June 30, 2026.
- DCAA Expectations. DCAA’s August 27, 2026, Audit Alert indicates auditors may evaluate other than certified cost or pricing data for proposals below the new threshold.
- TINA Lite Implementation. TINA Lite is now permanent for Department of War acquisitions, although implementing DFARS regulations have not yet been issued.
- Contractor Impact. Government contractors should expect continued requests for supporting cost data below $10 million and should distinguish carefully between certified and other than certified cost or pricing data.
- Preparation Priorities. Estimating and purchasing policies, procedures, templates, and training should be updated to reflect the new threshold and evolving TINA Lite requirements.
The Fiscal Year 2026 National Defense Authorization Act (NDAA) introduced significant changes affecting how the Department of War (DoW) implementation of Truthful Cost or Pricing Data Act, increases to the Truthful Cost or Pricing Data Threshold from $2.5 Million to $10 Million and making the “TINA Lite” authority permanent. However, the Defense Federal Acquisition Regulations (DFARS) regulations to implement TINA Lite have not been promulgated yet.
On August 27, 2026, Defense Contract Audit Agency (DCAA) issued an Audit Alert on the increase to Truthful Cost or Pricing Data Threshold and TINA Lite Authority (MRD 26-CPSP-007(R)). The TINA Lite Authority is only applicable to DoW awards. The new TINA thresholds are based on the award date of the contract, subcontract or modification (i.e., after June 30, 2026).
Increase in TINA Threshold to $10M
With the increase in the TINA threshold to $10 Million, auditors will continue to audit proposals as usual by auditing certified cost and pricing data above the threshold, unless an exemption applies, to support fair and reasonable pricing.
Prior to this change, DCAA generally did not perform audits of proposals under $10 million based on internal guidance. Yet, the Audit Alert indicates that for proposals under $10 million, auditors will evaluate other than certified cost or pricing data, such as cost data. While the Defense Contract Management Agency (DCMA) typically reviewed proposals under $10 million, contractors may begin to see an increase in DCAA conducting proposal audits below $10 million and should expect requests for cost data.
DCAA’s Role in the Implementation of TINA Lite
With the implementation of TINA Lite on DoW proposals, expect auditors to begin engaging with contracting officers prior to the release of solicitations to help define or tailor data requirements and identify the appropriate type and format of your historical data.
However, we believe that determining what data is necessary under a TINA Lite proposal should remain the responsibility of the contracting officers and not the auditors. DCAA can provide support to the Contracting Officer, but the Contracting Officer remains responsible for determining what data is required in the solicitation.
What Does the Increase in TINA Threshold Mean to Government Contractors?
- Contractors must still provide other than certified cost or pricing data to support price reasonableness below the $10 Million threshold, which can include cost data.
- Government can no longer pursue defective pricing claims for contracts and subcontracts under $10 Million awarded after June 30, 2026.
- Expectations for adequate supporting cost data will remain high.
- Contractors should not sign Certificate of Current Cost and Pricing Data for any proposals under $10 Million that are in process or under audit.
How TINA Lite will Impact Government Contractors
TINA Lite does NOT eliminate the requirement for certified cost and pricing data. The contracting officer will specify in the solicitation which certified cost or pricing data is required and will rely on that information to determine the proposed price is fair and reasonable.
DCAA auditors are expected to support contracting officers by helping identify the appropriate type and format of your historical data to support a TINA Lite acquisition. DCAA’s sole involvement will most likely result in expanded or unnecessary data requirements, creating added burden for government contractors and undermining the intended efficiencies of TINA Lite.
Government contractors need to engage early with the acquisition team, take the lead in understanding the data requirements in the solicitation, and ensure DCAA does not request data beyond what the Contracting officer has determined is necessary.
For additional background on the TINA Lite authority and how it works, read our article, "What Government Contractors Need to Know about TINA Lite Becoming Permanent."
Takeaways
Government contractors should update their estimating and purchasing policies, procedures, and templates to reflect the new $10 Million threshold and provide training on the new threshold and distinctions between certified and other-than-certified cost or pricing data.
The training should focus on the fact that even if certified data is not required, a fair and reasonable price must still be determined. In other words, contracting officers and higher-tier contractors will not stop asking for cost or pricing data to support proposals below $10 Million and your estimators and buyers should not stop performing price and cost analysis on purchases below $10 Million. Only the certification requirement goes away below $10 Million.
It is essential that government contractors engage early with acquisition officials on solicitations that will be subject to TINA Lite. Government contractors need to be involved and stay engaged throughout the process to make sure DCAA isn’t asking for data the contracting officer doesn’t need.
Preparing for the New TINA Requirements
Redstone GCI assists government contractors with preparing and supporting other than certified cost or pricing data below the TINA threshold and evaluating TINA Lite solicitation requirements. Our subject matter experts also support cost volume development, estimating policies and procedures, data sweep processes, and training to help government contractors understand applicable requirements before proposal submission and price agreement.
Frequently Asked Questions
- What is the new TINA threshold? The Truthful Cost or Pricing Data threshold increased from $2.5 million to $10 million for qualifying contracts, subcontracts, and modifications awarded after June 30, 2026.
- Does the $10 million threshold mean contractors no longer need to provide cost or pricing data below that amount? No. Contracting officers and higher-tier contractors may still request other than certified cost or pricing data to support a fair and reasonable price.
- What is TINA Lite? TINA Lite allows the Department of War to tailor the certified cost or pricing data required for certain acquisitions rather than requiring the full set of data traditionally associated with TINA.
- Does TINA Lite eliminate certified cost or pricing data requirements? No. Certified cost or pricing data may still be required. The contracting officer will identify the data needed for the acquisition.
- What role does DCAA have under the new requirements? DCAA may support contracting officers by reviewing proposal data and helping identify the type and format of historical data that may be needed.
- What should government contractors do now? Contractors should update estimating and purchasing policies, procedures, templates, and training to reflect the new threshold and prepare for evolving TINA Lite requirements.
Lynne is a Director with Redstone Government Consulting, Inc. providing government contract consulting services to our clients primarily related to Commercial Item Determinations and support, Cost Accounting Standards, DFARS Business System Audits, Proposals, and Incurred Cost. Prior to joining Redstone Government Consulting, Lynne served in several capacities with DCAA and DCMA for over 35 years. Professional Experience Lynne began her career working with DCAA in the Honeywell Resident Office, Clearwater, FL in 1984. Lynne’s experience included various positions which involved conducting or reviewing forward proposals or rate audits, financial capability audits, progress payments, accounting and estimating systems, cost accounting standards, claims and disclosure statement reviews. She is an expert in FAR, DFARS, CAS and testified as an expert witness. Lynne assisted in drafting the commercial item guidance for DCAA Headquarters. Lynne was assigned as a Regional Technical Specialist where she provided guidance to 20 field offices on highly complex or technical issues relative to forward pricing, financial capability or progress payment issues. As an Assistant for Quality, she was involved in reviewing and ensuring audit reports were in compliance with policy and GAGAS as well as made NASBA certified presentations to the staff including but not limited to billing reviews, CAS, unallowable cost and progress payments. To enhance her experience in government contracting, Lynne accepted a position with DCMA in 2015 as part of the newly organized DCMA Cadre of Experts in the Commercial Item Group. This included performing reviews of prime contractor’s assertions and/or commercial item determinations as well as performing price analyses. Lynne was a project lead and later became a lead analyst where she engaged with the buying commands on requests and reviewed price analysis reviews performed by a team of 5 analysts. She also assisted the DCMA CPSR team relative to commercial items and co-instructed the Commercial Item Training presented to DCMA. Education Lynne earned a Bachelor of Science Degree in Accounting from the University of Central Florida. Certifications State of Florida Certified Public Accountant State of Alabama Certified Public Accountant Defense Acquisition Workforce Improvement Act (DAWIA) Level III- Auditing DAWIA Level III – Contracting