Redstone Government Consulting Blog | Cost Accounting Standards (CAS) (3)

Let’s Set the Stage

So as a contractor you have received several cost-based contracts (i.e., subject to FAR Part 31), however they have all been less than $7.5M. You are flying under the Cost Accounting Standards (CAS) radar. You get a $9M cost-based contract that does not meet any of the exceptions to CAS covered listed at 9903.201-1(b) – categories of contracts and subcontracts exempt from all CAS requirements. The dreaded “trigger contract.”

Have you made a change in accounting practice that would require a Cost Accounting Standard (CAS) Cost Impact? Watch our latest blog to help you understand the requirements and potential issues.

The calendar year ended December 31^st and you are closing your books and gathering information for your incurred cost submission that is due June 30^th. There is one more requirement you should consider that may have been overlooked. Does your company meet the requirement to input independent research and development (IR&D) costs into the Defense Technical Information Center (DTIC)?

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.

The Financial Accounting Standards Board (FASB) issued Topic 842, Leases, in February 2016 effective for fiscal years beginning after December 15, 2018. The change was “to increase transparency and comparability among organizations by recognizing lease assets and lease liabilities on the balance sheet and disclosing key information about leasing arrangements.” For the past 40 years or so, operating leases were only required to be presented in the disclosure and were off-balance sheet transactions. Other than the new asset (Right to Use asset) and a related liability on the balance sheet, the impact on the income statement (a single line item for lease expense) and cash flow are unchanged, at least under GAAP. International Financial Reporting Standards (IFRS) now requires all leases be treated similar to capital leases (Topic 842 calls these finance leases). So, under IFRS there will be more unallowable interest to properly account for on Government proposals and contracts incorporating FAR Part 31.

On August 17, 2020; Acting Principal Director for Defense Pricing and Contracting issued two memos providing guidance in support of DFARS Class Deviation 2020-O0013 and 2020-O0021 – CARES Act Section 3610 Implementation. There is also a memo providing contracting officers with a template for a Memorandum for Record to document the file for the issuance of the Section 3610 related contract modification.

We Lifted the Vail

A few months back we submitted a request to DCAA under Freedom of Information Act. Based on the DPC guidance referencing both DCAA and DCMA as playing a key role in support of the rest of the DoD Acquisition Community, we expected DCAA would have a significant number of documents disclosing this key role. Turns out, not so much. All we got was a single document listing 13 frequently asked questions (FAQs) DCAA has been fielding from their auditors, dated July 31, 2020.

5 Things You Need to Know Before Your Update

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.

Accounting for Bid and Proposal (B&P) Explained

Bid and Proposal is a topic that comes up with our contractor clients on a regular basis. Most questions surrounding this topic involve: whom at the contractor should be charging B&P, especially, contractor personnel that typically charge overhead or G&A. We understand why this is confusing. It is our opinion that the guidance per FAR (Federal Acquisition Regulations) and CAS (Cost Accounting Standards) regarding this topic is unclear and leaves contractors scratching their heads trying to be compliant.