Redstone Government Consulting Blog | Cost Accounting Standards (CAS) (4)

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.

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,

The most common CAS (Cost Accounting Standards) exemption for most businesses is the small business exemption.  Most contractors understand that as long as they’re small, CAS is a non-issue.  What happens when you’re approaching your NAICS cap and headed toward the dreaded “other than small” status?

In responding to contractor criticisms that DCAA has far too many criteria within their “adequacy checklists”, DCAA has now developed and is pilot testing a new adequacy checklist which involve the same criterion, but each criterion is individually weighted to yield a true risk and materiality based adequacy determination.   Additionally, in developing the weighted criterion, DCAA has implicitly acknowledged that contractor proposals do not have to be 100 percent adequate to be auditable.

“My DCAA auditor is telling me I’m now subject to CAS. What does that mean? What do I do?”