Congress Asks How to Support DoW Supplier Cost and Pricing Transparency Efforts

On October 20, 2026, a bipartisan group of Senators sent a letter to Department of War (DoW) Deputy Secretary Andrew Feinberg. The Senators wrote in support of the Deputy Secretary’s August 18, 2026, memorandum titled “Supplier Cost and Pricing Transparency.” The Senators hailed this memorandum for holding defense contractors accountable for overcharging the department and for allowing the Pentagon to obtain cost and pricing data from industry to negotiate the best price for the Warfighter, the taxpayer, and Nation.

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Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance

Could Signing an IDIQ Contract Trigger Full CAS Coverage?

Effective October 1, 2026, the CAS final rule uses the contract ceiling to assess the monetary exemption for single award Indefinite-Delivery Indefinite-Quantity (IDIQ) contracts and the individual order ceiling for multiple award IDIQs. Before signing, government contractors should consider whether full CAS coverage could affect their nontraditional defense contractor status and related exemptions.

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Topics: Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)

DCAA Issues Guidance on Non-Traditional Defense Contractors

DCAA’s October 6, 2026, memorandum addresses exemptions for nontraditional defense contractors from certain cost, pricing, and business system requirements. DCAA may still provide audit and advisory support, and contractors may still need to provide cost data. Questions remain about implementation and how individual exempt contracts will be reviewed.

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Estimating System Compliance

DoW Cost and Pricing Guidance Leaves Key Questions Unanswered

Department of War’s (DoW) October 1, 2026, memorandum provides guidance on cost data requests, reporting, and profit expectations. Questions remain about how the direction will affect pricing negotiations, accounting requirements, and profit sharing. Government contractors should assess these expectations alongside existing contract terms and applicable regulations.

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Estimating System Compliance, Commercial Determination

FAR Council Proposes Revised Incurred Cost Submission Requirements

The FAR Council’s proposed revisions to FAR 52.216-7 would change several requirements used to determine whether an incurred cost submission is adequate. The changes would reorganize or remove certain schedules and add requirements for some fixed-price incentive contracts, creating important considerations for submission preparation, audit support, and contract closeout.

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Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)

DoW Acquisition Reform Targets CAS, Pricing, Audits, and Business Systems

DoW is pursuing significant acquisition reforms that could reshape CAS applicability, pricing, audits, and contractor business system oversight. The planned changes emphasize greater use of GAAP, reduced administrative requirements, and streamlined acquisition practices, with implementation actions scheduled over the next 30 to 120 days and additional regulatory changes potentially required.

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Estimating System Compliance, Manufacturing Operations Consulting

CAS Final Rule Increases Thresholds and Changes Coverage Requirements

The CAS Board has finalized significant changes to CAS thresholds and coverage requirements effective October 1, 2026. The rule raises the basic and full coverage thresholds while introducing new considerations for IDIQ contracts, existing awards, and Disclosure Statement requirements.

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Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Estimating System Compliance

Preparing for the $10 Million TINA Threshold and New TINA Lite

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.

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Topics: Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), REAs, Claims & Terminations

Department of War (DoW) is After Your Data and Profit

On August 18, 2026, DoW issued a memorandum calling for broader access to contractor and subcontractor cost data, greater pricing transparency, and increased scrutiny of profit. The direction could significantly affect pricing practices, negotiations, system access, and compliance expectations across the defense industrial base.

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Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance

DCAA Eliminates CAS 404, 408, 409, and 411 Compliance Audits as Oversight Shifts

DCAA has ended planned compliance audits for CAS 404, 408, 409, and 411 following their removal from CAS effective August 7, 2026. While standalone audits for these standards are being discontinued, government contractors should expect continued scrutiny of compliance with Generally Accepted Accounting Practices (GAAP), accounting practice changes, CAS 401 compliance, and disclosure statements through other DCAA audit activity.

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Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Material Management & Accounting System (MMAS)