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

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 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)

What Government Contractors Need to Know About TINA Lite Becoming Permanent

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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Estimating System Compliance, Commercial Determination

Cost Accounting Standards Board (CASB) Makes Progress on Conforming CAS to GAAP

The CASB’s final rule rescinds CAS 408 and 411 and most of CAS 404 and 409 to align CAS with GAAP, effective August 7, 2026. For government contractors, the change may reduce duplicative requirements, but it does not eliminate considerations related to disclosure, consistency, or cost impact tied to accounting practice changes.

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

QuickBooks Setup Decisions Can Create Problems for Government Contractors

QuickBooks is often one of the first accounting systems used by small and growing government contractors. It is accessible, familiar, and capable of supporting many core accounting needs. But the way QuickBooks is set up matters. Early decisions about accounts, projects, payroll, cost pools, and reporting may not seem significant at the time, but those choices can create problems later when the government contractor needs to support contract billing, indirect rate analysis, incurred cost preparation, or questions from a government customer or auditor.

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Topics: Accounting System Compliance, Small Business Compliance, DCAA Audit Support, Quickbooks

OMB Directs Agencies to Buy Commercial or Justify Non-Commercial Acquisitions

OMB’s new guidance directs agencies to expand commercial acquisitions and justify non-commercial awards. Government contractors may see closer review of commerciality, pricing, option periods, and cost-reimbursement contracts, making support for market research and contract decisions more important.

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

Here We Go Again, DCAA Reorganization Phase 3

On April 20, 2026, the Defense Contract Audit Agency (DCAA) announced yet another reorganization: a transition to 23 “hub” organizations while maintaining office locations at key defense contractor sites. This reduction reduces the 180 office (branch and suboffices) locations to 23 hubs covering only 19 of the 50 states in the continental U.S.

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Topics: Accounting System Compliance, Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Human Resources, Government Regulations, Organizational Change Management Consulting, Manufacturing Operations Consulting