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.
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
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.
Topics: Accounting System Compliance, Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Human Resources, Government Regulations, Organizational Change Management Consulting, Manufacturing Operations Consulting
DCAA recently released Version 1.04 of the ICE Model that utilizes Microsoft Power Query to prepare incurred cost proposals. For government contractors preparing annual incurred cost submissions with Microsoft Power Query, this update should be used in replacement of the previous version released. Both the April 2026 Power Query version and the May 2019 Visual Basic version remain available, but each version carries different considerations for preparation, review, and submission through the Contractor Submission Portal.
The updated Power Query version is intended to improve compatibility with contract information such as contract ceiling issues on Schedule I. The instructions have been revised to provide better clarification of information required to properly run the power query version. The original Visual Basic version remains available, but contractors using this version need to be aware of a specific restriction in the Contractor Submission Portal. Files prepared in the Visual Basic version must be saved as .xls or .xlsx before uploading to the Contractor Submission Portal. The Contractor Submission Portal will not accept .xlsm macro files.
Topics: Accounting System Compliance, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Federal Acquisition Regulation (FAR)
In June 2023, the Armed Services Board of Contract Appeals (ASBCA) denied Honeywell's motion to dismiss a $151 million claim alleging improper G&A allocation treatment under CAS 410. The Board affirmed that interdivisional cost transfers must be included in a total cost input base, contradicting Honeywell's position. Government contractors should review whether their G&A allocation bases are consistent with this ruling.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)
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The Cost Accounting Standards (CAS) Board has been working to eliminate several cost accounting standards and replace them with reliance on GAAP. As of April 2026, five standards are under proposed elimination, including a new March 2026 NPRM for CAS 407. Contractors should be aware that removing these standards does not eliminate cost accounting or consistency obligations.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)
On March 20, 2026, the CAS Board issued a Notice of Proposed Rulemaking proposing significant increases to the CAS thresholds and changes to exemption determinations for indefinite-delivery contracts. Most changes reflect requirements in Section 1806 of the 2026 NDAA and are broadly favorable to contractors, though key concerns remain about the treatment of single-award indefinite-delivery contracts.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)
The United States Supreme Court has ruled that the International Emergency Economic Powers Act does not authorize presidential tariffs, effectively invalidating prior IEEPA-based duties. This decision creates uncertainty around potential refunds and shifts attention to new tariff measures now in effect. Importers and trade compliance teams must reassess duty exposure, documentation practices, and forward-looking trade strategies in a rapidly changing regulatory environment.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Estimating System Compliance, Manufacturing Operations Consulting
Contractors pursuing competitive prime awards under FAR Part 15 face heightened expectations for cost realism, documentation, and historical support. Agencies rely on detailed cost narratives and supporting data to make best value determinations. Weak or unsupported pricing can delay negotiations or undermine award decisions, making early preparation and internal alignment critical to proposal success.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
Section 1826 of the FY 2026 National Defense Authorization Act shifts DoD treatment of nontraditional defense contractors from discretionary to mandatory exemptions from key cost and business system requirements. With no dollar threshold and rulemaking still pending, government contractors must evaluate timing, contract status, and downstream compliance implications.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Contractor Purchasing System Review (CPSR), Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Commercial Determination
Congress has directed NIH and the Department of Defense to maintain negotiated indirect cost rates and restrict the use of rate caps within recent appropriations legislation. The update may affect grant funding, reimbursement expectations, and agreement terms. Organizations should understand how timing and regulatory alignment influence existing and future awards.
Topics: Accounting System Compliance, DCAA Audit Support, Government Regulations, Grants & Cooperative Agreements (2 CFR 200)