Reporting of Independent Research and Development (IR&D) projects on the Defense Technical Information Center (DTIC) portal is normally due no later than three months after the contractor’s fiscal year-end, both annually and upon project completion. However, the DTIC portal was offline from November 2025 until approximately April 20, 2026, due to cyber vulnerabilities. Despite the nearly six‑month outage, Defense Pricing, Contracting and Acquisition Policy (DPCAP) has provided contractors just over 30 days, until May 31, 2026, to enter all required IR&D information, including new projects, annual updates, and closed projects. This accelerated timeline contrasts with the DFARS allowance of up to three months after the fiscal year-end for reporting.
Topics: Accounting System Compliance, Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, DFARS Business Systems, Defense Procurement & Acquisition Policy (DPAP), Government Regulations, Federal Acquisition Regulation (FAR)
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
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)
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)
Government contractors should be aware of a proposed FAR rule implementing FY 2023 NDAA Section 5949 that will prohibit the use of certain covered semiconductor products and services in federal procurements by December 23, 2027. The rule introduces new certification, disclosure, and supply chain review requirements that may significantly impact sourcing, compliance, and contract performance.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Export & Import, Material Management & Accounting System (MMAS), Commercial Determination, Manufacturing Operations Consulting
The FY 2026 NDAA, Section 1807, directs DoD to maintain Project Spectrum, a no-cost online platform offering cybersecurity training, tools, and resources for small and medium-sized government contractors. Originally launched in 2019, the platform supports CMMC compliance and is available to any company pursuing DoD work, regardless of current contract status.
Topics: Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Cybersecurity, Commercial Determination, Manufacturing Operations Consulting
The Department of War has introduced an Acquisition Transformation Strategy aimed at prioritizing commercial solutions and expanding participation from nontraditional contractors. While the direction signals reduced barriers and faster acquisition, contractors must evaluate how evolving expectations, timing, and risk tolerance will affect compliance, pricing, and engagement strategies.
Topics: Accounting System Compliance, Small Business Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Commercial Determination
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
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
