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)
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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)
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 Item 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 Item 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 Item Determination
Department of Defense class deviations are implementing the Revolutionary FAR Overhaul across multiple FAR and DFARS parts, with effective dates beginning as early as February 1, 2026. These changes affect clause structure, regulatory language, and timing considerations, requiring contractors to closely evaluate solicitations, flowdowns, and contract terms to maintain alignment with updated requirements.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR)
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Government contractors will see another significant change to the acquisition threshold under the FY 2026 National Defense Authorization Act. The Truthful Cost or Pricing Data threshold is increasing to $10 million, creating new considerations for proposals, negotiations, and contract modifications. Multiple threshold updates within a short period have introduced added complexity around timing, clause language, and award dates. Understanding how these changes interact with existing contracts is essential for maintaining consistency and avoiding unnecessary compliance risk.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Estimating System Compliance
In reference to the now outdated terminology “Multiple Personality Disorders” (now “DID” or Dissociative Identity Disorder), my focus is on two Government actions, the 2026 NDAA (National Defense Authorization Act) and the very recent EO (Executive Order), “Prioritizing the Warfighter in Defense Contracting.” Before getting into the substance of this blog, just to note that one can only hope that the proposed/legislated changes to improve the efficiencies and effectiveness of the procurement process (for the Department of War and more broadly the US Government) will actually succeed and not be just one more set of idealized and unfulfilled political promises.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS)
On November 24, 2025, President Trump signed EO 14363, Launching the Genesis Mission to accelerate America’s race for global dominance in the application of AI to scientific discovery and scientific challenges.
Topics: Accounting System Compliance, Incurred Cost Proposal Submission (ICP/ICE), DFARS Business Systems, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), Grants & Cooperative Agreements (2 CFR 200)