A $1 million False Claims Act settlement over allegedly noncompliant Chinese components highlights the risks of inaccurate sourcing certifications. Government contractors need to understand supplier sourcing, document compliance reviews, and monitor changing restrictions to help ensure purchased products meet the requirements in their government contracts.
Topics: Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Material Management & Accounting System (MMAS), Manufacturing Operations Consulting
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.
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
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.
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
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.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR)
Proposed FAR Part 15 revisions would change how the government evaluates proposals and conducts exchanges with offerors. The changes could create more opportunities for government contractors to explain beneficial approaches, address specific proposal concerns, and negotiate key contract terms. Comments on FAR Case 2026-003 are due October 19, 2026.
Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, Government Regulations, Federal Acquisition Regulation (FAR)
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.
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
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.
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
DoD’s July 30, 2026, class deviation raises the Full CAS and Disclosure Statement thresholds to $100 million, changing how CAS coverage may apply to certain defense contracts. Government contractors should reassess CAS applicability, pending proposals, Disclosure Statement requirements, and ongoing audit activity to determine how the new thresholds affect current obligations.
Topics: Accounting System Compliance, DFARS Business Systems, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR), Estimating System Compliance
Government contracting disagreements can reach an impasse when the parties dispute which requirements apply. Legal counsel may offer another avenue for documenting the contractor’s position and seeking clarification. An OTA termination matter illustrates how a legal show cause notice clarified FAR Part 31 applicability, even though DCAA retained its audit report.
Topics: Litigation Consulting Support, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), REAs, Claims & Terminations
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.
Topics: Accounting System Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Federal Acquisition Regulation (FAR)
