Federal acquisition policy is shifting fixed-price contracting back to the default and preferred approach under Executive Order 14402 and updated FAR Council guidance. With implementation beginning in July 2026, government contractors should consider how contract type, pricing risk, existing awards, and contract administration may be affected.

Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Contractor Purchasing System Review (CPSR), Government Regulations, Federal Acquisition Regulation (FAR), Manufacturing Operations Consulting

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)

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

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

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

For the last few years, our friends at the Defense Contract Audit Agency (DCAA) have been very helpful by publishing the Contractor Compensation Cap in the December timeframe. This year, I am guessing that the Government shutdown has diverted their attention. To help our clients, we have calculated the 2026 amount of the cap.

Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Employee & Contractor Compensation, Incurred Cost Proposal Submission (ICP/ICE), DCAA Audit Support, Human Resources, Government Regulations, Federal Acquisition Regulation (FAR)

Well, our friendly DCAA auditors are back after the Government shutdown. On December 2, 2025, Defense Contract Audit Agency (DCAA) issued a memorandum to their auditors titled, “Actions Required for Assignment Due Dates Following Furloughs.”

Topics: Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Small Business Compliance, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations

Well, of course, The Department of Defense (DOD) can. The three most common situations where DoD requires cost data on a fixed price contract are:

Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, Government Regulations, Federal Acquisition Regulation (FAR)