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
Effective October 1, 2026, the CAS Board rescinds CAS 407 and transfers retained standard costing requirements to CAS 418. Greater reliance on GAAP reduces duplicative requirements, but government contractors must continue to follow consistent accounting practices and evaluate disclosure and cost impact obligations before making changes.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Government Regulations, Cost Accounting Standards (CAS)
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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
DCAA has ended planned compliance audits for CAS 404, 408, 409, and 411 following their removal from CAS effective August 7, 2026. While standalone audits for these standards are being discontinued, government contractors should expect continued scrutiny of accounting practice changes, CAS 401 compliance, and disclosure statements through other DCAA audit activity.
Topics: Accounting System Compliance, Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), Material Management & Accounting System (MMAS)
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Topics: Proposal Cost Volume Development & Pricing, Contracts & Subcontracts Administration, DFARS Business Systems, DCAA Audit Support, Government Regulations, Estimating System Compliance, Commercial Determination
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)