Redstone Government Consulting Blog

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)

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

The FY 2026 NDAA raised the Truthful Cost or Pricing Data threshold to $10 million and made TINA Lite permanent for Department of War acquisitions. DCAA’s August 2026 guidance provides additional direction on proposal reviews and data expectations, making it important for government contractors to understand how these changes may affect proposal preparation and negotiations.

Topics: Proposal Cost Volume Development & Pricing, Incurred Cost Proposal Submission (ICP/ICE), Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Cost Accounting Standards (CAS), REAs, Claims & Terminations

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)

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)

On August 21, 2026, the Department of Labor’s (DOL) Office of Federal Contractor Compliance Programs (OFCCP) published three final rules addressing its regulatory framework following the revocation of EO 11246. One final rule rescinds the regulations that implemented EO 11246, while the other two modify the regulations implementing Section 503 of the Rehabilitation Act of 1973, as amended, and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) of 1974, as amended. The Section 503 and VEVRAA changes are generally effective September 21, 2026, while the rescission of the EO 11246 implementing regulations is effective October 26, 2026.

Topics: Contracts & Subcontracts Administration, Human Resources, Government Regulations, Office of Federal Contract Compliance Programs, Organizational Change Management Consulting

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

The SBA’s final rule changes how individually owned firms establish social disadvantage for 8(a) eligibility by removing the rebuttable presumption and individual narrative test. Effective September 10, 2026, the new standard applies to pending and future applications and adds a requirement to show material harm resulting from discrimination or bias.

Topics: Litigation Consulting Support, Small Business Compliance, Contracts & Subcontracts Administration, Human Resources, Government Regulations

Other Transaction Authority awards can create contract administration questions when the agreement does not clearly incorporate FAR requirements. In one termination for convenience matter, a dispute over FAR Part 31 applicability showed how legal counsel can help clarify award terms, challenge unsupported assumptions, and move the parties beyond an impasse.

Topics: Litigation Consulting Support, Contracts & Subcontracts Administration, DCAA Audit Support, Government Regulations, Federal Acquisition Regulation (FAR), REAs, Claims & Terminations