--- title: Worst Disclosure Statement Surprises description: Don’t let a CAS Disclosure Statement ruin your holiday season. This list will help you know if you need and are ready to prepare a disclosure statement. image: https://info.redstonegci.com/hubfs/images/Blog_Images_with_title/RCGI-Worst%20Disclosure%20Statement%20Surprises.png --- [ PAY INVOICE](https://redstonegci.com/invoice-payment/) [Call Us Today 256-704-9800](tel:2567049800) [info@redstonegci.com](Mailto:info@redstonegci.com) [![Redstone_Logo](https://info.redstonegci.com/hubfs/redstone%20logo%20version%201%20-%20rgb-1.png)](https://www.redstonegci.com/) # Worst Disclosure Statement Surprises [Posted by Redstone Team on Wed, Dec 5, 2018 @ 12:12 PM](https://info.redstonegci.com/blog/author/redstone-team) - [Tweet](https://twitter.com/share) ![RCGI-Worst Disclosure Statement Surprises](https://info.redstonegci.com/hs-fs/hubfs/images/Blog_Images_with_title/RCGI-Worst%20Disclosure%20Statement%20Surprises.png?width=1000&name=RCGI-Worst%20Disclosure%20Statement%20Surprises.png) There are many presents one may enjoy receiving this holiday season. However, one present you do not want during the holiday season is a CAS Disclosure Statement (DS) surprise.  There are several surprises related to DS’s you can receive: - You have to submit a Disclosure Statement almost immediately - You don’t know if you need to submit a Disclosure Statement almost immediately - You are now subject to all of the CAS standards - You don’t have documented the answers to the Disclosure Statement questions - You don’t know the answers to the Disclosure Statement questions - You are in [noncompliance](https://www.redstonegci.com/consulting/government-compliance/government-compliance-training/) with one or more CAS standard - You must submit Disclosure Statements for your home office or intermediate home offices ## Bad Disclosure Statement News can Come With Large Contracts One of the worst surprises a government contractor can receive is to find out a Disclosure Statement is required in a very short time frame.  This can happen two ways: - Bid on a CAS covered contract in excess of $50M - Have CAS-covered sales in excess of $50M in the previous fiscal year Many contractors are surprised when they look at an RFP to find out that they must submit a Disclosure Statement *WITH* their proposal if it exceeds $50M.  It must be submitted prior to award of the contract.  I once had a company tell me that it wasn’t a big deal – they were going to lock themselves in a building on a Friday night, with plenty of beer and pizza, and not come out until it was written!  I never got a chance to see how that worked for them, but I doubt they really understood the magnitude of the problem.  ## Detailed Records Reduce the Surprises Another surprise is not having the information available to determine if your company had over $50M of CAS-covered sales in the previous year.  Many companies do not have an adequate universe of CAS-covered contracts.  If you already know you are subject to modified CAS coverage, it is important that you keep an accurate record of which contracts are CAS-covered to ensure you don’t late find out that you reached the $50M threshold and must submit a D/S. ## Disclosure Statement Preparation An additional complication is that the requirement to file a Disclosure Statement is often accompanied by becoming fully CAS-covered.  Therefore, the proposal should be prepared in a manner that is in accordance with the CAS standards or run the risk of being subject to a price adjustment due to a cost accounting practice change.  Once you have begun preparing the actual DS, you may find that you don’t have documentation that answers all the DS questions; it is even worse if you don’t know the answers to the questions.  There may be questions related to situations you have not yet encountered, but you know they are forthcoming.  You then must design the answer, answer the question and (hopefully) document the answer in your policies and procedures to ensure you follow it. Often CAS non-compliances are discovered during preparation of the initial Disclosure Statement and changes to the accounting system must be made.  Finally, you should also be aware that any home office or intermediate home office that allocates cost to the covered business entity will have to submit a Disclosure Statement. ## Disclosure Statement Success Planning is key to successful [Disclosure Statement preparation](https://www.redstonegci.com/consulting/government-compliance/cas-services/).  If your company is thinking about bidding on a contract over $50M or are approaching cumulative $50M if CAS covered contracts in a fiscal year, and don’t have a Disclosure Statement in place, you should begin planning now.  First, look at the questions asked in the Disclosure Statement.  If it is Greek to you, it is time to call [Redstone](https://www.redstonegci.com/) to help get you on track before one of these surprises costs you an award. [![Learn More About Our Cost Accounting Standards (CAS) Services](https://no-cache.hubspot.com/cta/default/203971/interactive-168706666552.png) ](https://info.redstonegci.com/hs/cta/wi/redirect?encryptedPayload=AVxigLIMwFYhtgtkegqfjoTFVfbEzUY2f7MRrdePUVHFt7ldi7dUkCSDukjs5NDyxvgemakwMXsdagT1q6vdF292QvjxRibT9i%2B2Av%2FKAE5y2%2FVGihuZyCJKxnkNUFe7%2FM5Y8zVQDFklGxswPemJlptbhYR7RvGF6PB2pGMiCssCXtuHo0LbHXBVUR2rrkVKHVZmKYOLUu6bLuBl6Ii5IIWMTSY5W1FESykfHC0%3D&webInteractiveContentId=168706666552&portalId=203971) ### Written by [Redstone Team](https://info.redstonegci.com/blog/author/redstone-team) ## About Redstone GCI Redstone GCI is a consulting firm focused on fulfilling the needs of government contractors in all areas of compliance. With a singular mission to help contractors through the multiple layers of “red tape,” we allow contractors to focus on what they do best – support their mission with the U.S. Government. We are home to a group of consultants made up of GovCon industry professionals, CPAs, attorneys, and retired government audit and acquisition professionals. Our focus and knowledge of audit and compliance functions administered by DCAA and DCMA will always be at the heart of what we do. However, for the past decade, we’ve strategically grown to support other areas of the government contractor back-office with that same level of focus and expertise. We’ve added expertise in contracts management, subcontract administration, proposal pricing, various software systems, HR and employment law, property administration, manufacturing, data analytics/reporting, Grant specialists, M&A, and many other areas. When we see a trend in the needs of contractors, we act to ensure we can provide the best expertise in the market to fulfill those needs. One thing our clients can be certain of is that with the Redstone GCI Team in your corner, there is no problem too big and no issue too technical for our team to tackle. Topics: [Contracts & Subcontracts Administration](https://info.redstonegci.com/blog/topic/contracts-subcontracts-administration) ### Search Posts This is a search field with an auto-suggest feature attached. - There are no suggestions because the search field is empty. ### Subscribe via E-mail ### Latest Posts ### Posts by category - [Accounting System Compliance (282)](https://info.redstonegci.com/blog/topic/accounting-system-compliance) - [Commercial Determination (34)](https://info.redstonegci.com/blog/topic/commercial-determination) - [Contractor Purchasing System Review (CPSR) (85)](https://info.redstonegci.com/blog/topic/contractor-purchasing-system-review-cpsr) - [Contracts & Subcontracts Administration (300)](https://info.redstonegci.com/blog/topic/contracts-subcontracts-administration) - [Cost Accounting Standards (CAS) (60)](https://info.redstonegci.com/blog/topic/cost-accounting-standards-cas) - [COVID-19 (23)](https://info.redstonegci.com/blog/topic/covid-19) - [Customer Success Story (2)](https://info.redstonegci.com/blog/topic/customer-success-story) - [Cybersecurity (28)](https://info.redstonegci.com/blog/topic/cybersecurity) - [DCAA Audit Support (249)](https://info.redstonegci.com/blog/topic/dcaa-audit-support) - [Defense Procurement & Acquisition Policy (DPAP) (7)](https://info.redstonegci.com/blog/topic/defense-procurement-acquisition-policy-dpap) - [Deltek Costpoint (54)](https://info.redstonegci.com/blog/topic/deltek-costpoint) - [DFARS Business Systems (179)](https://info.redstonegci.com/blog/topic/dfars-business-systems) - [DOD IG (10)](https://info.redstonegci.com/blog/topic/dod-ig) - [Employee & Contractor Compensation (22)](https://info.redstonegci.com/blog/topic/employee-contractor-compensation) - [Employers & Unions (8)](https://info.redstonegci.com/blog/topic/employers-unions) - [Estimating System Compliance (18)](https://info.redstonegci.com/blog/topic/estimating-system-compliance) - [Export & Import (19)](https://info.redstonegci.com/blog/topic/export-import) - [Federal Acquisition Regulation (FAR) (187)](https://info.redstonegci.com/blog/topic/federal-acquisition-regulation-far) - [Federal Construction Contracting (4)](https://info.redstonegci.com/blog/topic/federal-construction-contracting) - [Government Compliance Training (59)](https://info.redstonegci.com/blog/topic/government-compliance-training) - [Government Property Management (18)](https://info.redstonegci.com/blog/topic/government-property-management) - [Government Regulations (265)](https://info.redstonegci.com/blog/topic/government-regulations) - [Government Shutdown (9)](https://info.redstonegci.com/blog/topic/government-shutdown) - [Grants & Cooperative Agreements (2 CFR 200) (32)](https://info.redstonegci.com/blog/topic/grants-cooperative-agreements-2-cfr-200) - [Human Resources (118)](https://info.redstonegci.com/blog/topic/human-resources) - [Incurred Cost Proposal Submission (ICP/ICE) (83)](https://info.redstonegci.com/blog/topic/incurred-cost-proposal-submission-icp-ice) - [Litigation Consulting Support (17)](https://info.redstonegci.com/blog/topic/litigation-consulting-support) - [Manufacturing Operations Consulting (26)](https://info.redstonegci.com/blog/topic/manufacturing-operations-consulting) - [Material Management & Accounting System (MMAS) (23)](https://info.redstonegci.com/blog/topic/material-management-accounting-system-mmas) - [Non-US Government Contractor (3)](https://info.redstonegci.com/blog/topic/non-us-government-contractor) - [Office of Federal Contract Compliance Programs (31)](https://info.redstonegci.com/blog/topic/office-of-federal-contract-compliance-programs) - [Organizational Change Management Consulting (17)](https://info.redstonegci.com/blog/topic/organizational-change-management-consulting) - [Paycheck Protection Program (PPP) Loans (8)](https://info.redstonegci.com/blog/topic/paycheck-protection-program-ppp-loans) - [Program Management & Project Cost Control (2)](https://info.redstonegci.com/blog/topic/program-management-project-cost-control) - [Proposal Cost Volume Development & Pricing (79)](https://info.redstonegci.com/blog/topic/proposal-cost-volume-development-pricing) - [Quickbooks (21)](https://info.redstonegci.com/blog/topic/quickbooks) - [REAs, Claims & Terminations (10)](https://info.redstonegci.com/blog/topic/reas-claims-terminations) - [Redstone GCI (50)](https://info.redstonegci.com/blog/topic/redstone-gci) - [Sequestration (4)](https://info.redstonegci.com/blog/topic/sequestration) - [Service Contract Act (14)](https://info.redstonegci.com/blog/topic/service-contract-act) - [Small Business Compliance (121)](https://info.redstonegci.com/blog/topic/small-business-compliance) - [System Award Management (SAM) (9)](https://info.redstonegci.com/blog/topic/system-award-management-sam) - [UKG Ready HR Software Consulting (7)](https://info.redstonegci.com/blog/topic/ukg-ready-hr-software-consulting) - [Unanet (35)](https://info.redstonegci.com/blog/topic/unanet) - [Vlog (41)](https://info.redstonegci.com/blog/topic/vlog) ### Disclaimer ``` Data published on our website, such as our white papers, blogs and other government contracting commentary reflect our interpretations and opinions of current events and regulations, at the time such data is published, and the perspectives/opinions of other professionals in our industry may vary from our own.  Further, our commentary and perspectives do not reflect legal analyses, since we are not attorneys, but rather government contracts and accounting advisors.  We therefore make no representation that the use of our published information will insulate a company from government challenges, nor otherwise ensure a successful defense on any government procurement adverse action.  Readers agree that articles or blog commentary presented within our website shall not be replicated or re-published without requesting before publication in another medium, and our expressed written consent to do so. ``` **Redstone Government Consulting** 501 Madison Street SE, Suite 100 Huntsville, AL 35801 **Phone: ** [256.704.9800](tel:2567049800) **Email Us**[ info@redstonegci.com](mailto:info@redstonegci.com) **[PAY INVOICE](https://redstonegci.com/invoice-payment/)** [PCI DSS compliance documentation](https://redstonegci.com/wp-content/uploads/2016/10/pci_dss_self_assessment_certificate.pdf) © 2026 Redstone Government Consulting | All Rights Reserved | [Privacy Policy](https://redstonegci.com/privacy-policy/) | [Event Refund / Cancellation Policy](https://redstonegci.com/event-refund-cancellation-policy/)