Updating cas disclosure statements

11 Apr

A CAS-covered contract may be subject to either full or modified coverage. (a) The contracting officer shall insert the provision at 52.230-1, Cost Accounting Standards Notices and Certification, in solicitations for proposed contracts subject to CAS as specified in .201 (FAR Appendix).The rules for determining whether full or modified coverage applies are in .201-2 (FAR Appendix). (b) If an award to an educational institution is contemplated prior to July 1, 1997, the contracting officer shall insert the basic provision set forth at 52.230-1 with its Alternate I, unless the contract is to be performed by a Federally Funded Research and Development Center (FFRDC) (see .201-2(c)(5) (FAR Appendix)), or the provision at .201-2(c)(6) (FAR Appendix) applies.First there is the "adequacy" determination and secondly, the "compliance" determination. Today we want to focus on the specific factors that the Government uses to determine whether a Disclosure Statement is adequate.It is important to note that the ACO (Administrative Contracting Officer) is the one that actually makes the determination but it is the contract auditor that provides the basis and report for that determination.It provides a structure for Contractors are required to complete separate Disclosure Statements for each "segment" allocating costs to Government contracts.So, for example, if a contractor has a corporate office or a home or intermediate office that allocates costs to that segment, additional Disclosure Statements are required.

(1) Insert the clause at FAR 52.230-3, Disclosure and Consistency of Cost Accounting Practices, in negotiated contracts when the contract amount is over 0,000, but less than million, and the offeror certifies it is eligible for and elects to use modified CAS coverage (see .201-2 (FAR Appendix)), unless the clause prescribed in paragraph (c) of this subsection is used.

, which is a written document that describes a contractor’s cost accounting practices and procedures.

This statement should adequately describe either the actual or proposed cost accounting practices, and these practices must follow and comply with the applicable What Are the Cost Accounting Standards (CAS) Cost Accounting Standards for disclosure statements exist to create consistency in pricing and accounting practices so that the Federal Government can determine costs during negotiated federal procurements and to see how you do business.

Contractors that contemplate bidding on million or higher contracts must submit a CAS Disclosure Statement prior to award.

Yesterday we described the Government's "administrative" processes related to Disclosure Statements that have been submitted.