Achieving success with Cost Accounting Standards (CAS) for government contractors

It’s essential that government contractors comply with Cost Accounting Standards (CAS) if they want to maximize their contracting opportunities and achieve success.

Compliance with CAS is not only essential for government contractors, it’s essential if government contractors want to maximize their contracting opportunities.

Staying up to date on statutory and regulatory requirements and essential guidance is key, particularly when it comes to CAS compliance, disclosure statements, and adapting to trends, and leveraging technology.

Effective disclosure statement submission, compliance, and revision

The submission process typically involves providing the disclosure statement to various stakeholders, including the contracting officer, auditors, and other relevant parties. Familiarity with submission tools and potential assistance may be necessary to facilitate this process. When revising disclosure statements, contractors must adhere to statutory and regulatory requirements. This involves ensuring that CAS and regulatory requirements are being met, and making all necessary updates and changes if they’re not. However, contractors also need to be aware of the triggers that require submission of disclosure statements, such as the $50 million threshold. This threshold serves as a primary trigger, necessitating disclosure unless exempted.

It is also crucial to be prepared for potential submissions post-contract award or renegotiation. Proactive compliance measures help ensure contractors are ready to submit disclosure statements when required, minimizing non-compliance risk.

Ignoring necessary revisions can lead to audit scrutiny and potential non-compliance findings. To mitigate this risk, contractors must carefully review and revise disclosure statements. After revising a disclosure statement, contractors must initiate the resubmission process and seek approval from the contracting officer. This step is essential for maintaining compliance and transparency throughout the revision process.

Compliance with CAS standards while adapting to evolving contract trends

To understand prevailing trends in government contracting, contractors must track prevalent contract types, such as fixed-price or time-and-materials (T&M). Compliance with CAS standards is mandatory if not otherwise exempt. Contractors subject to modified CAS must comply with CAS 401, 402, 405, and 406. 

Contractors subject to full CAS coverage must understand and adhere to all 19 standards to ensure compliance and mitigate risks of non-compliance. 

Leverage technology and navigate materiality for effective cost accounting

  • Understanding materiality criteria: Materiality in cost accounting practice changes involves considering various criteria, such as absolute dollar amount, percentage of contract cost, and cumulative impact.
  • Embracing technological advancements: Embracing technological advancements, particularly artificial intelligence (AI), offers opportunities to enhance efficiency and streamline compliance processes. Contractors may be able to leverage AI solutions to optimize business operations and satisfy compliance requirements effectively.
  • Exploring innovative solutions: Cost accounting practice changes fall into three categories: required, unilateral, and desirable. Contractors must explore innovative solutions to navigate these changes and optimize their cost accounting practices for compliance and effectiveness.

Subject matter expertise

View All Specialists

Caitlin Lewis

CPA, Manager
Jon Bencivenga

Jon Bencivenga

CFE, Director – Government Contracting Advisory
christine williamson

Christine Williamson

CPA, PMP, Partner

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This has been prepared for information purposes and general guidance only and does not constitute legal or professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick LLP, its partners, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.