1.
COST ACCOUNTING STANDARDS
Presented by Robert Jones, Left Brain Professionals

2.
Host: Liz Briggson, CPA
Connect on LinkedIn:
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3.
GOVERNMENT CONTRACTS & ACCOUNTING EXPERT
Email: robert@leftbrainpro.com
Phone: (614) 556-4415
LinkedIn: https://www.linkedin.com/in/rjones330/
Website: www.leftbrainpro.com/
Robert Jones CPA, CPCM, NCMA Fellow
 Professional Background
 Masters in Accountancy – College of Charleston
 Business Management, Compliance, Operations
 Controller
 Defense Contracts Manager
 Instructor and Speaker

4.
Cost Accounting
Standards

5.
We Know Government
Contracts

6.
Who we are
Left Brain Professionals is a boutique accounting firm that serves
government contractors. We specialize in accounting system design
& implementation, audit support, training, and cybersecurity
compliance.

7.
Our Services

8.
Our Team
Robert E. Jones
Government Contracts &
Accounting Expert
CPA, CPCM, NCMA Fellow
Melissa Metzger
Government Accounting &
Finance Advisor
MAFM, CPA Candidate
Steven Bressler
Government Contract
Associate
steve@LeftBrainPro.commelissa@LeftBrainPro.comrobert@LeftBrainPro.com

9.
Learning
Objectives
• Describe the purpose of Cost
Accounting Standards (CAS)
• List the Cost Accounting
Standards
• Identify CAS applicability
• Describe the disclosure process

10.
Room Poll
Which best describes your understanding of Cost Accounting
Standards?
A. What are Cost Accounting Standards?
B. I know a little
C. Fairly knowledgeable
D. I am an expert on CAS

11.
Purpose of Cost
Accounting Standards

12.
Purpose of Cost Accounting Standards (CAS)
Public Law 100-679 (41 U.S.C. 422)
Requires certain contractors and subcontractors to comply with
Cost Accounting Standards (CAS) and to disclose in writing and
follow consistently their cost accounting practices.
Cont…

13.
Purpose of CAS, Continued…
CAS Requirements
• Disclose practices in writing which includes maintaining
disclosure statement and submitting amendments or revisions as
necessary
• Consistently follow written practices
• Comply with all CAS
• Agree to equitable adjustment if contractor changes a practice
• Agree to adjustment if contractor fails to comply with CAS
Flow-down requirements to include in subcontracts and to monitor
subcontractor compliance.

14.
Room Poll
CAS Requirements can be disclosed verbally by a contractor or
subcontractor?
A. True
B. False

15.
Cost Accounting
Standards

16.
Cost Accounting Standards, Continued…
401 – Consistency in Estimating, Accumulating & Reporting Costs
CAS 401 is to:
1. achieve consistency in the cost accounting practices used by a
contractor in estimating costs for its proposals with those
practices used in accumulating and reporting costs during
contract performance, and
2. provide a basis for comparing such costs.
Cont…

17.
Cost Accounting Standards, Continued…
401 – Consistency in Estimating, Accumulating & Reporting Costs,
Continued…
Includes consistency in the structure
and level of detail in accumulating
and estimating costs.
Cont…

18.
Cost Accounting Standards, Continued…
402 – Consistency in Allocating Costs Incurred for the Same Purpose
CAS 402 is to ensure that each type of cost is allocated only once and on
only one basis to any contract or other cost objective. The fundamental
requirement is that all costs incurred for the same purpose, in like
circumstances, are either direct costs only or indirect costs only with
respect to final cost objectives.
Once a cost is determined to be either direct or indirect, it is always treated
the same way even if later determined to be unallowable or unbillable. See
also CAS 418.
Cont…

19.
Cost Accounting Standards, Continued…
403 – Allocation of Home Office Expenses to Segments
CAS 403 is to establish criteria for allocation of home office expenses to the
segments of the organization on the basis of a beneficial or causal [not
"casual"] relationship.
Each segment (division, location, etc.) bears its fair share of home office
expenses.
Cont…

20.
Cost Accounting Standards, Continued…
404 – Capitalization of Tangible Assets
CAS 404 establishes criteria for determining the acquisition costs of
tangible assets that are to be capitalized. CAS 404 does not cover
depreciation or disposition of fixed assets, which is covered by CAS
409.
Written capitalization policy with set dollar amount that aligns with
the size and complexity of the organization. Note IRS safe harbor for
expense vs capitalization of $2,500 to $5,000.
https://www.irs.gov/businesses/small-businesses-self-
employed/tangible-property-final-regulations Cont…

21.
Cost Accounting Standards, Continued…
405 – Accounting for Unallowable Costs
CAS 405 is to facilitate the negotiation, audit, administration, and
settlement of contracts. It contains guidelines on:
1. identification of costs specifically described as unallowable, at the
time such costs first become defined or authoritatively designated
as unallowable, and
2. the cost accounting treatment to be accorded such identified
unallowable costs to promote the consistent application of sound
cost accounting principles covering all incurred costs.
Cont…

22.
Cost Accounting Standards, Continued…
405 – Accounting for Unallowable Costs, Continued…
The standard does not govern the
allowability of costs, which is a function
of the appropriate acquisition or
reviewing authority [FAR 31 and DFARS
231].
Unallowable costs must be segregated
and removed from billings or claims.
Cont…

23.
Cost Accounting Standards, Continued…
406 – Cost Accounting Period
CAS 406 is to provide criteria for selecting the time periods to be used
as cost accounting periods for contract cost estimating, accumulating,
and reporting. It will reduce the effects of variations in the flow of costs
within each cost accounting period. It will also enhance objectivity,
consistency, and verifiability and promote uniformity and comparability
in contract cost measurements:
The cost accounting period must be the fiscal year (calendar or
otherwise) or another annual period agreed to by the Government.
Sounds like a GAAP Principle.
Cont…

24.
Cost Accounting Standards, Continued…
407 – Use of Standard Costs for Direct Material & Direct Labor
CAS 407 is to provide criteria:
1. under which standard costs may be used to estimating,
accumulating and reporting costs of direct material and direct
labor, and
2. relating to the establishment of standards, accumulation of
standard costs, and accumulation and disposition of variances
from standard costs.
Cont…

25.
Cost Accounting Standards, Continued…
407 – Use of Standard Costs for Direct Material & Direct Labor,
Continued…
Need to have a logical practice for the establishment of standards
that includes periodic review and update. Variances must be
reviewed & resolved.
Related to 401, if you use standard costs for estimating, you must use
them for accumulation and reporting. Variances must be accounted
for at the same level of detail.
Cont…

26.
Cost Accounting Standards, Continued…
408 – Accounting for Costs of Compensated Personal Absence
CAS 408 is to establish criteria for measuring and allocating the costs
of compensated personal absences to final cost objective. These
costs include compensation paid by contractors to their employees
for such benefits as vacation, sick leave, holiday, military leave, etc.
Expense must be assigned to period in which it is earned. If
employees earn PTO each pay period, then expense must be in the
same period, not when PTO is used.
Cont…

27.
Room Poll
The purpose of this cost accounting standard is to facilitate
the negotiation, audit, administration, and settlement of
contracts?
A. 403 – Allocation of Home Office Expenses to Segments
B. 405 – Accounting for Unallowable Costs
C. 406 – Cost Accounting Period
D. 408 – Accounting for Compensated Personal Absence

28.
Cost Accounting Standards, Continued…
409 – Depreciation of Tangible Capital Assets
CAS 409 provides criteria for assigning costs of
tangible capital assets to cost accounting
periods and should enhance objectivity and
consistency in their allocation.
Estimated residual values and service lives
(based on experience) must be determined for
all fixed assets.
Cont…

29.
Cost Accounting Standards, Continued…
410 – Allocation of Business Unit General and Administrative
Expenses to Final Cost Objectives
CAS 410 provides criteria for the allocation of general and
administrative (G&A) expenses to final cost objectives and furnishes
guidelines for the type of expense that should be included in the
G&A expense pool. It also establishes that G&A expense shall be
allocated on a cost input base that represents total activity.
Cont…

30.
Cost Accounting Standards, Continued…
410 – Allocation of Business Unit General and Administrative
Expenses to Final Cost Objectives, Continued…
G&A expenses must be incurred for managing and administering
the whole business unit and must be grouped in a separate cost
pool and allocated only to final cost objectives.
FAR 31.203(d) requires G&A expenses be allocated to final cost objectives through a
base that contains unallowable costs. Cont…

31.
Cost Accounting Standards, Continued…
411 – Accounting for Acquisition Costs of Material
CAS 411 provides criteria for the accounting of acquisition costs of
material, provides guidance on using inventory costing methods,
and improves the measurement and assignment of costs to cost
objectives.
Requires written policies and procedures (a given for all CAS), direct
items clearly identified, and insignificant items may be treated as
indirect.
Cont…

32.
Cost Accounting Standards, Continued…
412 – Composition and Measurement of Pension Costs
CAS 412 establishes the composition of pension costs, the basis of
measurement, and the criteria for assigning pension costs to cost
accounting periods. CAS 413 addresses the accounting treatment of
actuarial gains and losses and the allocation of pension costs to
segments of an organization.
Cont…

33.
Cost Accounting Standards, Continued…
412 – Composition and Measurement of Pension Costs, Continued…
Think primarily defined benefit plans which require complex
actuarial calculations for sufficient funding of benefits. While ERISA
deals primarily with the funding aspect, CAS 412 deals with the cost
accounting treatment.
FAR 31.205-6(j)(1) makes CAS 412 applicable to all contracts, even contracts which are
not CAS-covered or subject only to modified CAS-coverage. Auditors should ensure that
proposed or claimed pension costs, where significant, are in compliance with the
provisions of CAS 412. Cont…

34.
Room Poll
In which CAS does it state that G&A expenses must be incurred for
managing and administering the whole business unit and must be
grouped in a separate cost pool and allocated only to final cost
objectives?
A. 409 – Depreciation of Tangible Assets
B. 410 – Allocation of Business Unit General and Administrative Expenses
to Final Cost Objectives
C. 411 – Accounting for Acquisition Costs of Material
D. 412 – Composition and Measurement of Pension Costs

35.
Cost Accounting Standards, Continued…
413 – Adjustment and Allocation of Pension Cost
CAS 413 establishes criteria for:
1. assigning actuarial gains and losses to
cost accounting periods,
2. valuing pension fund assets, and
3. allocating pension costs to segments.
Cont…

36.
Cost Accounting Standards, Continued…
413 – Adjustment and Allocation of Pension Cost, Continued..
Provisions in the standard are somewhat more stringent than ERISA
requirements, concerning frequency of actuarial valuations and
methods of valuing pension fund assets. Consequently, some
accounting changes may be required for compliance with the
standard in addition to those previously made to comply with ERISA.
FAR 31.205-6(j)(1) makes CAS 413 applicable to all contracts, even contracts which are
not CAS-covered or are subject only to modified CAS-coverage. Auditors should ensure
that proposed or claimed pension costs, where significant, are in compliance with the
provisions of CAS 413.
Cont…

37.
Cost Accounting Standards, Continued…
414 – Cost of Money as an Element of the Cost of Facilities Capital
CAS 414 recognizes the cost of facilities capital as a contract cost. It
provides criteria for measuring and allocating an appropriate share
of the cost of money which can be identified with the facilities
employed in a business.
Only applies to facilities that are being depreciated, not to those
allocated based on usage.
Cont…

38.
Cost Accounting Standards, Continued…
414 – Cost of Money as an Element of the Cost of Facilities Capital,
Continued…
The cost of money is an imputed cost, which is identified with the
total facilities capital associated with each indirect cost pool, and is
allocated to contracts over the same base used to allocate the other
expenses included in the cost pool.
Check out our Cost of Money Calculator
Cont…

39.
Room Poll
CAS 413 – Adjustment and Allocation of Pension Cost,
establishes criteria for all of the following except?
A. Assigning actuarial gains and losses to cost accounting periods
B. Valuing pension fund assets
C. Measuring deferred compensation costs
D. Allocating pension costs to segments

40.
Cost Accounting Standards, Continued…
415 – Accounting for the Cost of Deferred Compensation
The purpose of CAS 415 is to provide criteria for measuring deferred
compensation costs and assigning those costs to cost accounting
periods. It applies to all deferred compensation costs except for
compensated absences and pension costs covered in CAS 408 and
CAS 412.
Cont…

41.
Cost Accounting Standards, Continued…
415 – Accounting for the Cost of Deferred Compensation,
Continued…
Deferred compensation costs are measured by the present value of future
benefits to be paid and are assigned to the cost accounting period in which
the contractor becomes obligated to compensate the employee.
Think stock options or similar plans typically found in more complex
organizations.
FAR 31.205-6(k) makes CAS 415 applicable to all contracts, even contracts which are not
CAS-covered or subject only to modified CAS-coverage. Auditors should ensure that
proposed or claimed deferred compensation costs, where significant, are in compliance
with the provisions of CAS 415. Cont…

42.
Cost Accounting Standards, Continued…
416 – Accounting for Insurance Cost
CAS 416 provides criteria for the measurement of insurance costs,
the assignment of such costs to cost accounting periods, and their
allocation to cost objectives.
CAS 416 covers accounting for purchased insurance, self-insurance,
and payments to a trustee of an insurance fund.
Cont…

43.
Cost Accounting Standards, Continued…
416 – Accounting for Insurance Cost, Continued…
Think primarily self-insurance costs which involve estimates and the
reconciliation of actual losses, dividends, etc.
FAR 31.205-19 makes the self-insurance provisions of CAS 416 applicable to
all contracts, even contracts that are not CAS-covered or subject only to modified
CAS coverage. Auditors should ensure that proposed or claimed insurance costs,
where significant, comply with the provisions of CAS 416. Cont…

44.
Cost Accounting Standards, Continued…
418 – Allocation of Direct and Indirect Costs
CAS 418 requires the consistent classification of costs as direct or
indirect, establishes criteria for accumulating indirect costs in indirect
cost pools, and provides guidance on allocating indirect cost pools.
Requires homogenous pools (only the same type of costs) and a
logical causal-beneficial relationship between pool and base.
Note: this is where I struggle with AASHTO guidelines for A/E firms to use only
direct labor as the base for Fringe and a single General Overhead.
Cont…

45.
Cost Accounting Standards, Continued…
419 – Reserved
Cont…

46.
Cost Accounting Standards, Continued…
420 – Accounting for Independent Research and Development Costs
and Bid and Proposal Costs (IR&D and B&P)
This standard provides criteria for the accumulation of IR&D/B&P costs
and for the allocation of such costs to cost objectives.
Should be accumulated by project: separate charge code for each effort.
FAR 31.205-18 makes CAS 420 partially applicable to all contracts, even contracts that are
not CAS-covered or subject only to modified CAS-coverage. Auditors should ensure that
proposed or claimed IR&D/B&P costs, where significant, are in compliance with the
provisions of CAS 420.

47.
Room Poll
In CAS 415 – Accounting for the Cost Deferred Compensation,
deferred compensation costs are measured by the future
value of present benefits to be paid?
A. True
B. False

48.
CAS Applicability

49.
Types of CAS Coverage
Full
Full coverage requires that the business unit comply with all of the CAS
specified in part 9904 that are in effect on the date of the contract award
and with any CAS that become applicable because of the later award of
a CAS-covered contract. Full coverage applies to contractor business
units that-
1. Receive a single CAS-covered contract award of $50 million or more;
or
2. Received $50 million or more in net CAS-covered awards during its
preceding cost accounting period.
Cont…

50.
Types of CAS Coverage, Continued…
Modified
Modified CAS coverage requires only that the contractor comply with-
1. 401 Consistency in Estimating, Accumulating and Reporting Costs
2. 402 Consistency in Allocating Costs Incurred for the Same Purpose
3. 405 Accounting for Unallowable Costs
4. 406 Cost Accounting Standard – Cost Accounting Period
Modified, rather than full, CAS coverage may be applied to a covered
contract of less than $5 million awarded to a business unit that received
less than $50 million in net CAS-covered awards in the immediately
preceding cost accounting period. Cont…

51.
Types of CAS Coverage, Continued…
Modified, Continued…
If any one contract is awarded with modified CAS coverage, all CAS-
covered contracts awarded to that business unit during that cost
accounting period must also have modified coverage with
limited exception.
A contract awarded with modified CAS coverage shall remain subject to
such coverage throughout its life regardless of changes in the business
unit's CAS status during subsequent cost accounting periods.
Cont…

52.
Types of CAS Coverage, Continued…
Educational Institutions
Coverage for educational institutions requires that the business unit
comply with all of the CAS specified in part 9905 that are in effect on
the date of the contract award and with any CAS that become
applicable because of later award of a CAS-covered contract.

53.
CAS Exemptions
• Sealed bid
• Negotiated contracts less than
TINA/TCPD
• Small businesses
• Foreign governments
• Price set by law or regulation
• Commercial items
Cont…

54.
CAS Exemptions, Continued…
• Contracts or subcontracts of less than $7.5 million, provided
that, at the time of award, the business unit of the contractor or
subcontractor is not currently performing any CAS-covered
contracts or subcontracts valued at $7.5 million or greater
• Subcontractors under the NATO PHM Ship program to be
performed outside the United States by a foreign concern
• Firm-fixed-price contracts or subcontracts awarded on the basis
of adequate price competition without submission of certified
cost or pricing data.
Cont…

55.
Room Poll
Types of CAS Coverage Include-
A. Full
B. Modified
C. Educational
D. All of the above

56.
CAS Disclosure

57.
CAS Disclosure
General requirements for submission of a Disclosure Statement are:
1. Any business unit that is selected to receive a CAS-covered contract or
subcontract of $50 million or more, including option amounts.
2. Any company which, together with its segments received net CAS-
covered awards totaling more than $50 million in its most recent
accounting period.
3. When required, a separate Disclosure Statement must be submitted
for each segment having more than the Truthful Cost or Pricing Data
(TCPD) threshold of costs included in the total price of any CAS-
covered contract or subcontract.
Additional details and exceptions may apply.

58.
CAS Decision Tree
https://www.dcaa.mil/Portals/88/Docu
ments/Guidance/CAM/Chapter_08_-
_Cost_Accounting_Standards.pdf?ver=2
019-10-10-155312-227

59.
We recommend CAS compliance to all contractors even if a formal
disclosure statement is not required. Why?
1. CAS generally aligns with GAAP and prudent accounting principles.
2. Auditors will use CAS as a guideline in many audits even if a contract
is not CAS covered.
3. Some CAS apply to all contractors, even those without CAS covered
contracts, when such costs are significant (412, 413, 415, 416, 417
420).
4. Contractors usually trip the modified CAS coverage before full CAS,
so you might as well get a head start.
Best Practices

60.
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