Government Contracting - FAR Supplements - FAR Chapter 99 CAS

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1/12/22 – FAR
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2/2/22 – DPGI
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2/16/22 – AIR FORCE
2/23/22 – DISA
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8/10/22 – NRC
8/17/22 – DOT
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8/24/22 – VA

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1/12/22 – N/A
1/19/22 – N/A
1/28/22 – DOD
2/2/22 – N/A
2/11/22 – ARMY
2/18/22 – AIR FORCE
2/25/22 – DISA
3/4/22 – DLA
3/11/22 – USMC-NAVY
3/18/22 - SPECIAL OPS
3/25/22 -TRANS COMMAND
4/1/22 – AGRICULTURE
4/8/22 – AIDAR
4/15/22 – DOC
4/22/22 – DOE
4/29/22 – DOI
5/6/22 – DOL
5/13/22 – DOS
5/20/22 – DOT (Treasury)
5/27/22 – DOEd
6/3/22 – EPA
6/10/22 – FEHB
6/17/22 – GSA
6/24/22 – HHS
7/1/22 – DHS
7/8/22 – HUD
7/15/22 – BBG
7/22/22 – DOJ
7/29/22 – OPM
8/5/22 – NASA
8/12/22 – NRC
8/19/22 – DOT
(Transportation)
8/26/22 – VA

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2022 – FAR DEPARTMENT SUPPLEMENT – FAR CHAPTER 99
CAS
Date: Wednesday, January 19, 2022
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SPEAKER
INSERT YOUR
LOGO HERE
2022 – FAR DEPARTMENT SUPPLEMENT – FAR CHAPTER 99 CAS
MEET OUR SPEAKER
Ryan Koenitzer
RKI
rkoenitzer@rkiaccounting.com
(617) 413 – 5438
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FAR CHAPTER 99 CAS
Cost Accounting Standards
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AGENDA
 CAS Overview
 CAS Applicability
 CAS (Standards)
 CASB DS-1
 Changes to Cost Accounting Practice
 Best Practice Tips
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CAS OVERVIEW
Key Application and Purpose:
 CAS provides consistency in definition and application of cost accounting practices
 CAS is current public law and requires compliance with established criteria and guidance
 CAS is divided into 19 standards (CAS 401 through CAS 420)
 Adherence to applicable CAS standards applies throughout the entire life of a CAS-covered contract
Why is CAS needed? To protect U.S. Government’s price and cost participation interests
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CAS OVERVIEW
CAS Requirements & Implications:
 Most standards are already required by FAR
 CAS trigger increases EXPOSURE AND DISCLOSURE
 Cost impacts may be required when changes to established cost accounting practices occur
 Exemptions to CAS exist (e.g., contract awarded to small businesses; FFP contract for commercial item(s);
FFP awarded on basis of adequate price competition without submission of cost or pricing data)
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CAS APPLICABILITY:
 CAS is applicable to negotiated contracts greater than $2M, unless the contract meets one of the following
exemptions:
̶ Contract is less than $7.5M and the Contractor is not currently performing under any
CAS-covered contracts of $7.5M or greater at the time of award
̶ Award is firm-fixed price (FFP) contract for commercial item(s)
̶ Price is set by law or regulation
̶ Contract is awarded under sealed bid procedures
̶ Contract is awarded to a small business
̶ FFP contract awarded on the basis of adequate price competition without submission of cost or pricing data
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CAS APPLICABILITY
Full vs. Modified CAS-Coverage:
Full CAS-Coverage
 Requires compliance with all CAS standards
 Full CAS-coverage is triggered when:
̶ Contractor receives a CAS-covered award over $50M in current cost accounting period, or
̶ Contractor received over $50M in CAS-covered awards in previous cost accounting period
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cas
CAS APPLICABILITY
Full vs. Modified CAS-Coverage:
Modified CAS-Coverage
 Requires compliance with CAS 401, 402, 405, 406
 Modified CAS-coverage is triggered when:
̶ Contractor receives a CAS-covered contract greater than $7.5M but less than $50M in current cost accounting
period
Foreign Concerns
 Requires compliance with CAS 401 and, 402
Reference: CON 252 CAS Flowchart (FULL)_PDF (dau.edu)
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• Individual standards set forth how direct and indirect costs should be accounted
for:
• Measurement
• Assignment
• Allocation
• Key requirement is consistency

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Standard No. Standard Title
CAS 401 Consistency in Estimating, Accumulating, and Reporting Costs
CAS 402 Consistency in Allocating Costs Incurred for the Same Purpose
CAS 403 Allocation of Home Office Expenses to Segments
CAS 404 Capitalization of Tangible Assets
CAS 405 Accounting for Unallowable Costs
CAS 406 Cost Accounting Period
CAS 407 Use of Standard Costs for Direct Material and Direct Labor
CAS 408 Accounting for Costs of Compensated Personal Absence

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CAS 409 Depreciation of Tangible Capital Assets
CAS 410
Allocation of Business Unit General and Administrative Expenses to Final
Cost Objectives
CAS 411 Accounting for Acquisition Costs of Material
CAS 412 Composition and Measurement of Pension Cost
CAS 413 Adjustment and Allocation of Pension Cost
CAS 414 Cost of Money as an Element of the Cost of Facilities Capital
CAS 415 Accounting for the Cost of Deferred Compensation
CAS 416 Accounting for Insurance Costs

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CAS 417
Cost of Money as an Element of the Cost of Capital Assets Under
Construction
CAS 418 Allocation of Direct and Indirect Costs
CAS 419 (Reserved)
CAS 420 Accounting for IR&D and B&P Costs

CASB DS-1 Disclosure Statement
 USG form that discloses a Contractor’s cost accounting practices and procedures
 Purpose is to provide consistency in reporting of costs
 Disclosure Statement required to be submitted by:
̶ A Business Unit selected to receive CAS-covered contract or
subcontract estimated to exceed $50M, including options
̶ Any company which, together with its business segments (as defined in CAS 410-30(a)(7)),
received net CAS-covered awards totaling more than $50M in most recent cost accounting period.
̶ Any CAS Home Office that allocates costs to one or more disclosing segments performing CAS-covered
contracts
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CHANGES TO COST ACCOUNTING PRACTICES
FAR 30.302-1:
Definition – A cost accounting practice is any disclosed or established accounting method or technique
which is used for:
Allocation of cost to cost objectives,
Assignment of cost to cost accounting periods, or
Measurement of costs.
• Changes to cost accounting must be disclosed to the USG
• USG may – and typically does - request an assessment of the related cost impact of the proposed accounting
change
• Cost impacts only required under CAS covered awards
• USG provides COs wide latitude for settling cost impacts
• USG will not pay increased cost, in the aggregate, as a result of a change in cost accounting practice
• Applies to FFP and Cost-Type contracts
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Types of changes in cost accounting practice:
1. Unilateral - Change from one compliant practice to another compliant practice
that a contractor elects to make, but that the Government has not determined to
be desirable
2. Desirable - Contractor elects to make a change from one compliant practice to
another, and the Government determines that the change not detrimental to the
Government (e.g., increased cost)
3. Non-Compliance - Contractor fails to comply with an applicable CAS; or
Contractor fails to consistently follow any disclosed or established cost
accounting practice
Changes require disclosure to CO 60 days in advance
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Best Practice Tips
• Know precisely when you “trigger” CAS
• Perform an analysis of your cost accounting practices against applicable
Standards and monitor
• Maintain a current list of CAS covered awards, specifically identifying modified
and full applicability of coverage
• Know what a ‘change in cost accounting practice’ is
• Consider cost accounting practices when making organizational decisions
including re-organizations, consolidations, and M&A
• Understand the rules
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SPEAKER
INSERT YOUR
LOGO HERE
THANK YOU TO OUR SPEAKER
Ryan Koenitzer
RKI
rkoenitzer@rkiaccounting.com
(617) 413 – 5438
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THANK YOU FOR ATTENDING!
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