Updating cas disclosure statements
The third situation is where the contractor has not complied with either its disclosed accounting practices or the requirements of the CAS. However, there are no hard and fast guides. Practice Changes A cost accounting practice change is any alteration in any cost accounting practice whether or not it is described in the Disclosure Statement. The amount of fixed costs recovered in settlement for a delay will need to be credited to the appropriate cost pools for the year in which the event occurred in order to avoid double recovery. First there is the "adequacy" determination and secondly, the "compliance" determination. Consequently, contractors should be ever vigilant that their actual accounting practices are the same as their disclosed accounting practices. Contractors should be aware that although the form contains many choices from which to choose, they are not all compliant with the CAS. In these instances, make as many copies of the provided continuation sheet as needed. Any amendments and revisions must be submitted in the same manner.
Full coverage requires the contractor to comply with all 19 standards during the performance of the contract. Although it may take a while, completing the CASB DS-1 correctly the first time will save you time and money in the future. Deferred Compensation and Insurance Cost For this section, you may need to consult with your human resources department as well as your accounting records. In these instances, make as many copies of the provided continuation sheet as needed. Contractors should be aware that although the form contains many choices from which to choose, they are not all compliant with the CAS. The cost impact is measured as the difference between the allocated costs under one cost accounting practice versus another, such as a compliant practice versus a noncompliant practice. Thus, while the criteria for CAS coverage are dependent on the business volume for a particular segment, the criteria for Disclosure Statements is company-wide and considers all business segments. Although the Disclosure Statement form itself appears ominous at first, its purpose is fairly straight-forward. If you missed that post, click here to read. In addition, contractors should also be aware that the government's acceptance of a contractor's Disclosure Statement means nothing. For example, the form permits the selection of cost of sales as the allocation base for General and Administrative expenses; however, such a practice is not compliant with CAS , Allocation of Business Unit General and Administrative Expenses to Final Cost Objectives. Posted by Paul D. Only in the second situation can the cost impact result in the government paying increased costs to the contractor. Using sealed bid procedures; That are not in excess of the Truth in Negotiations Act TINA threshold; Small businesses; When the price is set by law or regulation; Firm fixed price, fixed price with economic price adjustment other than cost, time and material or labor hour contracts for commercial items; As firm fixed price contracts awarded with adequate price competition without the submission of any cost data; With foreign governments or their agents or instrumentalities; To a foreign concern except for and which remain applicable; To a United Kingdom contractor for performance substantially in the United Kingdom provided that the contractor has filed a completed Disclosure Statement with the Ministry of Defense; To subcontractors under the NATO PHM Ship Program to be performed by a foreign concern; and For performance entirely outside the United States, its territories, and possessions. Second, the revision of a cost accounting practice for a cost which had previously been immaterial is not a change in accounting practice. Contract Changes and Terminations Contract modifications as a result of scope or quantity can introduce some interesting challenges for CAS covered contracts. Thus, even if the practice change resulted in increased costs being allocated to future government contracts, the change was to be accepted by the government if it satisfied both the test of adequacy and compliance. If referencing a written accounting policy that you have already submitted in your Preaward Survey , a copy of the relevant portion of the document may be submitted as appendices to the relevant part. Although there are contract clauses that actually impose the CAS, these clauses are required by statute. The ACO then makes a determination whether or not the Disclosure Statement adequately describes of contractor's accounting practices. But such an attitude is very short-sighted. Depreciation method Property units Residual value Then, mark whether the listed items are expensed or capitalized, how gains and losses on dispositions are treated, the criteria for capitalization and if there are group or mass purchases. Otherwise, they will be required to compute cost impact proposals for failing to comply with the standards or their Disclosure Statements and refund any monies obtained as a result of their failure. Under the recodified rules, however, a contractor's ability to change its cost accounting practices has been significantly impaired. After all, such a circumstance could be interpreted by some as being "detrimental to the interest of the government. The determination of amounts paid or a change in amounts paid for a unit of goods and services is not a cost accounting practice.
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