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Bad News for Contractors: ASBCA Decision Bars Offsets of Simultaneous Accounting Changes Under FAR 30.606

Client Alert | 1 min read | 07.22.15

In Raytheon Co. (May 7, 2015), the ASBCA held that under FAR 30.606 contractors may not offset cost impacts from simultaneous accounting changes within the same business segment, which if not reversed on appeal will cause major disruptions when contractors make multiple changes in cost accounting practices made after 2005 (the date of the FAR change), effectively giving the government the benefit of decreased costs without offsetting them against increased costs of simultaneous accounting changes. The Board decision ignores the language of CAS 9903.306(b)-(c), which states that when there is a change in accounting practice the government should not pay more than the "contract costs, price, or profit" that "would have been agreed to" had the accounting changes been known, which would logically include all simultaneous changes, not just changes that decrease the costs.


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Client Alert | 7 min read | 06.26.26

Federal Roundup: Updates for PBMs and Medicare Advantage Organizations

In June 2026, federal regulators and lawmakers continued their efforts to improve drug affordability through targeted reforms. These recent developments will primarily impact pharmaceutical manufacturers, managed care organizations, and pharmacy benefit managers (PBM) serving Medicare Part D program members. PBMs, Medicare Advantage organizations, and Part D sponsors should monitor these changes in the interest of maintaining compliance and providing input on regulatory proposals that may influence their business operations or compensation structures in the future....