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CAS Coverage And Indirect Costs

Client Alert | 1 min read | 03.31.06

A previous Bullet Point addressed a recent decision, AM General LLC, in which the ASBCA decided that a contract awarded pursuant to a partial waiver of the Truth in Negotiations Act was nevertheless covered by the Cost Accounting Standards and adopted a “benefit” test for determining the homogeneity of indirect cost pools under CAS 418. In their article entitled “Practitioner's Comment: “Benefit” Test for CAS 418 Homogeneity,” published in the March 8, 2006, Thomson West The Government Contractor (http://www.crowell.com/pdf/newsroom/GovtContractor_March06.pdf), Terry Albertson and Linda Bruggeman discuss both the legal and practical problems with the Board's CAS 418 analysis as well as the legal issues presented by the CAS Board's lengthy delay in implementing the CAS exemptions in FASA and FARA.

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Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....

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