CAS Exemption For Time & Material And Labor Hour Contracts
Client Alert | less than 1 min read | 07.06.07
To conform the Cost Accounting Standards regulations to the statutory provisions of the Services Acquisition Reform Act and to the recently amended provisions of the FAR, the CAS Board has issued regulations (72 Fed. Reg. 36367, July 3, 2007) exempting Time and Material (T&M) and Labor Hour (LH) contracts for commercial items from CAS coverage. Because the comparable FAR provisions require competition as a prerequisite to award of T&M and LH contracts for commercial items, the CAS exemption will apply only to competitively awarded contracts.
Insights
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GAO Indicates Reasonable Conflict of Interest Investigation Must Include Inquiry of Involved Firm
The U.S. Government Accountability Office’s (GAO) recent decision in Viderity Inc.—Costs, B-424422.5, Sept. 1, 2026, offers useful insight into what constitutes a legally sufficient conflict of interest investigation. The decision arose in an unusual procedural posture: Viderity initially protested, alleging that an agency evaluator had a personal conflict of interest. After the agency took corrective action, Viderity filed a cost entitlement claim requesting that GAO direct the agency to reimburse Viderity’s protest costs. In evaluating that claim, GAO assessed whether Viderity’s underlying protest ground was “clearly meritorious.”
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