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DCMA Details Oversight of Counterfeit Electronic Parts

Client Alert | less than 1 min read | 08.04.15

On July 6, 2015, DCMA issued Instruction 1205 that provides the framework the government will use to assess compliance with DFARS 252.246-7007 (May 2014), which requires certain contractors to design and deploy systems to avoid and detect counterfeit electronic parts. The instruction assigns roles and responsibilities for DCMA functions, establishes a risk-based approach that will drive the types of oversight and surveillance contractors can generally expect, and details the reporting that may occur if counterfeit materials or suspected counterfeit materials are identified.


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Client Alert | 1 min read | 07.08.26

CAS Board Publishes Final Rule Rescinding CAS 404, 408, 409, and 4117

As part of its ongoing effort to conform the Cost Accounting Standards (“CAS”) to generally accepted accounting principles (“GAAP”), the CAS Board published a final rule rescinding CAS 408 (Accounting for costs of compensated personal absence) and CAS 411 (Accounting for acquisition costs of material).  The CAS Board also rescinded CAS 404 (Capitalization of tangible assets) and CAS 409 (Depreciation of tangible capital assets) but retained certain requirements of CAS 404 and 409, which will be located in new paragraphs of CAS 405 (Accounting for unallowable costs).  Specifically, the CAS Board retained the requirements currently located at CAS 404-50(d)(1), CAS 409-50(e)(5), CAS 409-50(j)(1), and CAS 409-50(j)(4), which the CAS Board explained are necessary to protect the Government’s interests.  Otherwise, the CAS Board determined that the requirements of CAS 404, 408, 409, and 411 overlapped with GAAP such that GAAP “may be applied reasonably as a substitute for CAS to support contract cost and pricing.”...

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