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Deliver Uncompromised – or Else? DoD Considers Elevating Security in its Procurement Process

Client Alert | 1 min read | 08.14.18

Contractors may soon need to recalibrate their approach to DoD procurements. The Department recently announced that it is reviewing a strategy dubbed “Deliver Uncompromised,” which lays out recommendations for how it can better secure its vast and varied supply chain. Central to the strategy is an increased focus on security in the procurement process. A contractor’s overall security would join cost, performance, and schedule as key evaluation pillars – marking a significant shift in how contractors compete for work. The strategy recognizes, however, that its success would likely require increased incentives for the contracting community to invest in risk mitigation, including liability protections and tax incentives. Although only a proposal for now, the strategy is yet another indicator of the government’s broader emphasis on supply chain security. Just yesterday, the National Defense Authorization Act for Fiscal Year 2019 was signed into law in record time, with several provisions focused on the same issue.  

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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  The CAS Board also rescinded CAS 404 (Capitalization of tangible assets) and CAS 409 (Depreciation of tangible capital assets) but retained certain requirements of CAS 404 and 409, which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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