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SBA’s July 2013 Small Business Subcontracting Revisions Finally Implemented in the FAR

Client Alert | less than 1 min read | 07.21.16

On July 14, 2016, DoD, GSA, and NASA published a final rule implementing numerous updates to the FAR to account for regulatory changes affecting the small business subcontracting requirements made by the SBA dating back to July 2013. These changes, which become effective November 1, 2016, range from requiring prime contractors to assign NAICS codes to subcontracts, to providing contracting officers the discretion to establish subcontracting goals at the order level of IDIQ contracts, to protecting subcontractors’ ability to discuss payment or utilization matters with the contracting officer.

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  The CAS Board also rescinded CAS 404 (Capitalization of tangible assets) and CAS 409 (Depreciation of tangible capital assets) but retained certain requirements of CAS 404 and 409, which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