Substantial Changes To CAS Administration Regulations
Client Alert | 1 min read | 03.16.05
Final rules, effective April 8, 2005, concerning proposed changes to CAS administration requirements that have been pending since April 2000 were promulgated on March 9, 2005 (70 Fed. Reg. 11743-61). The new regulations will be discussed in detail at the upcoming OOPS/WOOPS programs on March 31-April 1/April 14-15, but some of the highlights include:
- When there is a CAS noncompliance, contract price adjustments may be required for closed contracts and closed years,
- Improvement in the definition of "desirable" and "required" changes may permit contractors to avoid price adjustments,
- Retroactive accounting changes are permitted in limited circumstances,
- Widely criticized proposals to prohibit offsets between FFP and flexibly-priced contracts were abandoned, and
- Estimates to complete rather than original cost estimates must be used to determine cost impact on FFP contracts.
Insights
Client Alert | 10 min read | 07.03.25
The Orders represent FinCEN’s first actions using new special measures authority under the Fentanyl Sanctions Act and FEND Off Fentanyl Act of 2024 (codified at 21 U.S.C. § 2313a) (the “Fentanyl Act”) and continue the Trump Administration’s broader efforts against transnational cartels and narcotics trafficking.
Client Alert | 4 min read | 07.02.25
Client Alert | 4 min read | 07.02.25
