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CAS Board Adjusts Coverage Threshold

Client Alert | less than 1 min read | 06.14.07

The Cost Accounting Standards Board issued a final rule, effective June 14, 2007, adjusting the $500,000 threshold for contract coverage upward to $650,000 to be consistent with the threshold in the Truth in Negotiations Act (72 Fed. Reg. 32809). Apparently in response to comments from the Project on Government Oversight (POGO), the final rule (unlike the proposed rule published on December 15, 2005) does not increase the other CAS thresholds – such as the $7.5M “trigger” contract threshold and the $50M threshold for “full” CAS coverage and submission of a Disclosure Statement – because the CAS Board has determined that these are not “acquisition-related dollar thresholds” required to be adjusted for inflation under the FY05 Defense Authorization Act.

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Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....

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