OMB Seeks to Jettison Defense CAS Board and De-Couple CAS and TINA
Client Alert | 1 min read | 06.07.19
In late April, the Office of Management and Budget (OMB) sent a letter to Congress containing a number of legislative proposals to streamline and improve the federal acquisition process for inclusion in the Fiscal Year (FY) 2020 National Defense Authorization Act (NDAA). Two of those proposals relate to the Cost Accounting Standards (CAS). The first calls for the disestablishment of the Defense CAS Board—which was a product of the FY 2017 NDAA—to avoid creating a more complicated CAS regulatory framework. The second would de-link the monetary threshold for CAS from the Truthful Cost or Pricing Data threshold (formerly known as TINA), and increase the basic threshold for CAS applicability from $2 million to $15 million. These are two recommendations that the Section 809 Panel made in Volume II of its Report (the CAS Board is also considering repeal of the provisions establishing the Defense CAS Board and increasing the CAS applicability thresholds).
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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 The CAS Board also rescinded CAS 404 (Capitalization of tangible assets) and CAS 409 (Depreciation of tangible capital assets) but retained certain requirements of CAS 404 and 409, which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.”
Client Alert | 1 min read | 07.08.26
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Client Alert | 7 min read | 07.08.26
Illinois Imposes Transparency and Safety Obligations on Frontier AI Systems
Client Alert | 10 min read | 07.08.26
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