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Barry McVay's FEDERAL CONTRACTS DISPATCH

DATE: August 9, 2000

FROM: Barry McVay, CPCM

SUBJECT: Cost Accounting Standards Board; Comprehensive Review of Cost Accounting Standards (CAS)

SOURCE: Federal Register, August 9, 2000, Vol. 65, No. 154, page 48738

AGENCIES: Cost Accounting Standards Board (CASB), Office of Federal Procurement Policy (OFPP), Office of Management and Budget (OMB)

ACTION: Notice

SYNOPSIS: The CASB is inviting public comments on how it should perform its comprehensive review of the CAS and the attendant requirements.

EDITOR'S NOTE: The CAS are 19 standards which apply to large contractors performing large contracts. They are in Chapter 99 of Title 48 of the Code of Federal Regulations, and are included as an appendix to the paper-version of the Federal Acquisition Regulation (FAR) for information purposes. The CAS are available on the Internet at http://www.arnet.gov/far/97/html/appendix.html.

On August 4, 2000, the Department of Defense announced that it will hold public meetings on August 23 and 24, 2000, to discuss CAS administration issues and possible CAS streamlining. For more on the announcement, see today's FEDERAL CONTRACTS DISPATCH "Department of Defense; Public Meetings on Cost Accounting Standards (CAS) Administration and Streamlining."

DATES: Comments must be submitted no later than September 25, 2000.

ADDRESS: Send comments to Rudolph J. Schuhbauer, Project Director, Cost Accounting Standards Board, Office of Federal Procurement Policy, 725 17th Street, NW, Room 9013, Washington, DC 20503, Attn: CASB Docket No. 00-02. Include with the written comments a 3.5" computer diskette copy of the comments and denote the word processing format used.

FOR FURTHER INFORMATION CONTACT: Mr. Rudolph J. Schuhbauer, Project Director, CASB, 202-395-3254.

SUPPLEMENTAL INFORMATION: 41 U.S.C. 422 gives the CASB the "exclusive authority to make, promulgate, amend, and rescind cost accounting standards and interpretations thereof...", and to promulgate appropriate rules and regulations to implement the CAS. Such regulations must require contractors and subcontractors to (1) disclose their cost accounting practices, including the methods of distinguishing direct costs from indirect costs and the basis for allocating indirect costs, and (2) agree to a contract price adjustment, with interest, for any increased costs paid to such contractor or subcontractor due to a change in cost accounting practices or failure to comply with applicable CAS.

The CASB has on its agenda a comprehensive review of CAS and its attendant requirements. The CASB is requesting the views of interested parties with respect to the particular CAS items they believe may require modification, issuance of an interpretation, or recision. Those wishing to submit specific items for possible inclusion in CASB's comprehensive review are to use the following format:

Items submitted by the public and federal agencies will be considered in the development of a detailed plan for the conduct of the comprehensive review. After the CASB reviews the comments, it will schedule a public meeting to discuss its detailed plan for accomplishing the comprehensive review. The date, time, and location of the meeting will be in a separate notice.

FOR FURTHER INFORMATION CONTACT: Barry McVay at 703-451-5953 or by e-mail to BarryMcVay@FedGovContracts.com.

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