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Barry McVay's FEDERAL CONTRACTS DISPATCH

DATE: August 16, 2000

FROM: Barry McVay, CPCM

SUBJECT: Department of Defense; Public Meetings on Cost Accounting Standards (CAS) Streamlining

SOURCE: Defense Cost, Pricing and Finance Directorate Web Page at http://www.acq.osd.mil/dp/cpf, August 11, 2000.

AGENCIES: Department of Defense (DOD)

ACTION: Notice of Public Meetings

SYNOPSIS: The Office of the Director of Defense Procurement, which had announced it would hold a public meeting on August 23, 2000, to discuss possible CAS streamlining, and a public meeting on August 24, 2000, to discuss the April 18, 2000, proposed Federal Acquisition Regulation (FAR) rule on CAS administration, will now dedicate both meetings to discuss CAS streamlining. This change was made because the Cost Accounting Standards Board (CASB) has set September 25, 2000, as the deadline for comments on CAS streamlining. Also, CAS streamlining meetings will be held three days a week (Tuesday, Wednesday, and Thursday) beginning the week of August 29.

The meeting on the proposed FAR Part 30 rule is rescheduled for September 26, 2000.

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

For more on the CASB request for public comments on how is should conduct its comprehensive review of the CAS and the attendant requirements, see the August 9, 2000, FEDERAL CONTRACTS DISPATCH "Cost Accounting Standards Board; Comprehensive Review of Cost Accounting Standards (CAS)."

For more on the original announcement of the August 23 and 24, 2000, meetings, see the August 9, 2000, FEDERAL CONTRACTS DISPATCH "Department of Defense; Public Meetings on Cost Accounting Standards (CAS) Administration and Streamlining."

For more on the proposed FAR rule on CAS administration, see the April 18, 2000, FEDERAL CONTRACTS DISPATCH "Federal Acquisition Regulation (FAR); Cost Accounting Standards Administration."

DATES: The meetings to discuss potential CAS streamlining will be held August 23 and 24, 2000, from 9:00 a.m. to 4:00 p.m. at the National Contract Management Association (NCMA) headquarters. The meeting to discuss the proposed FAR rule, that was to be held August 24, 2000, has been rescheduled for September 26, 2000, from 9:00 a.m. to 4:00 p.m. at NCMA. The dates and times of subsequent public meetings will be published by the Defense Office of Cost, Pricing, and Finance at http://www.acq.osd.mil/dp/cpf.

ADDRESSES: The meetings will be held at the NCMA, 1912 Woodford Drive, Vienna, VA 22182. Directions may be found on the Internet at http://www.acq.osd.mil/dp/cpf/ncmadir.doc.

FOR FURTHER INFORMATION CONTACT: Mr. David Capitano, Office of Cost, Pricing, and Finance, 703-695-9764, fax: 703-693-9616, e-mail: capitadj@acq.osd.mil.

SUPPLEMENTAL INFORMATION: On April 18, 2000, a proposed rule was published that would amend FAR Subpart 30.6, CAS Administration, to more clearly and completely explain the cost-impact process that the government and contractor must follow when a contractor makes a compliant change to a cost accounting practice or follows a noncompliant practice.

The Director of Defense Procurement wanted to hear the views of interested parties on what they believe to be the key issues pertaining to the proposed rule, so the Director held a meeting on August 2, and scheduled another meeting on August 24 to further discuss the issues brought up at the August 2 meeting.

In addition, the Director held a meeting on August 3 to hear the views of interested parties regarding possible CAS streamlining (such as elimination, revision, and/or amendment of one or more CAS), and scheduled another meeting on August 23 to further discuss the CAS identified for streamlining (the list of CAS is at http://www.acq.osd.mil/dp/cpf/casstreamliningaugust3.doc).

However, on August 9, the CASB invited the public to comment on how it should proceed with its own comprehensive review of the CAS, since it has the "exclusive authority to make, promulgate, amend, and rescind cost accounting standards and interpretations." The CASB announced that comments must be received by September 25, 2000.

To be able to develop and submit its comments and recommendations to the CASB by the September 25, 2000, deadline, the Director has decided to dedicate the August 24 meeting to CAS streamlining and postpone the meeting on the April 18, 2000, proposed FAR Part 30 rule until September 26, 2000. Also, because of the short deadline, the Director has decided to hold meetings on Tuesdays, Wednesdays, and Thursdays between August 29 and September 21 to prepare the CAS streamlining comments. The announcement on the Defense Cost, Pricing and Finance Directorate Web Page at http://www.acq.osd.mil/dp/cpf states that "it would be extremely helpful if interested parties would draft some proposed language for any particular part or parts they believe should be modified or rescinded."

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

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