Recent CAS Developments
Category: Articles
Several recent regulations issued by the Office of Federal Procurement Policy have impacted the Cost Accounting Standards (CAS). Presented below are two notable changes which contractors need to be aware of.
The first regulation affecting the CAS is an increase in the CAS applicability threshold from $650,000 to $700,000. The threshold was increased to keep pace with a corresponding increase in the Truth in Negotiations Act (TINA) threshold which was effective last October. Future increases in the CAS applicability threshold will be tied to any changes in the TINA threshold under an interim rule published by the CAS Board. The change in the applicability threshold is effective August 11, 2011.
The second recent change in the CAS is the elimination of the overseas exemption under 9903.201-1(b)(14), which previously exempted contracts to be executed and performed entirely outside the United States, its territories, and possessions. The elimination of this exemption was scheduled for implementation through the issuance of a final rule in the Federal Register on August 10, 2011.
Please contact Rubino & McGeehin for more information. Mr. Curtis can be reached at 301-564-3636, or at pcurtis@rubino.com.