Cost Accounting Standards (CAS)

Cost Accounting Standards are a set of 19 standards and rules promulgated by the United States Government for use in determining costs on negotiated procurements. CAS differs from the Federal Acquisition Regulation in that FAR applies to substantially all contractors, whereas CAS applies primarily to the larger ones.^[1]

There are 19 accounting standards, as set by the Cost Accounting Standards Board. They are:^[2]
1. Consistency in estimating, accumulating, and reporting costs.
2. Consistency in allocating costs incurred for the same purpose.
3. Allocation of home office expenses to segments.
4. Capitalization of tangible assets.
5. Accounting for unallowable costs.
6. Cost accounting period.
7.Use of standard costs for direct material and direct labor.
8. Accounting for compensated personal absence.
9. Depreciation of tangible capital assets.
10. Allocation of business unit general and administrative expenses to final cost objectives.
11. Accounting for acquisition costs of material.
12. Composition and measurement of pension costs.
13. Adjustment and allocation of pension costs.
14. Cost of money as an element of the cost of facilities capital.
15. Accounting for the cost of deferred compensation.
16. Accounting for insurance costs.
17. Cost of money as an element of the cost of capital assets under construction.
18. Allocation of direct and indirect costs.
19. Accounting for independent research and development costs and bid and proposal costs.

CAS Exemptions^[3]
The following categories of contracts and subcontracts are exempt from all CAS requirements (48 CFR 9903.201-1):
a. Sealed bid contracts.
b. Negotiated contracts and subcontracts (including interdivisional work orders) less than the Truth in Negotiations Act (TINA) threshold.
c. Contracts and subcontracts with small businesses. FAR Subpart 19.3 addresses determination of status as a small business. A small business (offeror) is one which represents, through a written self-certification, that it is a small business concern in connection with a specific solicitation and has not been determined by the Small Business Administration (SBA) to be other than a small business. The contracting officer accepts an offeror's representation unless that representation is challenged or questioned. If the status is challenged, the SBA will evaluate the status of the concern and make a determination. (Specific standards appear in Part 121 of Title 13 of the Code of Federal Regulations.)
d. Contracts and subcontracts with foreign governments or their agents or instrumentalities or, insofar as the requirements of CAS other than CAS 401 and CAS 402 are concerned, any contract or subcontract awarded to a foreign concern.
e. Contracts and subcontracts in which the price is set by law or regulation.
f. Firm-fixed-price contracts and subcontracts for the acquisition of commercial items.
g. Contracts or subcontracts less than $7.5 million, provided that, at the time of award, the business unit of the contractor or subcontractor is not currently performing any CAS-covered contracts or subcontracts valued at $7.5 million or greater. “Currently performing” is defined in 48 CFR 9903.301, Definitions. A contract is being currently performed if the contractor has not yet received notification of final acceptance of all supplies, services, and data deliverable under the contract (including options). “Currently performing” is intended to reflect the period of time when work is being performed on contractual effort. The period ends when the Government notifies the contractor of final acceptance of all items under the contract. If a contractor is currently performing a CAS-covered contract of $7.5 million or greater, CAS coverage is triggered and new awards are subject to CAS (unless they meet another exemption under 9903.201-1(b)).
h. Subcontracts under the NATO PHM Ship program to be performed outside the United States by a foreign concern.
i. Firm-fixed-price contracts and subcontracts awarded on the basis of adequate price competition without submission of certified cost or pricing data.
j. In cases where the prime contract is exempt from CAS under any of the exemptions at 9903.201-1 any subcontract under that prime is always exempt from CAS.

Cost Accounting Standards (CAS)

See Also