Overview
This section establishes the Cognizant Federal Agency Official (CFAO) as the central authority for Cost Accounting Standards (CAS) administration and outlines the mandatory delegation process for contracting officers following a contract award.
Key Rules
- Centralized Authority: The CFAO performs CAS administration for all contracts and subcontracts within a business unit, even if other administrative functions are retained by the contracting officer.
- Determinations and Findings: The CFAO is specifically responsible for determining if a change in cost accounting practice or a noncompliance has occurred and resolving any resulting cost impacts.
- 30-Day Window: Contracting officers must request that the CFAO perform CAS administration within 30 days of awarding a new CAS-covered contract.
- Audit Integration: The CFAO is required to request and consider the advice of the auditor when performing CAS administration duties.
- Subcontractor Procedures: Specific procedures for subcontract awards are governed by the flow-down provisions in FAR 52.230-6(l), (m), and (n).
Practical Implications
- Consistency: By centralizing authority in the CFAO, the government ensures that a contractor’s accounting practices are evaluated consistently across all federal contracts rather than being subject to conflicting interpretations by multiple contracting officers.
- Specialization: This separation of duties allows the CFAO to focus on the technical complexities of cost accounting and auditor coordination while the procuring contracting officer focuses on performance and delivery.