Overview
FAR Subpart 30.3 is currently "Reserved," meaning it serves as a placeholder within the Federal Acquisition Regulation (FAR) structure. It directs practitioners to 48 CFR 9903.3, which contains the actual Cost Accounting Standards Board (CASB) rules and regulations governing CAS coverage, disclosure requirements, and consistency in cost accounting practices.
Key Rules
Because this subpart is a pointer to 48 CFR 9903.3, the critical regulations incorporated by reference include:
- CAS Coverage Criteria: Rules determining whether a contract is subject to "Full CAS," "Modified CAS," or is exempt.
- Disclosure Statement Requirements: Specific triggers (such as the $50 million threshold) that require a contractor to submit a formal Disclosure Statement (Form CASB DS-1 or DS-2) describing their accounting practices.
- Consistency Requirements: Rules mandating that contractors follow their disclosed or established cost accounting practices consistently for all CAS-covered contracts.
- Transition Rules: Regulations detailing how a contractor moves from modified coverage to full coverage based on contract awards.
Responsibilities
- Contracting Officer (CO): Responsible for determining CAS applicability during the solicitation phase and ensuring the correct CAS clauses are inserted into the contract.
- Administrative Contracting Officer (ACO): Typically delegated the authority to review Disclosure Statements for adequacy and compliance.
- Defense Contract Audit Agency (DCAA) / Auditors: Responsible for auditing the contractor’s accounting system to ensure the practices described in the Disclosure Statement are followed in practice.
- The Contractor: Responsible for submitting accurate Disclosure Statements and notifying the government of any changes to their cost accounting practices that may result in a cost impact.
Practical Implications
- Cross-Referencing is Essential: In government contracting, the FAR does not always house the full text of every regulation. Practitioners must look to 48 CFR Chapter 99 for the substantive "teeth" of CAS; relying solely on FAR Part 30 will result in missing critical compliance details.
- Regulatory Hierarchy: Because the CAS Board has statutory authority, their regulations (found in 48 CFR 9903) take precedence in matters of cost accounting. The "Reserved" status in the FAR ensures there is no conflicting language between the FAR and the CASB’s primary regulations.
- Audit Risk: Since the "Rules and Regulations" (9903.3) define what constitutes a "compliant" accounting system, failure to understand the referenced material leads to high risk during DCAA audits and potential price adjustments for non-compliance.