$14.8 Billion Crosses the New CAS Line on October 1

If you have a cost-type proposal going in after September 30, the coverage box you check on it changes in two weeks.

On October 1 the Cost Accounting Standards Board's threshold rule takes effect, and the trigger for full CAS coverage and a Disclosure Statement goes from $50 million to $100 million. The basic applicability threshold moves at the same time, from $2.5 million to $35 million.

Two days ago the Deputy Secretary of War signed a memorandum telling the Department to lean into all of it, and the trade press spent yesterday on the GAAP headline.

The headline is the least useful part.

What Actually Moves, and What Doesn't

The memorandum does not change CAS applicability. It cannot.

Coverage moves because the Board amended 9903.201-2 and 9903.202-1, and that rule was final on September 1, three weeks before Feinberg signed anything.

So separate the two clocks. Here is what the Board's rule does on October 1:

1. Full coverage and the Disclosure Statement start at $100 million, up from $50 million. The Board struck "$50 million" wherever it appeared in 9903.201-2, 9903.201-3, and 9903.201-4 and wrote in "$100 million."
2. Nothing under $35 million is covered at all, up from $2.5 million. The old carve-out for awards worth less than 10 percent of a contractor's sales and under $10 million is gone, because at $35 million it stopped doing any work.
3. Agency waiver authority rises to $100 million in step with the coverage threshold.
4. The total-company test is dead. The threshold now applies at the business-unit level, which is where your indirect rates already live.
5. Indefinite-delivery contracts get a rule that says which value counts. On a multiple-award IDC, applicability and every exemption are tested at each task or delivery order using that order's ceiling. On a single-award IDC, they are tested once, at IDC award, against the IDC ceiling.

That last one is worth sitting with. The Board's own preamble puts IDC obligations at $262 billion in FY2024, "over one-third of all contract obligations," and until now the question of whether the vehicle or the order carried the threshold had no clean answer.

An entire single-award IDC is exempt if it only orders commercial products or services, or if it only orders firm-fixed-price and was awarded on adequate price competition without certified cost or pricing data.

Read that as a drafting instruction, because your contracting officer will.