Responsibilities
Contracting officers must ensure all CAS-related certifications and Disclosure Statements are properly submitted and reviewed before awarding a CAS-covered contract, unless an agency head authorizes an exception.
Overview
FAR 30.202-6 outlines the specific responsibilities of contracting officers, the cognizant Federal agency official (CFAO), and auditors regarding Cost Accounting Standards (CAS) coverage and Disclosure Statements. The contracting officer must determine if a contract requires CAS coverage, include the appropriate notice in the solicitation, and ensure that the offeror provides necessary certifications and Disclosure Statements. A CAS-covered contract cannot be awarded until the CFAO has determined in writing that the Disclosure Statement is adequate, unless the agency head authorizes an exception to protect the Government's interest. In such cases, the contractor must submit the Disclosure Statement post-award, and the CFAO must review it promptly. The cognizant auditor reviews Disclosure Statements for adequacy and compliance, while the CFAO issues formal determinations on these matters.
Key Rules
- Contracting Officer's Determination
- Must assess if CAS applies and include the correct notice in solicitations.
- Certification and Disclosure Statement Submission
- Ensure offerors provide required certifications and Disclosure Statements before award.
- Award Restrictions
- No award of CAS-covered contracts without CFAO's written adequacy determination, unless agency head authorizes otherwise.
- Auditor and CFAO Roles
- Auditor reviews Disclosure Statements; CFAO issues adequacy and compliance determinations.
Responsibilities
- Contracting Officers: Determine CAS applicability, include notices, collect certifications, and ensure Disclosure Statement submission.
- Contractors: Submit required certifications and Disclosure Statements as part of the solicitation process.
- Agencies: CFAO must make adequacy determinations; auditors review for compliance; agency head may authorize exceptions in special cases.
Practical Implications
- Ensures only compliant contractors receive CAS-covered contracts, protecting government interests.
- Delays in Disclosure Statement submission or adequacy determination can delay contract awards.
- Contractors must be proactive in preparing and submitting accurate Disclosure Statements to avoid award delays.