Determinations
FAR 30.202-7 requires contractors to submit accurate Disclosure Statements and respond promptly to adequacy and compliance determinations to ensure CAS and FAR Part 31 compliance.
Overview
FAR 30.202-7 outlines the process for determining the adequacy and compliance of a contractor’s Disclosure Statement under the Cost Accounting Standards (CAS). The section details the roles of auditors and the Cognizant Federal Agency Official (CFAO) in reviewing, assessing, and communicating the status of the Disclosure Statement, which describes a contractor’s cost accounting practices. The regulation ensures that contractors accurately disclose their cost accounting methods and comply with CAS and FAR Part 31 requirements.
Key Rules
- Adequacy Determination
- The auditor reviews the Disclosure Statement for accuracy, completeness, and currency, then reports findings to the CFAO. The CFAO determines if the statement adequately describes cost accounting practices and notifies the contractor of adequacy or requests revisions if inadequate. Notification should generally occur within 30 days of receipt.
- Compliance Determination
- After adequacy is confirmed, the auditor conducts a detailed compliance review against CAS and Part 31. The CFAO then determines compliance or addresses noncompliance, including requesting corrections for CAS issues and processing Part 31 issues separately.
Responsibilities
- Contracting Officers: Receive copies of adequacy notifications if the proposal triggers Disclosure Statement submission.
- Contractors: Must submit accurate, complete, and current Disclosure Statements and revise them if found inadequate or noncompliant.
- Agencies (CFAO/Auditor): Review, assess, and communicate adequacy and compliance determinations; request corrections as needed.
Practical Implications
- This section ensures transparency and standardization in cost accounting practices for CAS-covered contracts. Contractors must be diligent in preparing and updating Disclosure Statements, as delays or inadequacies can impact contract awards and compliance. Timely communication and correction of deficiencies are critical to avoid compliance issues and potential penalties.