Cost Accounting Standards Notices and Certification
Offerors (except small businesses and foreign governments) must certify their Cost Accounting Standards (CAS) status and submit required Disclosure Statements when bidding on contracts exceeding the CAS threshold.
Overview
FAR 52.230-1, Cost Accounting Standards Notices and Certification, is a solicitation provision that requires offerors (except small businesses and foreign governments) to disclose their cost accounting practices and certify their compliance with Cost Accounting Standards (CAS) when bidding on contracts exceeding the CAS threshold. The provision is divided into three parts: (I) Disclosure Statement and Certification, (II) Eligibility for Modified Contract Coverage, and (III) Notification of Changes to Cost Accounting Practices. Offerors must complete the relevant certifications, submit required Disclosure Statements (CASB DS-1 or DS-2), and indicate any changes in cost accounting practices that may affect existing contracts. Special rules apply to educational institutions and offerors eligible for modified coverage. Alternate I provides additional certification requirements for educational institutions regarding Disclosure Statement due dates.
Key Rules
- Disclosure Statement and Certification
- Offerors must submit or certify submission of a Disclosure Statement if the contract exceeds the CAS threshold, unless exempt. They must also certify that cost estimates are consistent with disclosed practices.
- Eligibility for Modified Contract Coverage
- Offerors eligible for modified coverage (less than $50 million in CAS-covered awards in the prior period) may claim exemption from full CAS coverage by checking the appropriate box and certifying eligibility.
- Notification of Changes to Cost Accounting Practices
- Offerors must indicate if the contemplated contract will require changes to established cost accounting practices affecting existing contracts.
- Special Provisions for Educational Institutions
- Educational institutions may have different requirements for Disclosure Statement submission, including due date certifications under Alternate I.
Responsibilities
- Contracting Officers: Ensure the provision is included in solicitations, review offeror certifications, and verify compliance with CAS requirements.
- Contractors/Offerors: Complete all required certifications, submit Disclosure Statements as required, and notify the Contracting Officer of any changes in status or cost accounting practices.
- Agencies: Oversee compliance, maintain records of Disclosure Statements, and coordinate with auditors as needed.
Practical Implications
- This provision ensures transparency and consistency in cost accounting for contracts subject to CAS, reducing the risk of noncompliance and audit findings. Offerors must be diligent in understanding their CAS status, timely submitting required documentation, and accurately certifying their practices. Failure to comply can result in proposal rejection or contract issues.