DCMA’s position is that CAS 406 (see our discussion of CAS 406 below) – or generally accepted accounting principles (GAAP) for non-CAS covered contractors – require that all costs have a single "correct" cost accounting period to which they must be assigned. The National Defense Industrial Association has expressed the opinion that this premise is incorrect. Rather than calling for a single "correct" period, they state CAS 406 and GAAP prescribe criteria for the selection of time periods to be used as a cost accounting period not for determining the one proper cost accounting period for assigning a cost. NDIA cites many examples of costs that are incurred in one period and under various circumstances, are assigned to future circumstances such as deferred independent research and development, amortization of internally developed software costs and restructuring expenses. Mr. Johnson provides another example where pension cost are incurred in the period in which the benefit is earned and is normally assigned to that period yet CAS 412-50(c)(2) requires that certain pension costs be rolled forward as a prepayment credit for reimbursement in future years.

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