FAR Council Revises Earlier Proposed Rule on Cost Impacts Due to Cost Accounting Practice Changes
Incorporating earlier comments to a proposed April 2000 rule, the FAR Council July 3 proposed to amend FAR Part 30 that sets the process of administering the cost accounting standards and determining the impact of accounting changes. EXPAND ON EARLIER The earlier proposed rule established a three-step sequence of submissions of cost impact statements where acceptance of the lowest step would be encouraged and where the cost impact on government contracts would be streamlined.
The changes over the earlier proposed rule include: (1) incorporating a June 2000 CAS Board final rule that added definitions for required, unilateral and desirable changes and excluded cost accounting practice changes related to external restructuring from contract price and cost adjustments (2) included the effect of “offsets” in the cost impact calculation process by separating the calculation of the cost impact from the resolution of the cost impact (3) authorizes the Cognizant Agency Federal Official (CAFO) to make a materiality determination at any point in the cost accounting process before requesting a general dollar magnitude (GDM) proposal (4) provides additional guidance on what constitutes “desirable changes” (5) revises the content of GDM and detailed cost impact (DCI) proposals (e.g. allowing broad based data as the basis for GDM proposals, projecting only larger contracts rather than all contracts for DCI proposals) to provide greater flexibility and reduce administrative effort (6) authorizes the CAFO to resolve a cost impact due to a change in accounting practice by adjusting a single contract or several but not all contracts as long as the government will not pay more in the aggregate (7) requiring the CAFO rather than COs to execute contract modifications and (8) adding a provision requiring contractors to indicate if the contract award will result in a cost accounting practice change and if so to prepare a pricing proposal using the changed practice (Fed. Reg. 40104).
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