Cost Accounting Practice Change

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Contents

Cost Accounting Practice Change

History -- Final Rule Issued June 14, 2000

  • Concludes CAS case begun in 1993
  • Significantly reduced Scope


Change in Accounting Practice

A Change in Accounting Practice is any change to a disclosed or established accounting method or technique which is used for allocation of costs to cost objectives, assignment of costs to cost accounting periods, or measurement of costs. [1]

Examples of Cost Accounting changes when there is a change in the method or technique for:

1. Determining whether a cost is directly or indirectly allocated.

2. Determining the composition of the cost pools.

3. Determining the selection of the allocation base.

4. Determining the composition of the allocation base.


Initial Adoption or Elimination of Costs

A change in practice has not occured if the initial adoption of a practice coincides with the first time a cost is incurred or function is created. [2], or


  • Elimination (partial or total) of a costs or costs of a function is not a change in practice, or


  • Revision of a practice for a previously immaterial costs is not a change in practice.

Types of Changes

Required Change[3]

A required change occurs with the issuance of a new CAS standard, requirements based on laws, accounting practices required to be changed to maintain compliance with CAS.

Unilateral Change[4]

Unilateral change by a contractor means a change in cost accounting practice from one compliant practice to another compliant practice that a contractor elects to make that has not been deemed desirable by the Cognizant Federal Agency Official (CFAO).

Desirable[5]

A compliant change to a contractor’s established or disclosed cost accounting practices that the CFAO finds is desirable and not detrimental to the Government and is, therefore, not subject to the no increased cost prohibition provisions of CAS-covered contracts and subcontracts affected by the change.

Noncompliance[6]

Non-compliance with Cost Accounting Standards

Requirements - Contractor

  • FAR requires 60 day notice of any change in Accounting Practice, with a description of the change. The change will then be reviewed for adequacy and compliance by the cognizant federal agency, normally an Administrative Contracting Officer (ACO).


  • All changes must be quantified, through one or both of the following steps;



  • Cost Impact

Requirements - Government (CFAO)

Prior to making any contract price or cost adjustment the CFAO shall determine

  • The contemplated contract price or cost adjusment will protect the Government from the payment of the estimated increased costs, in the aggregate; and
  • The net effect of the contemplated adjustments will not result in the recovery of more than the increased costs to the Government


Related Pages

Cost Accounting Practice Change - Examples

References and Notes

  1. (48 CFR 9903.302)
  2. (48 CFR 9903.302)
  3. FAR 52.230-2(a)(4)(i), Equitable Adjustment
  4. FAR 52.230-2(a)(5), No increased cost to the Government in the aggregate
  5. FAR 52.230-2(a)(4)iii and 3(a)(3)(ii), FAR 30.001
  6. FAR 52.230-2(a)(5) and 3(a)(4), No increased cost to the Government in aggregate