2024: The FAR, Federal Acquisition Regulations, Part 30

Jennifer Schaus and Associates hosts a complimentary webinar series on The FAR in 2024. Join the webinars on Wednesdays and Fridays at noon, eastern.
Recordings are on YouTube and the company website.
https://www.youtube.com/@jenniferschaus/videos

1. 2024 Webinar Series The FAR: Federal Acquisition Regulations Understand the rules of the federal contracting game - and play to win ! J Schaus & Associates, WASHINGTON DC – [email protected]

2. 2024 Webinar Series THE FAR ABOUT THE SERIES : We’ll cover each PART of THE FAR Typically held Wednesdays and Fridays, 12pm Complimentary Recorded Video Posted on YouTube https://www.youtube.com/@jenniferschaus/videos PPT Posted on SlideShare.net Sponsor/Advertising Options Available J Schaus & Associates, WASHINGTON DC – [email protected]

3. 2024 Webinar Series THE FAR J Schaus & Associates, WASHINGTON DC – [email protected]

4. 2024 Webinar Series THE FAR J Schaus & Associates, WASHINGTON DC – [email protected]

5. 2024 Webinar Series THE FAR ABOUT US: Services for FED GOV CONTRACTORS: Washington DC based; Professional services for established gov cons; Market Analysis to GSA Schedules; Contract Administration, etc. J Schaus & Associates, WASHINGTON DC – [email protected]

6. 2024 Webinar Series THE FAR ABOUT US: Services for those selling TO FED CONTRACTORS: Newsletter Advertising; Webinar Advertising; Social Media Advertising; Event Sponsorship; Ask for our MEDIA KIT! J Schaus & Associates, WASHINGTON DC – [email protected]

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8. WEDNESDAY 05/15 10am SBA – Review Key Programs Room: 2360 – House-Rayburn THURSDAY 05/16 930am NAVY – FY25 Defense Authorized Request - Room: 216 – Senate-Hart US SENATE – & - HOUSE OF REPRESENTATIVES Scheduled Hearings

9. TUESDAY, MAY 21 st 9-11am “GSA Schedules: The What, Why, How To - And Fine Print!” REGISTER: https://events.teams.microsoft.com/event/01d60a75-d77d-44d0-a501-9f74ff47c4ef@253e7787-672d-4071-9290-fc3db5246db7 TUESDAY, JUNE 4 th 9-11am “Federal Contractors Basic Marketing Guide” REGISTER: https://events.teams.microsoft.com/event/70f1a706-f1b3-46e1-9f88-d769e16075f3@253e7787-672d-4071-9290-fc3db5246db7 LIVE WEB BASED TRAINING

10. VA APEX ACCELERATOR - 2024 TRAINING EVENTS THURSDAY, JUNE 13 th 11.30am-1.30pm GSA Schedules: Requirements, Proposal Prep and – What’s Next REGISTER: https://virginiaptac.ecenterdirect.com/events/4448 TUESDAY, AUGUST 6 th 1pm-3pm Marketing 101 For Federal Contractors: Attract The Primes, Attract The Government REGISTER: https://virginiaptac.ecenterdirect.com/events/4452 TUESDAY, NOVEMBER 12 th 9.30am-11.30am GSA Schedules: Requirements, Proposal Prep and – What’s Next REGISTER: https://virginiaptac.ecenterdirect.com/events/4456

11. Our Sponsored Content Webinars Palmetier Law – Part 1 of 2 - Thursday JUNE 20 SBIR / STTR Unleashing Small Business Innovations: A Path To Growth & Prosperity https://attendee.gotowebinar.com/register/819675359822707801 Palmetier Law – Part 2 of 2 Thursday JUNE 27 SBIR / STTR Unleashing Small Business Innovations: A Path To Growth & Prosperity https://attendee.gotowebinar.com/register/4351522212519190620

12. 2024 Webinar Series - THE FAR THANK YOU TO OUR WEBINAR SPONSORS J Schaus & Associates, WASHINGTON DC – [email protected]

13. The FAR – Federal Acquisition Regulations - WEBINAR SERIES 2024 JSchaus & Associates – Washington DC – [email protected]

14. Full training calendar: virginiaptac.org & useful links Register for free counseling: https://virginiaptac.org/services/counseling/ Your “one stop” shop for Government Contracting assistance Reach us at [email protected] or 703-277-7750 This APEX Accelerator is funded in part through a cooperative agreement with the Department of Defense. Next Steps?

15. 2024 Webinar Series THE FAR THE FAR – PART 30 J Schaus & Associates, WASHINGTON DC – [email protected]

16. 2024 Webinar Series THE FAR FAR PART 30: Cost Accounting Standards Administration SPEAKER: Lew Gaydon, Director FIRM: Capital Edge Consulting, Inc. EMAIL: [email protected] J Schaus & Associates, WASHINGTON DC – [email protected]

17. 2024 Webinar Series - THE FAR Agenda Overview and CAS Basics Cost Accounting Practice Changes Disclosure Statements J Schaus & Associates, WASHINGTON DC – [email protected]

18. 2024 Webinar Series - THE FAR Overview and CAS Basics J Schaus & Associates, WASHINGTON DC – [email protected]

19. 2024 Webinar Series - THE FAR Congressional Testimony and GAO Study – 1969, 1970 Cost Accounting Standards Board (P.L. 91-379) – 1970 Agency of Congress (moved to Executive Branch in 1988) Established to address concerns involving defense contractor cost estimating, accumulating and reporting under negotiated government contracts (Defense) “… exclusive authority to make, promulgate, and amend cost accounting standards ….. designed to achieve uniformity and consistency in the cost accounting practices governing the measurement, assignment, and allocation of costs to contracts…” J Schaus & Associates, WASHINGTON DC – [email protected]

20. 2024 Webinar Series - THE FAR P.L. 100–679 requires certain contractors and subcontractors to: Comply with Cost Accounting Standards (CAS) Disclose its cost accounting practices in writing Consistently follow its disclosed cost accounting practices Agree to Equitable Adjustment for Applicable Changes Agree to Adjustment to Recover Increased Costs for Noncompliance or Failure to Follow Established Practices Applicable flowdowns to subcontractors J Schaus & Associates, WASHINGTON DC – [email protected]

21. 2024 Webinar Series - THE FAR FAR Part 30 – Cost Accounting Standards Administration 30.1 – General 30.2 – Program Requirements Applicability Clauses Disclosure Requirements 30.3 – Reserved 30.4 – Reserved 30.5 – Reserved 30.6 – Administration Changes Noncompliance J Schaus & Associates, WASHINGTON DC – [email protected]

22. 2024 Webinar Series - THE FAR 48 CFR Chapter 99 – Cost Accounting Standards Establishes contract coverage requirements (Part 9903) Applicability and Exemptions Disclosure Requirements Individual standards set forth how direct and indirect costs should be accounted for (Part 9904) Measurement Assignment Allocation Educational Institutions (Part 9905) J Schaus & Associates, WASHINGTON DC – [email protected]

23. 2024 Webinar Series - THE FAR Types of CAS Coverage J Schaus & Associates, WASHINGTON DC – [email protected]

24. 2024 Webinar Series - THE FAR Full Coverage (Segment level) Single award of $50M or more; subsequent awards greater than $2M during same accounting period Awards greater than $2M in current cost accounting period if net CAS-covered awards of $50M or more in preceding cost accounting period Modified Coverage (Segment level) Single award of $7.5M or more (trigger contract) Subsequent awards greater than $2M while currently performing under a trigger contract J Schaus & Associates, WASHINGTON DC – [email protected]

25. 2024 Webinar Series - THE FAR Exempt from Coverage (Partial List) Sealed bids Negotiated contracts less than the TINA threshold - $2M Small business concerns Foreign concerns (CAS 401 & 402 only) Prices set by law or regulation FFP commercial item acquisitions FFP adequate competition w/o certified cost or pricing data Contracts less than $7.5M if currently not performing under a CAS-covered contract $7.5M or greater J Schaus & Associates, WASHINGTON DC – [email protected]

26. 2024 Webinar Series - THE FAR J Schaus & Associates, WASHINGTON DC – [email protected] CAS Description 401 Consistency in Estimating, Accumulating, and Reporting Costs 402 Consistency in Allocating Costs Incurred for the Same Purpose 403 Allocation of Home Office Expenses to Segments 404 Capitalization of Tangible Assets 405 Accounting for Unallowable Costs 406 Cost Accounting Period 407 Use of Standard Costs for Direct Material and Direct Labor 408 Accounting for Costs of Compensated Personal Absence 409 Depreciation of Tangible Capital Assets 410 Allocation of Business Unit G&A Expenses to Final Cost Objective

27. 2024 Webinar Series - THE FAR J Schaus & Associates, WASHINGTON DC – [email protected] CAS Description 411 Accounting for Acquisition Costs of Material 412 Composition and Measurement of Pension Cost 413 Adjustment and Allocation of Pension Cost 414 Cost of Money as an Element of the Cost of Facilities Capital 415 Accounting for the Cost of Deferred Compensation 416 Accounting for Insurance Costs 417 Cost of Money as an Element of the Cost of Capital Assets Under Construction 418 Allocation of Direct and Indirect Costs 420 Accounting for Independent Research and Development Costs and Bid and Proposal Costs

28. 2024 Webinar Series - THE FAR Basic Standards CAS 401 — Consistency in estimating, accumulating & reporting CAS 402 — Consistency in allocating costs for same purpose CAS 405 — Accounting for unallowable costs CAS 406 — Cost accounting period Allocation of Cost Standards CAS 403 — Allocation of home office expenses to segments CAS 410 — Allocation of business unit G&A to final cost objectives CAS 418 — Allocation of direct and indirect costs CAS 420 — Accounting for IR&D/B&P costs J Schaus & Associates, WASHINGTON DC – [email protected]

29. 2024 Webinar Series - THE FAR Compensation Standards CAS 408 — Compensated personal absence CAS 412 — Composition and measurement of pension costs CAS 413 — Adjustment and allocation of pension costs CAS 415 — Deferred compensation Asset Standards CAS 404 — Capitalization of tangible capital assets CAS 409 — Depreciation of tangible capital assets CAS 414 — Cost of money as an element of the cost of facilities capital CAS 417 — Cost of money as an element of the cost of capital under construction J Schaus & Associates, WASHINGTON DC – [email protected]

30. 2024 Webinar Series - THE FAR Other Standards CAS 407 — Use of standard costs CAS 411 — Accounting for material costs CAS 416 — Accounting for insurance costs J Schaus & Associates, WASHINGTON DC – [email protected]

31. 2024 Webinar Series - THE FAR Effect of Contract Modifications Mods made under the terms and conditions of the contract do not affect CAS applicability, but ... if the contract modification adds new work not contemplated in the original contract, the government may take the position that this new work must be treated as if it were a new contract and potentially subject to CAS if the added work exceeds the thresholds for CAS This position is based on an old CAS working group paper, but is not specifically addressed in CAS Guidance J Schaus & Associates, WASHINGTON DC – [email protected]

32. 2024 Webinar Series - THE FAR J Schaus & Associates, WASHINGTON DC – [email protected] Cost Accounting Practice Changes

33. 2024 Webinar Series - THE FAR Changes in Cost Accounting Practice FAR 30.302-1: Definition – A cost accounting practice is any disclosed or established accounting method or technique which is used for Allocation of cost to cost objectives Assignment of cost to cost accounting periods Measurement of costs Under CAS, once a contractor has established its accounting practices, a change to any disclosed accounting practice requires notification to the government and the government may request an assessment of the related cost impact of the proposed accounting change J Schaus & Associates, WASHINGTON DC – [email protected]

34. 2024 Webinar Series - THE FAR CAS Clauses Requiring Price Adjustments Requires that contractors agree to Price adjustments, with interest, if increased costs to the Government result from Failure to comply with CAS Failure to follow disclosed practices consistently in estimating, accumulating and reporting costs on contracts & subcontracts with this clause Price adjustments when a change in practice is required to comply with a CAS that becomes appli­cable or is necessary to remain com­pliant J Schaus & Associates, WASHINGTON DC – [email protected]

35. 2024 Webinar Series - THE FAR Submission of Cost Impact Proposal Required Accounting Practice Change arises when contractor Needs to comply with a new or modified CAS Changes from one compliant practice (disclosed or established) to another compliant practice to remain in compliance with CAS Unilateral Accounting Practice Changes Change from one compliant practice to another compliant practice that a contractor elects to make, but that the Government has not determined to be desirable J Schaus & Associates, WASHINGTON DC – [email protected]

36. 2024 Webinar Series - THE FAR Submission of Cost Impact Proposal Desirable Accounting Practice Changes Contractor elects to make a change from one compliant practice to another, and the Government determines that the change not detrimental to the Government Changes may be desirable even if costs increase on existing contracts / subcontracts Non-Compliances Contractor fails to comply with an applicable CAS Contractor fails to consistently follow any disclosed or established cost accounting practice J Schaus & Associates, WASHINGTON DC – [email protected]

37. 2024 Webinar Series - THE FAR Cost Accounting Changes Types of changes: Mandatory change to comply with new applicable CAS Equitable adjustment allowed Net increased costs to government allowable Net decreased costs to government also allowable Unilateral (Voluntary change - discretionary) Not agreed to by ACO Government does not consider necessary and beneficial to its interests Net increase to government not allowable J Schaus & Associates, WASHINGTON DC – [email protected]

38. 2024 Webinar Series - THE FAR Cost Accounting Changes Types of changes (continued): Unilateral (Voluntary change - sanctioned) Agreed to by ACO Considered desirable and not detrimental Equitable adjustment is allowed J Schaus & Associates, WASHINGTON DC – [email protected]

39. 2024 Webinar Series - THE FAR Cost Accounting Practice Changes Contract requirement – no aggregate increased cost as a result of a change in cost accounting practice Increased cost to the Government Fixed Price Contracts – practice causes allocation of “less cost” to the contract Cost Type Contracts – practice causes allocation of “more cost” to the contract Raytheon Case If change results in “increased costs” contract price must be adjusted J Schaus & Associates, WASHINGTON DC – [email protected]

40. 2024 Webinar Series - THE FAR Cost Impact Proposals and GDMs Must be submitted within 60 days (or other mutually agreed-upon date) after The proposed change is determined adequate and compliant The date of the contractor’s agreement with the initial finding of non-compliance The date the contractor is notified by the Government of a determination of non-compliance J Schaus & Associates, WASHINGTON DC – [email protected]

41. 2024 Webinar Series - THE FAR Cost Impact Proposals and GDMs (continued) Data required to be included: Identification of each CAS-covered contract / subcontracts and the calculated cost impact by type of change Cost, profit/fee, and price/amount on each CAS-covered contract / subcontracts Contracts grouped by contract type (e.g., FFP, FPI, CPFF, CPIF) Contracts grouped by the various Departments/ Agencies (e.g., Army, Navy, Air Force, NASA, DOE) J Schaus & Associates, WASHINGTON DC – [email protected]

42. 2024 Webinar Series - THE FAR Cost Impact Proposals and GDMs (continued) List of CAS-covered contracts & subcontracts that are, or will be, affected by the change/non-compliance Maintain a system for identifying all contracts and subcontracts containing FAR 52.230-2 (CAS Clause) Format of the Cost Impact Proposal is typically not specified Format may be Determined by Govt and provided to Contractor Must be in sufficient detail J Schaus & Associates, WASHINGTON DC – [email protected]

43. 2024 Webinar Series - THE FAR J Schaus & Associates, WASHINGTON DC – [email protected] Disclosure Statements

44. 2024 Webinar Series - THE FAR To Describe a Contractor’s Cost Accounting Practices & Procedures Format is prescribed by the CASB, Disclosure Statement Form No. CASB DS-1 (48 CFR 9903.202) DS Template can be found on-line at www.whitehouse.gov/omb/procurement/casb_ds-1.pdf Required under fully CAS-Covered contracts Home offices allocating costs to segments must submit applicable DS Parts Segments where costs included in CAS-covered contracts exceed $2M, unless The segment's CAS-covered awards are less than 30% of total segment sales for the period & less than $10M J Schaus & Associates, WASHINGTON DC – [email protected]

45. 2024 Webinar Series - THE FAR General Background Concepts Cost Accounting Practices Any disclosed or established accounting method or technique which is used for Allocation of cost to cost objectives Assignment of cost to cost accounting periods Measurement of cost J Schaus & Associates, WASHINGTON DC – [email protected]

46. 2024 Webinar Series - THE FAR Measurement of Cost Standard or actual cost Definition of asset book value Assignment of Cost to a Cost Accounting Period Use of accrual or cash basis accounting Depreciation methods Allocation of Costs to Cost Objectives Overhead expenses based on direct labor dollars Composition of expense pools or allocation bases J Schaus & Associates, WASHINGTON DC – [email protected]

47. 2024 Webinar Series - THE FAR The Components of the Disclosure Statement Cover Sheet and Certification Part I – General Information Part II – Direct Costs Part III – Direct vs. Indirect Costs Part IV – Indirect Costs Part V – Depreciation & Capitalization Practices Part VI – Other Costs & Credits Part VII – Deferred Compensation & Insurance Part VIII – Home Office Expenses J Schaus & Associates, WASHINGTON DC – [email protected]

48. 2024 Webinar Series - THE FAR Coversheet and Certification Contractor’s name, address and POC Reporting Unit Type Business Unit not divided by segments OR HO, IHO or Segment for Business Units which are divided Effect Date of the DS Identification of Original DS submission or Revision to Existing DS Name of Agency/Auditor DS will be submitted to and contact information J Schaus & Associates, WASHINGTON DC – [email protected]

49. 2024 Webinar Series - THE FAR Part I – General Information Major Items Type of Business Entity (Corp, NFP, FFRDC, etc.) Predominant Type of Government Sales (Manufacturing, R&D, Construction, Services, Other) Sales and industry data Description of cost accounting system (actual cost vs. standard cost) Integration of cost accounting system with financial accounting system Treatment of unallowable costs Fiscal year J Schaus & Associates, WASHINGTON DC – [email protected]

50. 2024 Webinar Series - THE FAR Part II – Direct Costs Major Items Description of principal types of direct costs Method of charging direct materials Method of charging direct labor As applicable, method of direct material and labor standard costing and variance disposition Treatment of inter-organizational transfers J Schaus & Associates, WASHINGTON DC – [email protected]

51. 2024 Webinar Series - THE FAR Part III – Direct vs. Indirect Costs Major Items Criteria for determining how costs are charged or allocated to cost objectives Treatment of specific transactions involving direct labor, direct material, and miscellaneous costs J Schaus & Associates, WASHINGTON DC – [email protected]

52. 2024 Webinar Series - THE FAR Part IV –Indirect Costs Major Items The number & type of indirect cost pools to include general & admin. (G&A), the composition of cost pools & the allocation bases Number of and how service center costs are allocated to cost objectives Allocation of IR&D/B&P to cost objectives J Schaus & Associates, WASHINGTON DC – [email protected]

53. 2024 Webinar Series - THE FAR Part V – Depreciation & Capitalization Practices Major Items Method of depreciation Method of determining useful lives and residual value Comparison to methods used for tax and financial purposes Criteria for capitalization Treatment of costs incurred in procurement of assets J Schaus & Associates, WASHINGTON DC – [email protected]

54. 2024 Webinar Series - THE FAR Part VI – Other Costs & Credits Major Items Method of charging and crediting compensated personal absence Treatment of severance payments and supplemental unemployment Treatment of credits J Schaus & Associates, WASHINGTON DC – [email protected]

55. 2024 Webinar Series - THE FAR Part VII – Deferred Compensation & Insurance Major Items Description of pension plans which cover the greatest number of employees, if applicable Description of pension plan contribution basis Description of deferred compensation plans Description of purchased insurance and treatment of self-insurance programs J Schaus & Associates, WASHINGTON DC – [email protected]

56. 2024 Webinar Series - THE FAR Part VIII – Home Office Expenses Major Items Description of home office expense pools and methods of allocation Description of home office expenses Sales information and listing of business units/segments receiving an allocation J Schaus & Associates, WASHINGTON DC – [email protected]

57. 2024 Webinar Series THE FAR FAR PART 30: Cost Accounting Standards Administration SPEAKER: Lew Gaydon, Director FIRM: Capital Edge Consulting, Inc. EMAIL: [email protected] J Schaus & Associates, WASHINGTON DC – [email protected]

58. 2024 Webinar Series THE FAR Please subscribe to our YouTube Channel for Gov Con Content Uploads including THESE WEBINARS! https://www.youtube.com/@jenniferschaus/videos J Schaus & Associates, WASHINGTON DC – [email protected]

59. 2024 Webinar Series The FAR: Federal Acquisition Regulations THANK YOU FOR JOINING US! J Schaus & Associates, WASHINGTON DC – [email protected]