Cost & Pricing Policy

The memorandum the September industrial base memo keeps referring back to directs contracting officer access to actual cost data at prime and supplier level for actions of $10 million or more, regardless of whether certification is required, and ordered delinquent CSDR reports submitted within 30 days. That deadline has passed.

DCMA and DCAA are directed to overhaul how forward pricing rate agreements are built. Estimating system and MMAS reviews are to be folded into commercial-aligned accounting system criteria within 90 days. Earned value management is confined to major development programs. And a DFARS profit policy rulemaking starts within 90 days.

The Deputy Secretary of War's 14 September 2026 memorandum, Fostering One Strong Industrial Base, directs the Department from Cost Accounting Standards to GAAP, sets a 60-day clock for proposals to the Cost Accounting Standards Board, and — effective on signature — bars any solicitation that would newly bring a business unit under full CAS coverage unless the Under Secretary for Acquisition and Sustainment approves the acquisition strategy in writing.

FAR Case 2026-003 would redefine deficiency around material terms, eliminate pre-competitive-range exchanges, loosen the competitive range, and formally recognize award to the highest technically rated proposal at a fair and reasonable price. Subpart 15.4 contract pricing is largely left alone.

FAR Case 2026-006 would remove the IRS Form 941 payroll reconciliation, the detailed time-and-materials cost element data, and contract fee computations from the Allowable Cost and Payment clause, and narrow subcontract reporting to subcontracts above the certified cost or pricing data threshold.

FAR Case 2026-006, published 18 September 2026, would shift contract type selection to a permissive framework, implement Executive Order 14402 through a new justification and approval section at FAR 16.104, and sweep firm-fixed-price level-of-effort term contracts into that requirement. Comments close 19 October 2026.

Executive Order 14426, signed 8 September 2026 and published 11 September, requires the Secretaries of War and Veterans Affairs to review and modify existing information technology contracts to add an interoperability requirement, and to include that requirement in all future contracts of the same kind.

Class Deviation 2026-O0046, Revision 1, posted 9 September 2026, revises DFARS Part 245 so that nontraditional defense contractors are exempt from DFARS 252.245-7003, Contractor Property Management System Administration, unless a contracting activity head waives the exemption.

DFARS Parts 244 and 231 were revised on 29 July and 4 August 2026 to implement FY2026 NDAA section 1826. Cost principles and purchasing system approval no longer apply to nontraditional defense contractors on Department of War contracts.

Class Deviation 2026-O0006, Revision 1, issued 30 July 2026, implements FY2026 NDAA section 1806 and doubles both the full-versus-modified CAS coverage line and the disclosure statement trigger. The CAS Board has since made the change government-wide effective 1 October 2026, but the FAR Part 30 overhaul text still carries the old figures.

A final rule published 1 September 2026 removes CAS 407 in its entirety and relocates the surviving production-unit requirements for standard costs and variances into CAS 418. Effective 1 October 2026.

A Cost Accounting Standards Board final rule published 1 September 2026 raises the basic CAS applicability threshold from $2.5 million to $35 million, doubles the full-coverage and Disclosure Statement threshold to $100 million, and sets how CAS exemptions apply to indefinite delivery contracts.

A July 20, 2026 executive order restricts 10 U.S.C. 4872 waivers starting January 1, 2027 and directs new regulations requiring full indentured bills of materials. Both changes have cost estimating consequences.

The FAR Council issued implementing guidance on 1 July 2026 and the Department of War followed on 15 July. Other-than-fixed-price selections now carry a justification burden, and the reach extends to some contracts already awarded.

A 24 July 2026 Department of War class deviation implements FY2026 NDAA sections 812(c), 1826, and 811(a)(5), converts the TINA Lite pilot into a permanent program, and changes should-cost review requirements.