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The CAS-to-GAAP Memo Is Signed. One Rule Binds Immediately: No New Full CAS Coverage Without USW(A&S) Approval.
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.
chris359949
Sep 243 min read
Proposed Rule Would Delete FAR Subpart 9.6 on Teaming and End DoW's Duty to Fund Small Business Qualification Testing
FAR Case 2026-011 would remove contractor team arrangements from the FAR entirely and, implementing section 812(a)(6) of the FY2026 NDAA, excuse the Department of War from paying for a small business to undergo qualification testing where fewer than two manufacturers could compete. Civilian agencies keep that obligation.
chris359949
Sep 212 min read
Nontraditional Defense Contractors Are Now Outside the DFARS Property Management System Clause
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.
chris359949
Sep 142 min read
Two Class Deviations Put Nontraditional Defense Contractors Outside FAR Part 31
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.
chris359949
Sep 72 min read
Full CAS Coverage Now Starts at $100 Million for Defense-Only Business Units
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.
chris359949
Sep 73 min read
CAS Applicability Moves to $35 Million and Full Coverage to $100 Million, Effective 1 October
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.
chris359949
Sep 72 min read
TINA Lite Goes Permanent: New Class Deviation Rewrites Part 215 Cost and Pricing Rules
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.
chris359949
Aug 52 min read
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