TINA Lite Goes Permanent: New Class Deviation Rewrites Part 215 Cost and Pricing Rules

On 24 July 2026 the Department of War issued Class Deviation 2026-O0046, Revision 1, covering Revolutionary FAR Overhaul Part 15 and DFARS Part 215, effective immediately. It implements several sections of the National Defense Authorization Act for Fiscal Year 2026 and is the most consequential change to defense cost and pricing rules published so far this year.

What changed

Section 812(c) transitions the pilot program commonly called TINA Lite into a permanent program. Class deviation 2024-O0007, which implemented the pilot under Section 890 of the FY2019 NDAA, is rescinded. Under TINA Lite, contracting officers can tailor the certified cost or pricing data required for certain acquisitions by relying primarily on historical actual cost data from prior similar buys rather than requesting a complete bottom-up proposal for every recurring element of work.

Section 1826 exempts nontraditional defense contractors from submission of certified cost or pricing data and from other special cost or pricing requirements, unless waived. Section 811(a)(5) repeals 10 U.S.C. 3455, removing the prior-determination and congressional notification requirement for procuring a major weapon system as a commercial product. The deviation also changes requirements for should-cost reviews.

Why it matters for cost and pricing work

Three effects are worth planning around. First, data availability. Broader exemptions mean fewer certified submissions entering the pipeline, and the thinning happens precisely among the nontraditional suppliers whose share of defense content is growing. Estimators who rely on certified data as a cross-check will have less of it, in the segment where they most need it.

Second, method. Making TINA Lite permanent shifts weight from bottom-up buildups toward actual-cost history and analogy. That is defensible when prior-buy actuals are clean, well-normalized, and genuinely comparable. The quality of the historical record becomes the binding constraint on estimate quality, which raises the value of disciplined cost data collection rather than lowering it.

Third, documentation hygiene. A rescinded pilot deviation means any estimate documentation, basis-of-estimate narrative, or internal policy that cites 2024-O0007 is now pointing at a superseded authority. That is a cheap fix if caught early and an awkward finding if caught in review.

Primary sources

DoW Class Deviation 2026-O0046 Revision 1, acq.osd.mil. Class Deviation 2024-O0007 (rescinded), acq.osd.mil. Revolutionary FAR Overhaul announcements, waru.edu. National Defense Authorization Act for Fiscal Year 2026, Public Law 119-60, sections 811, 812, and 1826.