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Interact Topic #18 – Cost Accounting Systems (CAS) Proposal Requirement

Evidencing an adequate CAS is a mandatory proposal requirement for the Alliant 2 Program. The requirement is for the offeror to demonstrate in its proposal on the proposal submission date that it has an accounting system determined to be adequate for federal cost reimbursement contracting by Defense Contract Audit Agency (DCAA) or any other cognizant federal agency per FAR 16.301-3(a)(1). Demonstrating this determination in the offer is mandatory; thus, a go/no go proposal requirement.

Over one-third of the task orders issued on the legacy Alliant and Alliant SB GWACs were of the cost reimbursement contract type; hence, there is an expectation from client agencies that all prime contractors on Alliant 2 and Alliant 2 SB are qualified to compete for cost reimbursement task orders from "day one" of the master contract award date. Considerable client agency demand for the cost reimbursement contract type on the first generation Alliant and Alliant SB GWACs supports this capability requirement on Alliant 2 and Alliant 2 SB. There will be no deviations or waivers granted for this proposal requirement.

 

 

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ARPDKnox
<p><span style="color: rgb(76, 76, 76); font-family: Arial, 'Arial Unicode MS', Helvetica, sans-serif; font-size: 14px; line-height: 21px;">The requirement is for the offeror to demonstrate in its proposal on the proposal submission date that it has an accounting system determined to be adequate for federal cost reimbursement contracting by Defense Contract Audit Agency (DCAA) or any other cognizant federal agency per FAR 16.301-3(a)(1).</span></p><p>Would a DCAA preaward survey of an offeror&#39;s prospective accounting system suffice this requirement? &nbsp;</p><p>This audit determines whether an offeror has an accounting system that is suitably designed, in all material respects, for the award of a prospepective contract in accordance with the criteria contained in FAR 53.209-1(f). &nbsp;This audit is limited to determining whether the design of the accounting system is acceptable for award. &nbsp;An audit of the accounting system itself was not performed. &nbsp;A Standard Form 1408 was completed with a recommendation for award. &nbsp;</p>
Alliant 2 Blogger (not verified)
<p>@ARPDKnox: Thank you for your feedback. Please reference Interact Topic #18 for guidance.&nbsp;</p>
David Hubbard
<p>&nbsp;</p><p>Per FAR 52.230-1(c)(3) a CAS Certificate of Monetary Exemption is granted to a business with annual revenue of $50M or less.&nbsp; Accordingly, the DCAA will not review or certify a submitted CASB-DS1 Disclosure Statement from a business with annual revenue of $50M or less.&nbsp; However,&nbsp; FAR 16.301-3(a)(1) listed in Interact Topic 18 &nbsp;states (a) &ldquo;<em>a cost-reimbursable contract may be used only when (1) the contractor&rsquo;s accounting system is adequate for determining costs applicable to the contract</em>&rdquo;.&nbsp;Please confirm that a detailed description of a small business contractor&rsquo;s accounting and billing system would comply with FAR 16.301(a)(1) in regard to an Alliant 2 SB proposal submission.&nbsp;</p>
Alliant 2 Blogger (not verified)
<p>The question&nbsp;conflates&nbsp;Cost Accounting Standards (CAS) @ FAR 52.230-1 with Cost Accounting System @ FAR 16.301-3, which has sometimes also been abbreviated as &quot;CAS&quot;.&nbsp; The requirement for a Cost Accounting System per FAR 16.301-3(a)(1) does not depend upon a Cost Accounting Standards review. &nbsp;Small businesses are exempt from Cost Accounting Standards per&nbsp;Code of Federal Regulations 9903.201-1 but not exempt from the Cost Accounting System requirement per FAR 16.301-3.</p>
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