CAS Applicability to IDIQ Contracts
Topic: Audits, Reviews, & Oversight
Original Air Date: Wednesday, February 15, 2012
Program Code: 170050
Unfortunately, the Cost Account Standards (CAS) administrative regulations don’t specifically address how CAS applies to Indefinite-Delivery/Indefinite-Quantity (IDIQ) contracts. An absence of clear regulation in this regard sparked an obscure and intense debate between contractors and the government auditors as these contracts became a mainstream feature of government procurement. Government auditors generally assert that CAS applies to all task orders if the CAS clauses are incorporated into the IDIQ contract. On the other hand, contractors generally argue that CAS applicability should be determined for each task order if the IDIQ contract contains CAS clauses. This webinar aims to settle this debate.
Missed the live event? Watch a snippet directly from the presentation!
- What contracts the CAS Board intended to be CAS-covered
- Why IDIQ contracts should be evaluated as a separate and distinct contract from a task order contract for purposes of applying CAS
- Why an IDIQ contract’s “maximum value” should be irrelevant for determining CAS applicability
- How to address special situations, such as when negotiated unit prices are incorporated in an IDIQ contract but task orders are awarded based on price competition.
Brent Calhoon is a partner with Baker Tilly’s Government Contractor Advisory Services practice in Vienna, VA. For more than 18 years, he has advised clients and their outside counsel on complex cost allowability, cost allocability, and compliance issues related FAR, CAS, TINA, and other accounting-related rules and regulations. He also performs independent forensic accounting investigations to assess allegations of fraud, accounting errors and irregularities, cost mischarging, and defective pricing. Brent helps clients design and improve business processes and functions critical to managing compliance and financial risks unique to government contractors. He has worked with a broad array of big and small public and private companies in many industries including aerospace and defense, professional services, transportation, energy, healthcare, construction, and manufacturing.
Brent earned his B.S. degree in Accounting, with honors, from Virginia Tech. He is a Certified Public Accountant licensed in Virginia.
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