CAS. Combined Air Support Cost Accounting Standards. Cost Impact Statements

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1 CAS Combined Air Support Cost Accounting Standards Cost Impact Statements

2 Cost Impact Statements Presenter: Anthony J. Nicolella

3 References 48 CFR 9903 CON 252 Fundamentals of CAS FAR Parts 30, 31 and 52 Defense Contract Audit Manual

4 Cost Impact Statement (CIS) Agenda What is a CIS Types of cost accounting practices (CAP) changes Five step process to calculate cost impact Types of CAS non compliances Fixed Price vs. Flexibly Priced Contracts CAS non compliance cost impact statement scenarios/examples Methods of recovering increased costs for unilateral changes or CAS noncompliance

5 What is a CIS A CIS allows the Government (GOV) to calculate the cost impact of a cost accounting practice change made by the contractor (KTR) The process begins when the Administrative Contracting Officer (ACO) receives a cost impact proposal from the KTR Note: A cost impact proposal is the vehicle whereby a KTR notifies the GOV of the cost impact to affected contracts

6 Types of cost accounting practices (CAP) changes There are three types of CAP changes: 1. Desirable changes 2. Required changes 3. Unilateral changes * Timely notice of CAP changes is required

7 Types of cost accounting practices (CAP) changes - continued 1. Desirable changes The change has been determined by the Cognizant Federal Agency Official (CFAO) to be desirable and not detrimental to the GOV The determination that a CAP change is desirable should be made on a case-by-case basis When there is a desirable change, the CFAO and the KTR negotiate a resolution of the cost impact, which can range from $0 to the entire amount of the cost impact

8 Types of cost accounting practices (CAP) changes - continued 2. Required changes KTR is required to make the change in order to comply with applicable standards, modifications or interpretations In order for such a change to be considered a required change, the KTR s former CAP must have been in compliance with CAS and the CAP change must be necessary for the KTR to remain in compliance Required changes entitle the KTR to an equitable adjustment. Hence, the GOV is not prohibited from paying increased costs for required changes

9 Types of cost accounting practices (CAP) changes - continued 3. Unilateral changes The change is completely voluntary, and the CFAO has not determined it to be desirable to the GOV The unilateral change must be a change from one compliant practice to another Under unilateral CAP changes, the GOV is prohibited from paying increased costs in the aggregate

10 Five Step Process to Calculate Cost Impact 1. Compute the increased/(decreased) cost estimates and/or cost accumulations for CAS-covered contracts. 2. Combine the increased/(decreased) cost estimates or accumulations within each contract group. 3. Determine the increased/(decreased) cost to the government for each contract group, including the net impact on cost estimates, accumulations and profits/fees. 4. Determine the aggregate increased costs to the government by combining the increased/(decreased) costs to the government for both contract groups. 5. Determine the appropriate settlement alternative for the government to recover any increased costs in the aggregate.

11 Types of CAS Non Compliances 1. Estimating Forecast based on current information 2. Accumulating Collect cost data in an organized manner 3. Estimating and accumulating

12 Fixed Price vs. Flexibly Priced Contracts Fixed Price: Contracts where price does not vary. Examples would include FFP, some IDIQ, FPLOE, etc. Flexibly Priced: Contracts where the price can vary. Examples, would include cost reimbursement contracts such as CPFF, CPIF, CPAF, and FPIF.

13 Chart on Non-Compliance Estimating Accumulating Flexibly Price Profit/Fee Costs Fixed Price * No Cost Impact * Negotiated Price using non-compliant practice A Less: Price would have been negotiated compliant B Equals Cost Impact C =

14 CAS Non Compliance Cost Impact Statement Rule/Example Estimating: - Price Negotiated Using a Noncompliant Practice - Less: Price that Would Have Been Negotiated Using Compliant Practice - Equals: Cost Impact of Noncompliance in Estimating Costs FFP Contract Example. Negotiated price of $1,000 using noncompliant practice. Had contractor (KTR) used compliant practice price would have been $600. What is the cost impact? $1,000 (amount using noncompliant practice) - $600 (amount using compliant practice) $400 = cost impact

15 CAS Non Compliance Cost Impact Statement Rules/Examples Estimating: - Price Negotiated Using a Noncompliant Practice (What is it?) - Less: Price that Would Have Been Negotiated Using Compliant Practice (What should it be?) - Equals: Cost Impact of Noncompliance in Estimating Costs Flexibly Priced Cost Re-Imbursement Contract (No Fee or Profit) Example. Negotiated a cost ceiling of $3,000 using noncompliant practice. Had KTR used compliant practice, the negotiated cost ceiling would have been $2,900. KTR actually incurred a cost of $2,500. What is the cost impact? $2,500 (amount using noncompliant estimating practice) -$2,500 (amount using compliant estimating practice) $0 = cost impact. Under flexibly priced contracts, Government pays actual costs

16 CAS Non Compliance Cost Impact Statement Rules/Examples Accumulation: - Amount paid on FFP Contract is not affected by the amount of actual costs incurred. FFP Contract Example. Negotiated price of $1,000 using noncompliant practice. The KTR accumulates $900 using a noncompliant practice. Had the KTR used a compliant practice, the amount of costs accumulated would have been $800. What is the cost impact? $1,000 (amount using noncompliant accumulating practice) -$1,000 (amount using compliant practice) $0 = cost impact. Under FFP, amount paid is not affected by actual costs.

17 CAS Non Compliance Cost Impact Statement Rules/Examples Accumulation: - For Flexibly Priced Contracts, a noncompliance in accumulating costs does impact the amount the Government pays, since payment is based on actual cost incurred. Flexibly Priced Cost Re-Imbursement Contract (No Fee or Profit) Example. Negotiated a cost ceiling of $3,000 using noncompliant practice. KTR accumulated $2,900 of actual cost using a noncompliant practice. The KTR would have accumulated $2,700 had a compliant practice been used. What is the cost impact? $2,900 (amount using noncompliant practice) -$2,700 (amount using compliant practice) $200 = cost impact.

18 CAS Non Compliance Cost Impact Statement Rules/Examples Estimating and Accumulation: - When both estimating and accumulating are involved, compute the cost impact separately then add together to get total cost impact. Estimating Accumulating Flex Price Profit/fee Costs FFP * No cost impact Example. KTR A has two contracts. Contract 1 is FFP and Contract 2 is cost re-imbursement with no fee, profit, or incentives. KTR estimates and accumulates costs under both contracts using a noncompliant practice. What is the cost impact? Estimating noncompliance Accumulating noncompliance Contract 1 (FFP) $5,000 Contract 1 (FFP) $0 Contract 2 (CR) $0 Contract 2 (CR) $3,000 $5,000 $3,000 Total cost impact = $8,000 * Negotiated price using compliant practice: A Less price would have been negotiated compliant: B Equals cost impact = C

19 Methods of Recovering Increased Costs for Unilateral Changes or CAS Noncompliance 1. Cash payment from the KTR 2. Adjusting all CAS-covered contracts and subcontracts 3. Adjusting some CAS-covered contracts and subcontracts 4. An alternate method

20 Questions?

21 Back-up Slides

22 Cost Accounting Standards General Standards 401 Consistency in Estimating, Accumulating and Reporting Costs 402 Consistency in Allocating Costs Incurred for the Same Purpose 405 Accounting for Unallowable Costs 406 Cost Accounting Period Compensation Costs 408 Accounting for the Costs of Compensated Personal Absence 415 Accounting for the Costs of Deferred Compensation 412/413: Composition and Measurement of Pension Costs and Adjustment and Allocation of Pension Costs.

23 Cost Accounting Standards Tangible Assets 404 Capitalization of Tangible Capital Assets 409 Depreciation of Tangible Capital Assets 414 Cost of Money as an Element of the Cost of Facilities Capital 417 Cost of Money as an Element of the Cost of Capital Assets Under Construction Specific Types of Costs 407 Use of Standard Costs for Direct Material and Direct Labor 411 Accounting for Acquisition Costs of Material 416 Accounting for Insurance Costs

24 Cost Accounting Standards Cost Allocation 403 Allocation of Home Office Expenses 410 Allocation of Business Unit General and Administrative Expenses (G&A) to Final Cost Objectives 418 Allocation of Direct and Indirect Costs 420 Accounting for IR&D and B&P Costs

25 Definitions & Terms Aggregate - Collective amount, sum, or mass arrived at by adding or putting together all components, elements, or parts of an assemblage or group. Accumulating costs - the collection of cost data in an organized manner, such as through a system of accounts. [48 CFR (a)(1)] Cognizant Federal agency official (CFAO) - the contracting officer assigned by the cognizant Federal agency to administer the CAS. Other names for CFAO include Administrative Contracting Officer (ACO), Divisional ACO (DACO), or Corporate (CACO). Detailed Cost-Impact (DCI). Estimating costs - the process of forecasting a future result in terms of cost, based upon information available at the time. [48 CFR (a)(3)] General Dollar Magnitude (GDM). Noncompliance - a failure in estimating, accumulating, or reporting costs to -- (1) Comply with applicable CAS; or (2) Consistently follow disclosed or established cost accounting practices. Reporting - Select relevant dollar data and present it in an intelligible manner.

26 CAS Coverage CAS & Disclosure Flow Statement Flow Chart

27 Processing Changes to Disclosed or Established Cost Accounting Practices. (a) Scope. This section applies to required, unilateral, and desirable changes in cost accounting practices. (b) Procedures. Upon receipt of the contractor's notification and description of the change in cost accounting practice, the CFAO, should review the proposed change concurrently for adequacy and compliance. The CFAO shall-- (1) If the description of the change is both adequate and compliant, notify the contractor in writing and-- (i) For required or unilateral changes (except those requested to be determined desirable changes), request the contractor submit a general dollar magnitude (GDM) proposal by a specified date, unless the CFAO determines the cost impact is immaterial; or (ii) For unilateral changes that the contractor requests to be determined desirable changes, inform the contractor that the request shall include supporting rationale and-- (A) For any request based on the criteria in (b)(3)(ii), the data necessary to demonstrate the required cost savings; or (B) For any request other than those based on the criteria in (b)(3)(ii), a GDM proposal and any other data necessary for the CFAO to determine if the change is a desirable change; (2) If the description of the change is inadequate, request a revised description of the new cost accounting practice; and (3) If the disclosed practice is noncompliant, notify the contractor in writing that, if implemented, the CFAO will determine the cost accounting practice to be noncompliant and process it accordingly.

28 Interest - on any increased costs paid as a result of the noncompliance FAR (a)(5), (a)(4), and (a)(5) provide that the Government will also recover interest on overpayments made to the contractor, including increased costs paid due to CAS noncompliances. Interest will be compounded daily from the date payment is made by the United States until the date the adjustment is effected, using the annual rate established under section 26 U.S.C of the 1986 Internal Revenue Code. This is the same interest rate used when defective pricing is found. The auditor should be alert to the potential significance of interest and offer to provide assistance to the CFAO in calculating interest due to the Government once the CFAO makes the final determination on the cost impact proposal audit report. The auditor should calculate daily compound interest using the CAS Noncompliance Cost Impact Interest Calculator located on DCAA s Intranet under DCAA SOFTWARE / APPLICATIONS LIBRARY. Calculating daily compound interest is in accordance with the Unites States Court of Appeals for the Federal Circuit (CAFC) ruling dated September 14, 2009; Case No Interest must be separately identified and remitted to the U.S. Treasury.

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