Is the change described in the scenario background considered a cost accounting practice change and subject to contract adjustment under the the CAS Clause.
This response is based on the information provided. We suggest you discuss with your contracting officer and/or legal department as appropriate.
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It's possible that a change in rate composition could result in the need for the contractor to analyze the cost impact and let us know. Since the method the contractor uses to estimate and propose costs needs to be consistent with the way it accumulates and reports costs, a change in rate composition could result in a shifting of costs between fixed-price, cost-reimbursement, and its commercial business. If the contractor is accumulating and reporting costs using the composite rates, any change to how the composite rate is calculated would alter the measurement and allocation of costs to contracts. In this case the contractor would be obligated to show us the impact of that change. However, if the composite rates are an estimating technique and the cost accounting practice for actual costs is unchanged and accumulates and reports at greater detail than the estimate, then no analysis of cost impact is necessary.