Is changing from a CAS Non-Compliant to a CAS Compliant Practice considered a Cost Accounting Practice Change?
I have always considered it a CAP change subject to FAR 30.605 and other types of CAP Changes subject to FAR 30.604 for their resolution.
I have others that have argued that it is not a CAP Change, but only a change from a CAS Noncompliant Change to a Compliant Practice.
I sent this on11/21/2018 and never received a response so I am sending it again.
This response is based on the information provided. We suggest you discuss with your contracting team, program manager and/or legal department as appropriate.
Open full Question Details
There are three types of cost accounting practice changes listed in FAR Part 30 and CAS. Those cost accounting practice changes are required, desirable and unilateral. All three types of cost accounting practice changes involve changing from one compliant practice to another compliant practice. A noncompliance is a contractor’s failure to comply with a CAS standard or regulation. The contractor’s correction of a noncompliance must be processed as a noncompliance, i.e., it is not a change in cost accounting practice.