Today we resume our series on the CAS Working Group Guidance Papers. Between 1975 and 1981, DoD convened a group of CAS "experts" to come up with practical solutions to issues that contracting officers were facing in trying to interpret and apply the (then) new rules and regulations being promulgated by the Cost Accounting Standards Board (CASB). During that time, the Working Group published a total of 25 "interim" guidance papers. According to DoD, twenty of the 25 interim papers are still current. The complete working group guidance papers can be downloaded here. As we noted in our first blog in this series, these are not the best quality but to our knowledge, are the only ones available on the Internet for free.
WG 77-16 - Applicability of CAS to Letter Contracts
The standard CAS clause require CAS Covered contractors to comply with all Cost Accounting Standards in effect on the date of contract award or the date shown on the signed certificate of current cost or pricing data.
This guidance addresses two questions: i) does CAS apply to letter contracts and if so, when? and ii) what significance does definitization of a letter contract have?
CAS is applicable to letter contracts as of the date of award unless it has been determined that the contract is excluded under one of the exemptions from CAS requirements. Definitization of the contract would not trigger any new Standards since definitization is a contract modification rather than a new contract (see Interim Guidance Paper WG 76-2).