WG 77-17 - Identification of CAS Contract Universe at a Contractor's Plant
Whenever a contractor makes a change to its disclosed or established accounting practices or is determined to be in noncompliance, FAR requires the contractor submit a cost impact proposal. An integral part of the cost impact proposal is the listing of CAS-covered contracts and subcontracts which will be affected by the change or noncompliance.
The GAO (Government Accountability Office) reported that auditors were spending an inordinate amount of time verifying the completeness and accuracy of the lists submitted by contractors. The GAO recommended that DoD develop a procedure for identifying all the CAS-covered contracts and subcontracts at each contractor's (or subcontractor's) facility.
The CAS clause implicitly requires that contractors are responsible for supplying accurate and complete lists of its CAS covered contracts. However, to preclude any misunderstanding and a consequent loss of time, DoD issued the following guidance:
In order to comply with the requirements of the CAS clause, contractors should be required to maintain a system for identifying accurately and completely all contracts and subcontracts which contain the CAS clause. The ACO (Administrative Contracting Officer) should ensure that the contractor has such a system in place and that it is functioning effectively.Apparently, accurate record keeping was a problem back in 1977 and from our experience, is still a problem today.