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FYI, a recently published (redacted) ASBCA decision sustains a contractor's appeal of a COFD related to changes in cost accounting practice. The DACO "abused her discretion" by failing to strictly follow FAR 30.602, specifically the mandatory consideration as to whether the cost impact from the contractor's changes to cost accounting practices was material in amount. A very important decision for those dealing with CAS compliance. http://www.asbca.mil/Decisions/2016/58068 Raytheon Company, Space & Airborne Systems 8.9.16 (REDACTED VERSION).pdf