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jeff4757

CAS and subcontractor ceiling

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My firm is planning to award a SOW to a subcontractor.

We will incrementally fund the subcontract but the total scope/award is $1.08mm

The subcontractor is concerned with exceeding their CAS limit for the year.

Is the CAS ceiling limit based on potential award OR the amount FUNDED??

Your feedback is appreciated.

Thank you!

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The CAS value of a contract is the full contract award value, assuming all priced options are awarded. Funding is irrelevant.

Hope this helps.

P.S. If your subK is afraid of CAS compliance, may I respectfully suggest you have a high-risk subK?

H2H

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There's not enough information here to determine if the subK needs to be concerned with CAS coverage (particularly full CAS).

If they can't, or won't, comply with modified CAS, I would be very concerned about awarding to them.

Paul

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Just sayin' ... there is not very much difference between Full and Modified CAS coverage if the contract in question is Cost-Type. That's because many of the Standards are incorporated (at least in part) into the Part 31 Cost Principles. My memory is whispering in my ear that about 10 of the 19 Standards are in the Cost Principles and compliance with them is a condition of cost allowability. (But don't quote me on that, please.)

And some of those in Part 31 are the tougher Standards (e.g., 412, 415).

It surprises a lot of otherwise "exempt" or "modified" contractors that they still have to comply with many of the Standards when they receive a cost-type contract. And that includes small businesses.

CAS, creating jobs for accountants and lawyers since 1970.

H2H

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