I have several contracts that currently have DFARs 252.242.7005 Contractor Business Systems but are CAS exempt. Until recently, it was my understanding that since the contracts are CAS exempt, the CBS requirements are not applicable since 252.242.7005 states, "This clause only applies to covered contracts that are subject to the Cost Accounting Standards under 41.U.S.C. chapter 15, as implemented in regulations found at 48 CFR 9903.201-1." My leads have now instructed me to request from the contractor a disclosure statement for their purchasing and estimating system regardless of their CAS exemption. Regardless of CAS, the ACO would have to make a determination for approval vs disapproval which would then be input into CBAR.
My question is whether this is the correct interpretation of the CAS and CBS clauses since it seems very backwards to me. I have always thought that CAS drives CBS which leads to a system review rather than doing a systems review then determining CAS. The contractor is also hung up on the issue since they know they are CAS exempt.