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The cost re ects sound business practices, arm s length bargaining, and the requirements of
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federal and state laws and regulations
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A prudent businessperson would take similar action, considering his or her responsibilities
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to the business owners, employees, customers, the government, and the public
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Signi cant deviations from established contractor practices inordinately increased contract
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costs
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Allocability Although the concept is not complicated, its application can become extremely dif cult and frequently controversial The cost principles consider a cost to be allocable if it is assignable or chargeable to one or more cost objectives in accordance with the relative bene ts received or other equitable relationship Subject to the foregoing, a cost is allocable to a government contract if it:
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Is incurred speci cally for the contract Bene ts both the contract and other work, or both government work and other work, and can
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be distributed to them in reasonable proportion to the bene ts received
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Is necessary to the overall operation of the business, although a direct relationship to any
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particular cost objective cannot be shown If the cost is direct, it is recoverable against a speci c contract; if indirect, only an appropriate portion of the expense can be recovered on a given contract Disagreements often focus on the extent of bene t to the government There is no requirement that bene t to the government be capable of precise measurement
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Cost Accounting Standards or Generally Accepted Accounting Principles Certain CAS have been speci cally incorporated into the cost principles A practice inconsistent with those standards is subject to disallowance under the cost principles as well as a nding of noncompliance with the standards If CAS are not applicable, GAAP may be an authoritative reference for determining appropriate accounting treatment Although GAAP have been de ned for a variety of nancial reporting practices, CAS address the allocability of costs to speci c nal cost
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373 SPECIFIC ACCOUNTING REQUIREMENTS
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objectives (eg, contracts) Consequently, the courts and boards of contract appeals have generally given considerable weight to GAAP only when more de nitive accounting treatment is not prescribed in the acquisition regulations or the contract itself The boards and courts have cautioned against relying on GAAP to determine the allocability of costs to government contracts by noting that such principles have been developed for asset valuation and income measurement and are not cost accounting principles as such, although cost accounting concepts may evolve out of them 2 When the cost accounting treatment permitted by GAAP is contrary to the criteria provided in the CAS, cost principles, or the contract, these latter criteria generally prevail
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Selected Costs The cost principles are revised on occasion to re ect public policy considerations, administrative convenience, and congressional interest The acquisition regulations require that expressly unallowable costs, plus all directly associated costs, be identi ed and excluded from proposals, billings, and claims submitted to the government A directly associated cost is a cost that is generated solely as a result of incurring another cost and would not have been incurred had the other cost not been incurred Salary costs of employees who engage in activities that generate unallowable costs generally are treated as directly associated costs to the extent of the time spent on the proscribed activity Directly associated costs are only unallowable to the extent that they are material in amount, except where the salary expenses are themselves unallowable The cost principles do not address each cost that may be incurred In the absence of a cost principle for a particular cost item, the determination of allowability is to be based on the principles and standards of FAR Subpart 312 and the treatment of similar or related selected items in FAR 31205 Cost items described in the cost principles are listed in Exhibit 371, with a brief summary as to whether or not the cost is allowable
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(c) COST ACCOUNTING STANDARDS The original CASB was established in 1970 as an agent of Congress During its turbulent life from 1970 to 1980, CASB promulgated accounting practice disclosure requirements and 19 CAS, which have the full force and effect of law In 1988, a ve-member CASB was reestablished within the executive branch (Of ce of Federal Procurement Policy OFPP), and chaired by the OFPP Administrator The other four members consist of a DOD member, a General Services Administration (GSA) member, an industry member, and a private-sector member knowledgeable in cost accounting matters The current board, like its predecessor, is authorized by statute to:
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Issue and amend regulations Issue standards, and amend existing standards, to achieve uniformity and consistency in the
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cost accounting principles followed by prime contractors and subcontractors in estimating, accumulating, and reporting costs for pricing, administering, and settling negotiated prime contracts and subcontracts Exempt from its standards certain classes or categories of contractors Require contractors to disclose in writing their cost accounting principles, including methods of distinguishing direct costs from indirect costs and the basis used for allocating indirect costs Require contractors to agree to contract price adjustments in favor of the government, with interest, for any net increased costs resulting from failure either to comply with duly promulgated CAS or to consistently follow their cost accounting principles in pricing contract proposals and in accumulating and reporting cost of contract performance The CASB s Rules, Regulations, and Standards are codi ed in Title 48 of the Code of Federal Regulations, 99
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Celesco Industries, ASBCA No 22401, January 31, 1980, Contract No 80-1 BCA 14,271
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