Higher Limits Mean Fewer Rules for Small Gov Deals
Published Date: 3/20/2026
Proposed Rule
Summary
The government wants to raise the money limits that decide which companies must follow special cost rules when working on federal contracts. This change mainly affects businesses dealing with big government projects, making it easier for smaller contracts to skip some paperwork. If you have thoughts, you’ve got until April 20, 2026, to speak up!
Analyzed Economic Effects
5 provisions identified: 4 benefits, 1 costs, 0 mixed.
Full CAS Threshold Raised to $100M
The rule would raise the regulatory thresholds for full Cost Accounting Standards (CAS) coverage and disclosure statements from $50 million to $100 million. The Board estimates the change would reduce entities subject to full coverage from 773 to 564 while maintaining $1.21 trillion of the dollars currently covered.
Basic CAS Applicability Raised to $35M
The proposal would change the basic statutory CAS applicability threshold from $2.5 million (with a $7.5 million trigger) to a single stated dollar threshold of $35 million and eliminate the $7.5 million trigger contract concept. The Board and OMB estimate this change would reduce CAS-covered business segments by about 60% while retaining over 90% of dollars currently subject to CAS coverage.
Waiver Authority Raised to $100M
The proposed rule raises executive agency head authority to waive CAS from $15 million to $100 million, allowing agency heads to grant CAS waivers for contracts up to $100 million without Board approval. This implements changes made to 41 U.S.C. 1502(b)(3).
CAS Rules Clarified for IDCs
The rule clarifies how CAS exemptions apply to indefinite delivery contracts (IDCs): for multiple-award IDCs, CAS applicability is determined at the individual task or delivery order level using that order's base and all options; for single-award IDCs, applicability is determined at the time of award using the IDC's base and all options (ceiling).
Removal of Small-Segment Disclosure Exemption
The Board proposes eliminating the exemption that allowed a segment not to submit a Disclosure Statement if, during the most recently completed cost accounting period, the segment's CAS-covered awards were less than $10 million and less than 30% of segment sales. The Board says this exemption is no longer necessary given the higher thresholds.
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Key Dates
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