Cost Accounting Standard Board

In the early years of the 20th century, the US Federal Government had accounting requirements designed in such a way as to protect it from making overpayments for goods and services. These requirements governed the degree to which costs are apportioned by contractors to their contracts with the government. In 1970 the congress created the Cost Accounting Standards Board (CASB) whose function was to develop a set of uniform and consistent standards. The board came up with 19 standards that imposed accounting requirements that were unique and significant on companies awarded contracts by the government. The paper is going to discuss the rise and fall of the Cost Accounting Standards Board.More often than not, the federal government use contracts in which their price is based on the contractor's cost of performance, the government therefore recognized the need to protect itself from mischarges by defining the costs that can be recovered from contracts and also put in place rules for the allocation of costs that are indirect to the contracts. The General Accounting Office was then given the mandate to explore the possibility of putting in place new guidelines. GAO submitted a report that comprehensively outlined the need of such guidelines and in 1970; the congress adopted the report and created CASB, as an independent board within the legislature. The Board was initially chaired by a Comptroller General who was given the power to appoint four other members. CASB was given the authority to promulgate standards that are designed to realize uniformity and consistency in practices of cost accounting that are used by the federal contractors on national defense contracts that were in excess of $100,000. By the start of the 1980s, the board had issued 19 standards that stated among other things, principles for measurement, assigning, and allocation of contracts. The board also exempted some classes of contracts from CAS coverage. In 1980 the CAS Board was dissolved after congress saw that it had accomplished its task but the standards set up remained in effect. The board was reestablished again in 1988 (CASB Review panel, 1999).In establishing and the subsequent reestablishing of the board, congress said that besides issuing of the Cost Accounting Standards, the CASB would also deal with matters that were traditionally performed by agencies for contracting as an area of contract administration. It was to regulate the implementation of CAS requirements, to call upon contractors to disclose their practices of cost accounting and agree to the adjustment of contract price for any increase in costs paid a particular contractor if there is a voluntary change in their accounting practices or a failure to adhere to CAS. By then the Congress strongly believed that an independent agency, different from the contracting agencies, was needed to oversee the establishment and implementation of the CAS. They felt that the contracting agencies could not be trusted to establish and implement an effective system properly. But currently, recent acquisitions emphasize increased discretion to be accorded to agencies and their officials in charge of contracting in procurement processes. This has greatly reduced the board's powers reducing it from an institution that was once thriving with authority in the regulation of procurement activities to one that now depends on other agencies to oversee the implementation of its standards.

When the CAS Board was first set up, its mandate was to come up with standards that establish a framework for contractors to measure, assign, and allocate costs. Other regulations for procurement had broader applications like implementing government procurement policy objectives and also determining the allowability of some particular costs. By then the stakeholders realized that in order to achieve their objectives, the CAS Board had to take precedence over other regulations for procurement. When it was first formed, the CAS Board was located in the legislative branch, but when it was reestablished, the current board was placed under the executive branch in the OFPP; this meant that it was within OMB. The original Board constituted five members, a number that was retained in the present Board. The comptroller chaired the first CAS Board with majority of the Board members coming from the private sector, but after reestablishment, the Board is chaired by the OFPP administrator and majority of its members are employees of the government. When you at the appropriation of funds, the original board had its funds appropriated separately not like the present Board which receives its funding from the OMB appropriation. The original board enjoyed adequate staffing when compared to the current one that is understaffed. These are just some of the differences showing how the board has gradually changed over the years (DCAA, 2010).The placement of the Board in the OFPP has led it into considerations of procurement policy that are not substantially accounting concerns. In its authorizing legislation, the Board is supposed to be an independent board, but currently it is made to be subordinate to OFPP and OMB. There is no doubt that this affects its ability to work as an independent entity. The primary missions of these boards are significantly different, CAS Board was formed to establish accounting rules and regulations for government contractors, and OMB on the other hand gives budgetary and other support to the president. This therefore does not allow it to have open discussions concerning preliminary administrative positions on important issues until they are finalized. The OFPP procurement policy mission is broader than just maintaining the CAS Board. It provides a direction and leadership that is of a higher level to the government's procurement system. In such cases, instances of some policy procurement considerations influencing board pronouncements can not be ruled out. The authorizing legislation for the CAS Board allows it to have express use of advisory committees and task forces but this has not happened because formation of such committees will be subject to the Federal Advisory Committee Act (FACA) that requires open access to the public. Lack of the use of advisory committees limit the Boards progress in resolving pressing issues of cost accounting (CASB, 1999).

There are also a number of activities carried out that make it unpopular in recent times. For instance, the board was given authority to grant waivers where appropriate. But the board's waiver procedures are stringent making it difficult for those seeking waivers. In fact the Board's statement of objectives, policies and concepts indicates its unwillingness to grant waivers, it shows that waivers would only be granted in rare and unusual circumstances. This explains the few requests made since the Board was formulated; the stringent criteria discourage many firms from seeking waivers even when they know a waiver is appropriate. This is one of the reasons why a consideration of delegating some duties to other agencies was arrived at. It is argued that although has the authority, procurement rules have evolved towards empowering contracting parties to exercise business judgment. It is even suggested that contracting agencies should be given the discretion to determine waivers from CAS are appropriate or not. This if implemented will mean that CASB's powers will be reduced (CAS Board, n.d).Many parties have come forward to say that CAS standards should be reviewed to reflect the many years of industry and government experience, the evolution of other departments such as the GAAP, and the emergence of acquisition reform. In the initial stages of its implementation, many contractors were fully CAS covered compared to the situation today where more and more contractors are not covered by CAS or are just subject to modified coverage because of the increased thresholds for applicability of CAS and also due to the declining value of contracts covered by CAS. All these show that CAS has evolved over the years, from the promulgation of the first standard, to the initial disclosure statement adequacy reviews; from the implementation of CAS 410 and 418, and the review of related cost impact statements. In those years many companies had CAS experts who were primarily grouped through continuous processes of training and exposure through CAS monitors. These were the people in whom one could confer on CAS related problems; it made CAS familiar to many. All this has now changed; many current contractors are not covered by CAS. The present CAS Board is not independent as it was intended; it has been placed under the OFPP, the OMB, it is understaffed. Many contractors see its standards as being restrictive (CAS Contract clause 2007).As it has been shown, CASB come into being with the zeal and determination to regulate government procurement processes. But as years passed things started to change and therefore a decline in the use of CAS ensued. Many claim that significant administrative costs are presented by CAS because its requirements are very complex and labour intensive. Reports have indicated that the complexity brought about by CAS requirements has seen companies establishing separate business units for commercial and government operations. They claim that it is costly for one to operate a government segment than operating a commercial one. The only option is therefore to integrate CASB with other agencies and this has seen a reduction of CASB mandate especially when compared to what it used to be in the initial years of its formation.

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