Practitioner Album for Final Rule on Conformance of CAS to GAAP for Cost Accounting Standards 404, 408, 409, and 411

Summary:

 

On Date the CAS Board issued Final Rule (FR Ref) Conformance of Cost Accounting Standards (CAS) to Generally Accepted Accounting Principles (GAAP) for CAS 404, 408, 409 and 411.

This final rule is part of the CAS Board’s larger project to conform CAS to GAAP where comparable requirements in GAAP protect the Government’s interest and promote uniformity and consistency.

CAS 404 Capitalization of Tangible Assets

 

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ASC 360 - Property, Plant and Equipment

ASC 360-10-05-3

ASC 360-10-20

ASC 360-10-35-4

ASC 360-10-35-33

ASC 205-Presentation of Financial Statements

ASC 205-10-20

ASC 210-Balance Sheet

ASC 210-10-45-4

ASC 210-10-S99-1

ASC 235-Notes to Financial Statements

ASC 235-10-50-1

ASC 805-Business Combinations

ASC 805-10-25-1

ASC 805-20-30-1

ASC 805-50-30-5

ASC 820-Fair Value Measurement

ASC 820-10-5

ASC 835-Interest

ASC 835-20-05-1

ASC 835-20-25-5

ASC 845-Nonmonetary Transactions

ASC 845-10-30-1

ASC 845-10-50-1

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CASB Disclosure Statement Part V - Depreciation and Capitalization Practices

CAS 401 Consistency in Estimating, Accumulating, and Reporting Costs

CAS 402 Consistency in Allocating Costs Incurred for the Same Purpose 

9903.201-4 CAS Contract Clauses

The Board determined that current GAAP requirements were essentially the same as those in CAS 404 with the exception of the requirement protecting the government from paying duplicative costs when government contractors merge or are acquired.

Retained Content

The table below identifies the content that was retained from CAS 404 where it has been relocated to in CAS 405. 

Cost Accounting Practice Impacts

The Board expects that contractors will continue to follow their existing practices as they are both compliant with CAS and GAAP.  Any current or future changes related to capitalization of the acquisition costs of tangible assets will be considered a voluntary change.  

CAS 408 Accounting of Costs of Compensated Personal Absence

 

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ASC 710 - Compenstation - General https://www.fasb.org

ASC 710-10-15-3

ASC 710-10-25-1

ASC 710-10-25-2

ASC 710-10-25-3

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CASB Disclosure Statement Part VI - Other Costs and Credits

CAS 401 Consistency in Estimating, Accumulating, and Reporting Costs

CAS 402 Consistency in Allocating Costs Incurred for the Same Purpose

CAS 406 Cost Accounting Period 

FAR Part 31

Compensation for personal services

9903.201-4 CAS Clauses

9903-201-9 Treatment of Certain Compliant Cost Accounting Practice Changes Related to Conformance of CAS to GAAP. 

The Board determined that current GAAP requirements are essentially the same as those in CAS 408 and concluded that reliance on GAAP would materially achieve the uniformity and consistency necessary for government contracting. CAS 408 is eliminated in its entirety with no retained content.

Cost Accounting Practice Impacts

The Board recognizes that conformance to GAAP related to CAS 408 may result in accounting practice changes. These changes would be exempt from the required cost impact process.

CAS 409 Depreciation of Tangible Capital Assets

 

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ASC 360 - Property, Plant and Equipment https://www.fasb.org

ASC 360-10-35-3

ASC 360-10-35-4

ASC 360-10-35-7

ASC 360-10-35-8

ASC 360-10-35-9

ASC 360-10-35-21

ASC 360-10-35-22

ASC 360-10-30 through 35-33

ASC 360-10-40-4

ASC 360-10-40-5

ASC 250 - Accounting Changes and Error Corrections

ASC 250-10-20

ASC 250-10-45-1

ASC 250-10-45-2

ASC 250-10-45-17 through 45-20

ASC 250-10-50-4

ASC 350 - Intangibles-Goodwill and Other

ASC 350-30-35-1 - through 35-5

ASC 805 - Business Combinations

ASC 805-20-25-1

ASC 835 - Interest

ASC 835-20-25-5

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CASB Disclosure Statement Part V - Depreciation and Capitalization Practices

CAS 401 Consistency in Estimating, Accumulating, and Reporting Costs

CAS 402 Consistency in Allocating Costs Incurred for the Same Purpose

CAS 418 Allocation of Direct and Indirect Costs

9903.201-4 CAS Clauses

FAR Part 31

Advance Agreements

Indirect Costs

Depreciation

Gains and Losses on Asset Diposition

Business Combinations

Insurance

The Board determined that current GAAP requirements were essentially the same as those in CAS 409 with the exception of certain requirements related to agreement on service life for specific assets, measurement of gains and losses on asset disposition, and gains and losses for other than arms-length transactions.

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GAAP does not have equivalent requirements for these scenarios. The Board determined that retaining the requirements from CAS 409 is necessary to protect the Government’s interest. The retained content was moved from CAS 409 to CAS 405 instead of maintaining an entire standard with minimal content.

Retained Content

The table below identifies the content that was retained from CAS 409 where it has been relocated to in CAS 405. 

 

Cost Accounting Practice Impacts

The Board expects that contractors will continue to follow their existing practices as they are both compliant with CAS and GAAP.  Any current or future changes related to capitalization of the acquisition costs of tangible assets will be considered a voluntary change. 

CAS 411 Accounting for Acquisition Costs of Material

 

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ASC 330 - Inventory https://www.fasb.org

ASC 330-10-05-2

ASC 330-10-05-3

ASC 330-10-30-1

ASC 330-10-30-9

ASC 330-10-30-12

ASC 330-10-30-14

ASC 330-10-30-15

ASC 330-10-50-1

ASC 340-Other Assets and Deferred Costs

ASC 340-40-25-7

ASC 606-Revenue from Contracts with Customers

ASC 606-10-05-3

ASC 606-10-05-4

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CASB Disclosure Statement Part II-Direct Costs

CAS 401 Consistency in Estimating Accumulating, and Reporting Costs

CAS 402 Consistency in Allocating Costs Incurred for the Same Purpose

CAS 418 Allocation of Direct and Indirect Costs

9903.201-4 CAS Clauses

FAR 52.216-7 Allowable Cost and Payment

DFARS 252.242-7997 (Deviation 2026O0050) MMAS

FAR Part 31

Credits

Material

The Board determined that current GAAP requirements are essentially the same as those in CAS 411 and concluded that reliance on GAAP, other CAS standards, and FAR Part 31 would materially achieve the uniformity and consistency necessary for government contracting. CAS 411 is eliminated in its entirety with no retained content.

Cost Accounting Practice Impacts

The Board expects that contractors will continue to follow their existing practices as they are both compliant with CAS and GAAP. Any current or future changes related to capitalization of the acquisition costs of tangible assets will be considered a voluntary change.