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CAS Board Doubles Full-Coverage Threshold to $100M
The rule relieves 200-plus contractors of full CAS, but single-award IDC holders may find themselves pulled in rather than let out.
The CAS Board published two final rules September 1, effective October 1, that double the full-coverage threshold from $50M to $100M, raise the basic coverage threshold from $2.5M to $35M, and eliminate the trigger-contract framework. The Board also rescinded CAS 407, which governed standard-cost accounting for direct material and direct labor. More than 200 entities stand to shed full CAS obligations. But the rules cut both ways: single-award IDCs will now be assessed for CAS applicability at the ceiling value, not the task-order level, meaning some contractors will face full CAS on vehicles they'd structured to stay under the old threshold.