Whitepaper: The Audit World's Biggest Myths
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Whitepaper: The Audit World's Biggest Myths
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Capital Edge Tip Line – August 21, 2025

CAS Board Discussions – Edition 11

In this week’s Capital Edge Tip Line, CEO Chad Braley dives deeper into the ongoing CAS Board Discussions and the areas that Capital Edge has followed and commented on during the open public period.

Key Updates from This Week’s Tip Line

CAS Board Discussions – What You Need To Know

What’s happening? CAS Board Discussions are underway and we're here to provide updates based upon what we've followed and commented on during the open public period.

What's being discussed?

  1. Statutory Threshold: Right now, the base CAS contract value of $2 million is tied to the same threshold used for Truthful Cost or Pricing Data (formerly known as TINA). The proposal would decouple them, with CAS having its own threshold, and TINA its own. There’s also talk of raising the TINA threshold beyond the scheduled inflation adjustment set to go into effect this October.
  2. Regulatory Threshold: There are rumblings that the CAS coverage threshold may jump from $50 million to $100 million. The current $7.5 million “trigger contract” value could be eliminated altogether. And the CAS-covered minimum value, currently $2 million, could rise to $10 million or even $25 million. These potential updates echo recommendations from the Section 809 Panel and other policy groups.
  3. Conformance to GAAP: The CAS Board is continuing its push to align certain standards more closely with GAAP. The key question is whether these areas are already adequately addressed in FAR 31 and GAAP, making CAS redundant.
    • In active review now are four standards:
      • 404: Capitalization of Tangible Assets
      • 408: Compensation for Personal Absence
      • 409: Depreciation
      • 411: Acquisition Cost of Material
    • Three more are under consideration for removal or revision:
      • 407: Standard Costs for Direct Labor and Materials
      • 415: Deferred Compensation
      • 416: Insurance Cost
  4. Cost Impacts: There’s discussion of a potential FAR deviation related to 36.003, in light of the 2023 NRD memo following the Raytheon case. That memo’s Scenario 2 contradicts the court decision and is viewed as unfavorable to contractors. Many are hoping for clearer alignment between CAS cost impact rules and the statute.
  5. CAS to Indefinite Delivery Contracts: This is an area we directly commented on during the open public period. The push is to apply CAS thresholds at the task order level, not at the total IDIQ value. That shift would help avoid the flawed assumption that a $200 million contract split across multiple vendors should automatically trigger CAS. One proposal suggests a $25 million threshold, still high enough to exempt most task orders, while keeping high-value contracts covered.

What this means for you:If these proposed CAS updates move forward, they could ease the compliance load for many contractors while keeping meaningful oversight in place. Discussions are underway and we’ll continue to monitor developments and keep you informed.

Looking for Expert GovCon Guidance?

Stay Ahead with Capital Edge

Whether you're trying to keep up with the ever-changing government contracting landscape or need help navigating the costs of non-compliance, Capital Edge is here to help and respond.

Have Questions? 

Contact us today to discuss how you can position your organization to stay ahead.

Capital Edge Tip Line – August 8, 2025

FAR Overhaul Update: FAR Part 31 Main Takeaways – Edition 10

In this week’s Capital Edge Tip Line, CEO Chad Braley dives deeper into the Revolutionary FAR Overhaul (RFO) and what you need to know about the changes to FAR Part 31.

Key Updates from This Week’s Tip Line

FAR Part 31 – What You Need To Know

What’s happening? We've been anticipating updates from the Revolutionary FAR Overhaul (RFO) and are starting to get answers.

What's changed?

What this means for you: This round of FAR updates didn’t eliminate complexity or streamline compliance. It just brought language up to date with current practices. Expect more buying guides, more trickle-down guidance, and if you're in compliance or contracts, plenty of job security.

Looking for Expert GovCon Guidance?

Stay Ahead with Capital Edge

Whether you're trying to keep up with the ever-changing government contracting landscape or need help navigating the costs of non-compliance, Capital Edge is here to help and respond.

Have Questions? Need Help?

Contact us today to discuss how you can position your organization to stay ahead.

Capital Edge Tip Line – June 25, 2025

DCAA Sustainment Rates, Audit Timelines & OTA Government Contracts - Edition 9B

With DCAA's FY2024 data now in focus, contractors are getting clearer insights into what sticks in an audit—and what doesn’t. In this week’s Capital Edge Tip Line, CEO Chad Braley breaks down the agency’s audit sustainment rates, completion timelines, and growing oversight into OTA government contracts. He also highlights where audit activity is rising in other agencies, including HHS.

Key Updates from This Week’s Tip Line

Audit Sustainment Rates – What’s Being Upheld

???? What’s happening? Nearly 49% of DCAA audit exceptions were sustained by contracting officers across all categories in FY2024.

???? Breakdown by audit type:

???? What it means for you:

???? Action Item: Treat every audit finding seriously. Even if the audit occurred years ago, current sustainment decisions may still apply.

Audit Timelines – How Long You Should Expect

???? What’s happening? Audit cycle times remain long, particularly for complex systems reviews.

???? Average durations:

???? Chad’s take: A low-risk letter from DCAA does not equal a clean bill of compliance. Many contractors assume approval when they’ve only passed the adequacy checklist.

???? Action Item: Prepare for extensive durations. Keep your documentation current, even if your last contact from DCAA was a simple memo.

OTA Government Contracts – Yes, They're Being Audited

???? What’s happening? DCAA evaluated over $550 million in OTA costs in FY2024, despite their FAR-exempt status.

???? What it means for you:

???? Action Item: Don’t rely on OTA exemptions. Structure records and reporting as if the agreement will be audited.

Third-Party Audits on the Rise – HHS Gets Active

???? What’s happening? Other agencies like HHS are leaning on third-party auditors to scrutinize historic contract activity.

???? Example: HHS recently initiated audits on a 2020 CAS change with a $75,000 cost impact—years after the fact.

???? Action Item: Be proactive in documenting cost changes and rate adjustments, even if years have passed. Third-party audits are expanding.

Looking for Expert GovCon Guidance?

Stay Ahead with Capital Edge

Whether you're preparing for a business systems review or need help navigating OTA government contracts, Capital Edge is your trusted compliance partner.

???? Have Questions? Need Help?

Connect with Capital Edge Consulting for proven audit strategies.

???? Contact us today to discuss your strategy for staying tariff-ready.

Stay informed. Stay compliant. Stay ahead.

Capital Edge Tip Line – June 20, 2025

Inside DCAA’s FY24 Annual Report to Congress with Chad Braley - Edition 9A

DCAA’s newly released FY24 Report to Congress offers a rare window into the agency’s audit activity, exception rates, and cost savings metrics. In this week’s Capital Edge Tip Line, CEO Chad Braley unpacks the highlights, questions the numbers behind the “return on investment” claims, and shares what it all means for contractors going forward.

Key Updates from This Week’s Tip Line

Audit Activity Snapshot: Where DCAA Focused Its Efforts

???? What’s happening? DCAA examined nearly $600 billion in contract costs, the most in five years, while claiming $5.1 billion in net taxpayer savings and a $7.20 return on every audit dollar.

???? What it means for you:

???? Action item: Forward pricing submissions remain high-risk for audit. Consider strengthening supporting documentation before submission.

Audit Exceptions by Category: What Got Flagged

???? What’s happening? DCAA identified $5.9 billion in audit exceptions—about 2.7% of the total costs reviewed.

???? Breakdown by type:

???? Action item: Prioritize internal reviews for forward pricing and terminations. Even with lower scrutiny, ensure incurred cost submissions are clean and defensible.

Monetized Estimates: DCAA’s ROI Calculation Controversy

???? What’s happening? DCAA now includes “monetized estimates” of cost savings from business system and CAS audits—even when no direct dollar findings are issued.

???? What it means for you:

???? Chad’s take: "We’ve seen system reviews identify material weaknesses without any financial findings. It’s unclear how DCAA is projecting cost savings from these reviews.”

ROI Rankings by Audit Type

???? Action item: Don’t just watch for audits, watch how agencies justify value. Audit scrutiny may not follow volume alone.

Looking for Expert GovCon Guidance?

Stay Ahead with Capital Edge

DCAA’s evolving focus, audit thresholds, and performance metrics directly impact how contractors prepare for oversight.

???? Have Questions? Need Help?

Reach out to Capital Edge Consulting to ensure your audit strategy aligns with DCAA expectations.

???? Contact us today to discuss your strategy for staying tariff-ready.

Stay informed. Stay compliant. Stay ahead.

Capital Edge Tip Line – June 11, 2025

Tariffs, Duties & Cost Strategy in Government Contracts with Chad Braley – Edition 8

With growing uncertainty around new tariffs, contractors are wondering how to handle potential price shifts and regulatory protections. In this week’s Capital Edge Tip Line, CEO Chad Braley offers practical insights into how federal contractors can prepare, propose, and protect themselves when duties are imposed mid-contract.

Key Updates from This Week’s Tip Line

Understanding FAR and DFARS Clauses Related to Tariffs

???? What’s happening? While “tariffs” aren’t mentioned directly in key regulations, terms like “duties” are and they matter. Relevant clauses include:

???? What it means for you:

???? Action item: Review your active contracts and proposal templates to ensure you are accounting for potential duties. Be proactive about exemptions and document cost reasoning clearly

Tariff Cost Planning for New Proposals

???? What’s happening? With tariff rules evolving, contractors must consider how to price and structure bids, especially those in pre-award stages.

???? What it means for you:

???? Action item: Evaluate where your goods and services are sourced and understand which materials may be affected. Build pricing flexibility into proposals where feasible.

Chad’s Take on the Bigger Picture

???? Chad doesn’t expect tariffs to be as catastrophic for government contractors as some fear. With the right preparation and contract structure, organizations can protect themselves and minimize exposure.

???? Claims and REAs (Requests for Equitable Adjustments) are likely to increase, but so is the opportunity to manage risk effectively.

Looking for Expert GovCon Guidance?

Stay Ahead with Capital Edge
Whether you're managing live contracts or preparing new bids, Capital Edge can help you align your cost strategy with regulatory protections.

???? Have Questions? Need Help?
Reach out to Capital Edge Consulting to talk through your specific contracting concerns.

???? Contact us today to discuss your strategy for staying tariff-ready.

Stay informed. Stay compliant. Stay ahead.

Capital Edge Tip Line – June 3, 2025

Navigating Government Contracting Updates with Chad Braley – Edition 7

From tariff volatility to sweeping federal procurement reforms, this week’s Capital Edge Tip Line dives into urgent updates that could affect how your contracts are priced, managed, and reimbursed. CEO Chad Braley breaks down how contractors should respond to shifting agency expectations and regulatory guidance.

Key Updates from This Week’s Tip Line

DOE Indirect Cost Caps – New Limits for Federal Awardees

???? What’s happening? The Department of Energy released new memorandums limiting indirect costs recoverable by:

???? What it means for you:

???? Action Item: Reevaluate indirect rate structures, especially if you’re pursuing active DOE funding opportunities. Watch NOFO language closely for cost recovery terms.

DCAA Final Decisions – Silent Audits Now Triggering Disputes

???? What’s happening? A wave of Contracting Officer Final Decisions (COFDs) is hitting contractors without prior audit warnings, often citing non-compliance, CAS violations, or questioned costs.

???? What it means for you:

???? Action Item: Prepare for increased enforcement. Shore up DCAA audit documentation, evaluate potential exposure areas, and engage early on audit or rate disputes.

FAR Consolidation – First Wave of Changes Arrives

???? What’s happening? The revolutionary rewrite of the Federal Acquisition Regulation has begun, with updates issued for:

???? What it means for you:

???? Action Item: Track ongoing FAR consolidation updates and prepare for further FAR changes. Monitor whether your agency introduces supplements or deviations.

Looking for Expert GovCon Guidence?

Whether you're navigating funding caps, audit risks, or regulatory overhauls, Capital Edge Consulting provides the strategic guidance you need.

???? Have Questions? Need Help?

If these developments could affect your business, don’t wait, reach out for support tailored to your compliance and contracting needs.

???? Contact us today to discuss your specific challenges and compliance needs.

Stay informed. Stay compliant. Stay ahead.

Capital Edge Tip Line – May 2, 2025

Navigating Government Contracting Updates with Chad Braley – Edition 6

From tariff volatility to sweeping federal procurement reforms, this week’s Capital Edge Tip Line dives into urgent updates that could affect how your contracts are priced, managed, and reimbursed. CEO Chad Braley breaks down how contractors should respond to shifting agency expectations and regulatory guidance.

Key Updates from This Week’s Tip Line

Tariff Impacts on Federal Contracts

???? What’s happening? Contractors are facing uncertainty as new tariff percentages are debated and implemented. While rates may shift, the focus is on how contracts handle these costs.

???? What it means for you:

???? Action item: Immediately assess relevant contract clauses and prepare internal guidance on how to account for tariffs during budgeting and cost disclosure.

Executive Order on Ensuring Commercial Cost-Effective Solutions

???? What’s happening? A recent Executive Order mandates agencies to justify any ongoing or planned purchases of non-commercial goods and services.

???? What it means for you:

???? Action item: Contractors should evaluate their current offerings and explore repositioning them as commercial solutions where possible. Monitor solicitations for updated compliance requirements.

DOE Workforce Reductions & Project Risk

???? What’s happening? The Department of Energy is undergoing significant personnel losses. Over 2,700 staff have opted into voluntary separation programs, with further reductions expected.

???? What it means for you:

???? Action item: Engage your DOE points of contact frequently. Prepare invoices proactively and clarify funding timelines to avoid disruptions.

Looking for Expert GovCon Guidence?

Whether you're navigating tariffs, agency mandates, or payment delays, Capital Edge is here to help you mitigate risk and maintain compliance.

???? Have Questions? Need Help?
If any of these changes impact your business, don’t hesitate to reach out to Capital Edge Consulting for guidance.

???? Contact us today to discuss your specific challenges and compliance needs.

Stay informed. Stay compliant. Stay ahead.

Capital Edge Tip Line – April 21, 2025

Navigating Government Contracting Updates with Chad Braley – Edition 5

From executive orders reshaping defense acquisitions to sweeping changes in research grant funding and regulatory rewrites, this week’s Capital Edge Tip Line delivers must-know updates for Government contractors and research institutions. CEO Chad Braley dives into how these developments may impact your compliance strategy and cost structure moving forward.

Key Updates from This Week’s Tip Line

Executive Order on Modernizing Defense Acquisition Reform

???? What’s happening? A new Executive Order initiates sweeping defense acquisition reform, directing the Department of Defense (DoD) to prioritize commercial acquisition strategies and streamline internal procurement processes.

???? What it means for you:

???? Action Item: Evaluate your DoD programs for compliance with performance benchmarks and be prepared for increased scrutiny of cost, timeline, and strategic value.

DOE Follows NIH in Indirect Cost Limits on Research Grants

???? What’s happening? The Department of Energy (DOE) has issued new policy guidance capping indirect costs for grants to research institutions and universities at 15%—mirroring NIH’s controversial playbook.

???? What it means for you:

???? Action Item: Assess current grant-funded projects for exposure to this cap and explore options for reclassifying certain expenses as direct costs. Be proactive in preparing legal and financial strategies.

FAR 2.0 Rewrite – The Shift Toward Statutory Compliance

???? What’s happening?

The Federal Acquisition Regulation (FAR) is undergoing a major transformation, with non-statutory content being removed and repurposed into “buying guides.”

???? What it means for you:

???? Action Item: Begin evaluating current contract practices against statutory requirements. Track future buying guide releases and plan for increased variability in how guidance is applied.

Looking for Expert GovCon Guidence?

The pace of change in federal contracting has never been faster. The Capital Edge Tip Line is your trusted source for expert guidance on compliance, audit readiness, and regulatory transformation.

???? Have Questions? Need Help?
If any of these changes impact your business, don’t hesitate to reach out to Capital Edge Consulting for guidance.

???? Contact us today to discuss your specific challenges and compliance needs.

Stay informed. Stay compliant. Stay ahead.

Capital Edge Tip Line – April 8, 2025

Navigating Government Contracting Updates with Chad Braley – Edition 4

Federal contracting is experiencing a seismic shift with the rewrite of the Federal Acquisition Regulation (FAR), agency restructures, and widespread layoffs that could disrupt programs and timelines. In this week’s Capital Edge Tip Line, CEO Chad Braley delivers a fast-paced breakdown of the latest developments, from the 40th anniversary of the FAR to looming compliance and audit implications across HHS, DCAA, and NIH.

Key Updates from This Week’s Tip Line

FAR Turns 40 – And It’s Getting Rewritten

????What’s happening? April 1 marked the 40th anniversary of the Federal Acquisition Regulation. Now, a major rewrite is underway.

???? What it means for you:

Action Items: Contractors should prepare for evolving compliance requirements by reviewing current FAR sections and tracking FAR Council updates.

DCAA Reorganization – Realignment and Office Closures

???? What’s happening? The Defense Contract Audit Agency is undergoing significant restructuring.

???? What it means for you:

???? Action item: Audit preparedness is more critical than ever. Ensure audit trails and documentation are up-to-date and compliant with current expectations.

HHS Layoffs – Program Offices Vanishing

???? What’s happening? Mass layoffs at Health and Human Services have eliminated entire program offices, leaving contractors with active contracts but no points of contact.

???? What it means for you:

???? Action item: Immediately identify all HHS contracts and assess who your current contacts are. Prepare to act quickly on terminations or restructuring guidance.

NIH Indirect Rate Litigation – Still in Limbo

???? What’s happening? Litigation continues around NIH’s attempt to cap indirect rates on research grants.

???? What it means for you:

???? Action item: Stay in close contact with legal and grant management teams to monitor the case. Prepare budgets for both capped and uncapped scenarios.

Looking for Expert GovCon Guidence?

Stay Ahead with Capital Edge The pace of change in federal contracting has never been faster. The Capital Edge Tip Line is your trusted source for expert guidance on compliance, audit readiness, and regulatory transformation.

???? Have Questions? Need Help?
If any of these changes impact your business, don’t hesitate to reach out to Capital Edge Consulting for guidance.

???? Contact us today to discuss your specific challenges and compliance needs.

Stay informed. Stay compliant. Stay ahead.

Capital Edge Tip Line – April 1, 2025

Navigating Government Contracting Updates with Chad Braley – Edition 3

Federal compliance continues to evolve, with significant updates impacting government contractors across multiple fronts. In this week’s Capital Edge Tip Line, Chad Braley, CEO of Capital Edge Consulting, shares expert analysis on the latest DCAA audit program updates, GSA’s procurement consolidation, and new USAID compliance guidance. Whether you're in compliance, finance, or contract management, these insights are essential for staying ahead.

In Edition 2, Chad, delves into critical developments, including:

Key Updates from This Week’s Tip Line

Major Overhaul: 30+ DCAA Audit Program Changes

???? What’s happening? DCAA has quietly released or revised over 30 audit programs, impacting home office allocations, professional consultant costs, estimating systems, and accounting systems.

What it means for you:

???? Action item: Contractors should assess which audit programs apply to their operations and confirm internal controls and documentation meet the updated standards.

GSA Procurement Consolidation: $400B+ in Federal Contracts

???? What’s happening? GSA is set to consolidate over $400 billion in acquisition services, dramatically increasing its procurement footprint.

What it means for you:

???? Action item: Monitor GSA procurement updates and engage early with contracting officers to stay ahead of changes in contract administration.

USAID Compliance Alert: Stop Work Order Invoicing

???? What’s happening? USAID issued updated guidance allowing grant recipients to begin invoicing for costs related to stop work orders. While initially targeting grants, the guidance will likely extend to contractors.

What it means for you:

???? Action item: Prioritize assembling and submitting invoices for stop work order costs. Seek advisory support to ensure completeness and compliance.

Looking for Expert GovCon Guidence?

Stay Ahead with Capital Edge The regulatory environment is shifting quickly, and staying proactive is essential. The Capital Edge Tip Line delivers real-time updates and expert perspectives to help you stay compliant and competitive.

???? Have Questions? Need Help?
If any of these changes impact your business, don’t hesitate to reach out to Capital Edge Consulting for guidance.

???? Contact us today to discuss your specific challenges and compliance needs.

Stay informed. Stay compliant. Stay ahead.

About Capital Edge Consulting

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Whitepaper: The Audit World's Biggest Myths
Download Now
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