Pathway 7 — Pilot cohort enrolling

When DCAA questions your indirect rates, your team answers with the standard, the math, and the memo. Not a guess.

For controllers, CFOs, government contract accounting managers, and DCAA-compliance leads at aerospace and defense contractors. Build cost accounting that survives a DCAA audit: know whether CAS applies and at what level, defend every cost as allocable, and stay ahead of the 2026 threshold and GAAP-conformance changes rewriting the framework right now. Backed by an AI Workbench that reads the contract, runs the applicability determination, and drafts the memo.

Who this is for

Controllers, CFOs, government contract accounting managers, DCAA-compliance leads, and FP&A leaders at defense contractors and their subcontractors. Anyone who owns the accounting system DCAA examines, the indirect rates that price every proposal, and the incurred-cost submission that closes the year.

The stakes

What a weak cost accounting system actually costs

Disapproved system, withheld billings

DCAA finds your accounting system inadequate. Billings get withheld, progress payments slow, and cash you have already earned sits frozen while you fix a control you did not know was weak.

Cost disallowed on the incurred-cost audit

The auditor reclassifies a pool, challenges an allocation base, or disallows a cost as unallowable under FAR Part 31. The rate drops. The recovery you booked evaporates, sometimes a year after you spent it.

Undisclosed practice change triggers cost impact

A change in cost accounting practice you did not disclose triggers a cost-impact analysis. Now you owe the government the difference, plus interest, and you are on the 60-day correction clock.

The 2026 changes blindside you

The FY2026 NDAA moved the thresholds. The CAS Board is conforming standards to GAAP and has proposed eliminating several. Your team is still running last year's framework. Your training is teaching numbers that are not true anymore.

The outcome

What your finance team becomes

After rollout, here is what changes.

CAS-fluent finance team Every analyst can read a contract and know in minutes whether CAS applies, at what coverage level, and which FAR 52.230 clause attaches. No more waiting on outside counsel for the basics.
Allocations that survive the audit Your team defends every cost as allocable, knows exactly where FAR Part 31 allowability diverges, and builds indirect rates that hold up from forward pricing through billing to final rates.
Ready for the 2026 transition Your team knows the old framework, the live transition, and the new one, every threshold and standard date-stamped. You walk into 2026 awards knowing exactly what changed and when.
The accounting system DCAA accepts A Disclosure Statement that matches actual practice, a system that passes the adequacy checklist, and an incurred-cost submission that closes without findings.
What's included

What's in this pathway

Every course includes role-profile onboarding, AI Workbench access, Manager Dashboard visibility, and Audit-Evidence Package export.

Pilot cohort

Cost Accounting Standards (CAS) for Government Contractors

Read any government contract and know whether CAS applies and at what coverage level. The 19 standards, including the ones the CAS Board has proposed eliminating, plus allocable vs allowable, the indirect rate machine, the Disclosure Statement, cost-impact and noncompliance, and the FY2026 NDAA threshold restructuring effective June 30, 2026. Built for controllers, CFOs, and DCAA-compliance leads. Pilot cohort enrolling now; modules releasing through 2026.

Coming

FAR Part 31 Cost Principles

The allowability counterpart to CAS. Selected cost principles, unallowable cost identification and segregation, expressly unallowable costs and penalties, and the documentation that keeps costs in your rates instead of out of them.

Coming

DCAA Audit Preparation

The auditor's-eye view. Accounting system adequacy, the SF1408 pre-award survey, floor checks, the DCAA Contract Audit Manual, and how to assemble evidence so you hand the auditor a map, not a pile.

Coming

Incurred Cost Submissions & Indirect Rate Management

Pools to rates to forward pricing to billing to incurred cost to final rates. The adequacy checklist, the schedules, FCCM, and the common findings that turn a routine submission into a multi-year audit.

The differentiator

The Workbench reads the contract and runs the determination with your team.

Other CAS training stops at the regulation. Our AI Workbench stays in the work. It reads the contract clauses, determines applicability and coverage, flags where allocable and allowable diverge, and drafts the memo. Trained on 48 CFR Chapter 99, FAR Parts 30 and 31, the FY2026 NDAA, and the DCAA Contract Audit Manual.

01

Applicability Determination

Your team enters the contract value and type. The Workbench applies the current thresholds, including the FY2026 NDAA changes effective June 30, 2026, and returns whether CAS applies, at full or modified coverage, and which 52.230 clause attaches.

02

Allocable vs Allowable

The single most-confused distinction in govcon accounting. The Workbench separates what CAS makes allocable from what FAR Part 31 makes allowable, cost by cost, so your team stops conflating the two in front of an auditor.

03

Rate & Pool Stress-Testing

Before the incurred-cost submission goes to DCAA, the Workbench checks pool composition, allocation bases, and FCCM treatment, then flags the allocations an auditor is most likely to challenge, while you can still fix them.

04

Memo & Disclosure Drafting

The Workbench drafts the CAS applicability memo, the practice-change and cost-impact narrative, and Disclosure Statement language in the structure an auditor expects. Your controller reviews and signs. Start at a 70% draft, not a blank page.

A real determination

A $40M award. New thresholds. Where do you land?

Watch how the Workbench handles the question every controller is asking in 2026.

QMS WORKBENCH · CAS APPLICABILITY SESSION
CONTROLLER · 9:18 AM
We're about to take a $40M cost-plus award. A contract this size used to be full CAS coverage. With the NDAA changes, where do we land, and what has to be in place before award?
QMS WORKBENCH
Two thresholds matter here, and both moved. As of the FY2026 NDAA (§1806), with the FAR change effective June 30, 2026: CAS applicability starts at $35M, and full coverage starts at $100M. A single $40M award is above the applicability threshold and below the full-coverage threshold. You land in modified coverage, not full.
QMS WORKBENCH · METHOD ROUTER
Recommending: Applicability Determination for the award + Disclosure Statement readiness check. I can draft the determination memo now.
QMS WORKBENCH · OUTPUT
Modified CAS coverage applies. Four standards attach: CAS 401, 402, 405, and 406. The contract clause is FAR 52.230-3. A Disclosure Statement is not triggered by this single $40M award. That is the $50M single-award or $50M net-awards test, and you are under both. Before award, confirm consistency in estimating and accumulating (401), consistency in purpose (402), proper treatment of unallowable costs (405), and a consistent cost accounting period (406).
PDF
CAS Applicability Determination: AWD-2026-0440
48 CFR 9903 · MODIFIED COVERAGE · THRESHOLDS AS OF 30 JUN 2026 · 4 PAGES
CONTROLLER · 9:26 AM
Took this straight to the CFO. First time we walked into an award knowing our CAS posture cold instead of calling counsel.
Why this matters

Cost accounting discipline is cash protection.

Every allocation that survives the audit is cash you keep. Every finding is cash withheld, disallowed, or paid back.

$
Withheld billings An inadequate accounting system finding lets the contracting officer withhold a percentage of every invoice until you remediate. On an active program, that is six figures of earned cash frozen for months.
Multi-year audit drag A messy incurred-cost submission does not close in a year. It opens a back-and-forth that ties up your controller, your records, and your forward rates across multiple fiscal years.
Penalties on unallowable costs Claim an expressly unallowable cost and the penalty is the cost itself plus interest, sometimes doubled. The exposure is not the rate adjustment. It is the penalty on top of it.
📉
Capability concentrated in one person The only person who understands your CAS posture is the controller who set it up. When they leave, the Disclosure Statement, the rate logic, and the audit history walk out the door with them.
Common questions

Before you book the demo.

Is this Cost Accounting Standards or Client Accounting Services?
Cost Accounting Standards: 48 CFR Chapter 99, the federal standards governing how government contractors measure, assign, and allocate costs on negotiated contracts. If you bill the government and DCAA examines your rates, this is your world. It is not bookkeeping or client accounting services.
Our contracts are under the new $35M threshold. Do we still need this?
Often yes. Even CAS-exempt contractors live under FAR Part 31 cost principles, DCAA scrutiny of indirect rates, and incurred-cost submission requirements. Thresholds also move and companies grow into coverage. The pathway teaches where you stand today and what changes as your award profile changes.
Everything is changing in 2026. Won't this be outdated by the time we finish?
That is exactly why it exists. Every threshold and standard carries an "as of" date. We teach the framework before the FY2026 NDAA changes, the live transition, and the framework after. Your team is current the day the FAR change takes effect on June 30, 2026, not a year behind it.
Who on my team is this actually for?
Controllers, government contract accounting managers, and the FP&A analysts who build indirect rates and proposals, plus the DCAA-compliance lead. The CFO gets the Manager Dashboard view of where the team stands. The people who touch the accounting system take the courses.

See it in 30 minutes.

We walk you through a Workbench applicability session, show the Manager Dashboard, and demo the audit-evidence PDF export end to end. After the demo you'll know exactly how this fits your finance team and where pricing lands.

Book a 30-min demo →

Ready to see this pathway in action?

30-minute working demo. We'll scope this pathway to your award profile, your CAS posture, and your DCAA audit timeline. You'll see the Workbench, the Manager Dashboard, and the Audit-Evidence Package on the call.

Book a 30-min demo

Demos run Tuesday, Wednesday, Thursday • 10am–4pm PST