Information Collection on Cost Accounting Standards Administration

Abstract

On behalf of the more than 1,600 member companies and the nearly 90,000 individual members that comprise the National Defense Industrial Association (NDIA), I offer the following comments on the subject information collection. We appreciate this opportunity to respond to Information Collection 9000-0129, Cost Accounting Standards Administration. Most industry participants will agree that, from both the contractor's and the Government's perspective, administering cost accounting practice changes is one of the most challenging and time consuming aspects of Cost Accounting Standards (CAS) Administration. Nevertheless, most will also agree that information required from contractors pursuant to Federal Acquisition Regulation (FAR) Subpart 30.6 and FAR 52.230-6 is generally necessary for the Government to identify, understand, evaluate, and negotiate the impact of cost accounting practice changes. However, we believe there is opportunity to reduce the burden on contractors and the Government by modifying when, how, and how often this information is collected from contractors and dispositioned by the Government.