June 24, 2013

CAS Requirements

(1) CAS Certification;

(2) Flowdown of applicable CAS clauses and

(3) CAS Notice within 30 days of award of CAS-covered subcontract.


For Commercial Item Exception, document the determination.


Couple of quick notes on these documentation requirements: 

  1. CAS Certification is really only required when a LB subcontractor is claiming a monetary exception. Otherwise, if you miss it (or the sub fails to fill out the cert in your Reps and Certs package and your SCA misses it prior to award), you can assume it applies to a LB and you know it doesn't apply to a SB. 
  2. Remember that Advance Notice (52.244-2, Alt 1) and CAS Notice are different, and one doesn't substitute for the other.  
  3. Don't assume commerciality when your PO is over $700,000.00. CPSR Teams are not adverse to finding CAS and TINA violations on commercial item procurements if internal Commercial Item Determination are not effectively documented prior to award.