FAR 30.202-6—Responsibilities.
Plain-English Summary
FAR 30.202-6 explains who is responsible for key Cost Accounting Standards (CAS) disclosure-statement tasks when a contract may be CAS-covered. It covers the contracting officer’s duty to identify possible CAS coverage, include the proper solicitation notice, verify required offeror certifications, and ensure required Disclosure Statements are submitted. It also covers the rule that a CAS-covered contract generally cannot be awarded until the cognizant Federal agency official (CFAO) has issued a written adequacy determination for the Disclosure Statement, unless the agency head authorizes award without the statement to protect the Government’s interest. In that exception, the contractor must still submit the Disclosure Statement after award and the CFAO must determine adequacy as soon as possible. The section also assigns review responsibilities to the cognizant auditor and adequacy/compliance determination responsibilities to the CFAO. In practice, this section is about making sure CAS applicability is identified early, disclosure requirements are enforced before award when required, and the Government has a documented basis for accepting a contractor’s cost accounting practices.
Key Rules
Identify CAS coverage early
The contracting officer must determine whether a proposed contract may require CAS coverage and must include the appropriate solicitation notice. This is an early acquisition planning duty, not a post-award cleanup step.
Verify certifications and disclosures
The contracting officer must ensure the offeror has made the required solicitation certifications and submitted any required Disclosure Statements. This helps confirm the offeror has acknowledged CAS-related requirements before award.
No award without adequacy determination
A CAS-covered contract generally may not be awarded until the CFAO has issued a written determination that the required Disclosure Statement is adequate. The adequacy determination is a prerequisite to award unless a narrow exception applies.
Limited emergency exception
If needed to protect the Government’s interest, the agency head may authorize award without first obtaining the Disclosure Statement, but this authority is nondelegable. In that case, the contractor must submit the statement after award and the CFAO must review it as soon as possible.
Auditor reviews disclosure statements
The cognizant auditor is responsible for reviewing Disclosure Statements for adequacy and compliance. This review supports the formal Government determination process.
CFAO issues final determinations
The CFAO is responsible for issuing the adequacy and compliance determinations for the Disclosure Statement. This is the official decision point for whether the contractor’s disclosed practices meet CAS requirements.
Responsibilities
Contracting Officer
Determine whether a proposed contract may require CAS coverage; include the appropriate CAS notice in the solicitation; ensure the offeror makes required solicitation certifications; and ensure required Disclosure Statements are submitted before award when applicable.
Cognizant Federal Agency Official (CFAO)
Issue written determinations that required Disclosure Statements are adequate; issue determinations of adequacy and compliance; and, if award occurs under the emergency exception, make the adequacy determination as soon as possible after award.
Cognizant Auditor
Conduct reviews of Disclosure Statements for adequacy and compliance and support the Government’s evaluation of the contractor’s disclosed cost accounting practices.
Agency Head
When necessary to protect the Government’s interest, authorize award of a CAS-covered contract without first obtaining the required Disclosure Statement. This authority is nondelegable.
Contractor / Offeror
Make required solicitation certifications; submit required Disclosure Statements when applicable; and, if award is made under the exception, provide the Disclosure Statement after award for CFAO review.
Practical Implications
Contracting officers need to screen for CAS coverage early, because missing the solicitation notice or disclosure requirement can delay award or create compliance problems.
A CAS-covered award should not move forward until the adequacy determination is in hand, so acquisition schedules should account for auditor and CFAO review time.
Contractors should treat Disclosure Statements as a substantive compliance document, not a formality, because the Government will review it for adequacy and compliance before award in most cases.
The emergency exception is narrow and high-level: only the agency head can authorize it, and the contractor still has to submit the Disclosure Statement afterward.
A common pitfall is confusing the auditor’s review with the CFAO’s determination; the auditor reviews, but the CFAO makes the official adequacy/compliance decision.
Official Regulatory Text
(a) The contracting officer is responsible for determining when a proposed contract may require CAS coverage and for including the appropriate notice in the solicitation. The contracting officer must then ensure that the offeror has made the required solicitation certifications and that required Disclosure Statements are submitted. (Also see 48 CFR 9903.201-3 and 9903.202). (b) The contracting officer shall not award a CAS-covered contract until the cognizant Federal agency official (CFAO) has made a written determination that a required Disclosure Statement is adequate unless, in order to protect the Government's interest, the agency head, on a nondelegable basis, authorizes award without obtaining submission of the required Disclosure Statement (see 48 CFR 9903.202-2 ). In this event, the contractor shall submit the required Disclosure Statement and the CFAO shall make a determination of adequacy as soon as possible after the award. (c) The cognizant auditor is responsible for conducting reviews of Disclosure Statements for adequacy and compliance. (d) The CFAO is responsible for issuing determinations of adequacy and compliance of the Disclosure Statement.