DCAA Implements Federal Circuit Decision Requiring Interest Compounded Daily On Adjustments For CAS Noncompliances

Sheppard Mullin Richter & Hampton LLP
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Albert Einstein supposedly said that “the most powerful force in the world is compound interest.” Whether or not the great man actually said that, DCAA is now prepared to show contractors just how powerful compounding can be.

Cost Accounting Standards (“CAS”) have always required that

*When a contractor is noncompliant with CAS and

*The noncompliance causes the government to pay increased costs, then

*The contractor must pay interest on the amount of the required adjustment, with

*Interest commencing on the date the violation first caused the government to pay the increased costs and continuing until the contractor makes full payment of the adjustment amount, and with

*Interest computed at the rate specified in the Internal Revenue Code, 26 U.S.C. § 6621.

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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