I. Background

The Cost Accounting Standards (CAS) Board published a final rule in the Federal Register at 76 FR 79545, on December 22, 2011, which revised the threshold for the application of CAS from "$650,000" to "the Truth in Negotiations Act (TINA) threshold, as adjusted for inflation (41 U.S.C. 1908 and 41 U.S.C. 1502(b)(1)(B))" in the CAS provisions and clauses at 48 CFR parts 9901 and 9903. The TINA threshold is adjusted every 5 years for inflation, as required by 41 U.S.C. 1908. Title 41 U.S.C. 1502(b)(1)(B) ties the CAS applicability threshold to the dollar value of the TINA threshold (currently $700,000). The FAR cites the TINA threshold at FAR 15.403-4(a)(1).