The TINA threshold is defined as $750,000 (up to $2 million). The CAS applicability threshold is $2 million, with $50 million being the threshold to be fully CAS compliant.
TINA - or The Truth in Negotiations Act - is a public law that requires full, fair, and transparent disclosure by contractors in the conduct of negotiations with the government.
This includes a provision requiring that contractors certify that pricing data disclosed to the government for procurements be accurate, complete and current as of the date of price agreement. Failure to do so means that the contractor has filed a false certification, and they could be subject to a post-award audit, related contract price adjustments, and possibly penalties and interest on the contract overpricing they did not disclose in good faith.
Per the Federal Acquisition Regulation (FAR), the TINA threshold is defined as $750,000. However, Section 811 of the 2018 National Defense Authorization Act (NDAA) increased the threshold to $2 million for all contracts entered into after July 1, 2018. The threshold is evaluated every five years. While the Contracting Officer may request pricing data to support proposals below the $2 million TINA threshold, this cost or pricing data would not be certified.
The Cost Accounting Standards (CAS) applicability threshold is also $2 million, since it is legally tied to the TINA threshold. That said, $50 million still remains the threshold for contractors to be fully CAS covered – that is, to be required to follow the requirements of all 19 CAS compliance standards. Because of this, it likely limits the number of contracts held by full CAS covered contractors to be subject to CAS.
Peter Witts CPA PC, specializes in government contract accounting, helping you ensure that your accounting practices are compliant with applicable regulations.
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