When we got it wrong

15 corrections across 77 published articles since February 2026. Every one stays on this page permanently, newest first.

Every entry below is a real change to a real article on this site. The corrections come from our ongoing content integrity audits and from readers who flagged the errors directly.

We post the corrections openly. If you read an older version of an article or saved one to PDF, this page tells you what changed and why.

CR-014 August 13, 2026

Seven articles treated being subject to CAS and owing a Disclosure Statement as the same status. They are two different thresholds, and most of our readers sit between them

Article: The CAS Disclosure Statement: When You Need One and DCAA Audit Types: The 7 Audits Every Government Contractor Faces and How to Reduce Your Indirect Rates: 7 Strategies That Win More Government Contracts and What to Look for in a GovCon Bookkeeping Provider: 10 Questions to Ask and Bid and Proposal Costs FAR 31.205-18: Compliance Guide and Forward Pricing Rate Proposals: What DCAA Expects and Fringe, Overhead, and G&A Rates Explained for Government Contractors

What changed: Cost Accounting Standards begin to apply to a negotiated contract above the Truth in Negotiations Act threshold, currently $2.5 million as adjusted for inflation, and a contract above that line carries modified coverage: four standards, CAS 401, 402, 405 and 406. A Disclosure Statement is a separate and much higher obligation. It is not required until a single CAS-covered award, or net CAS-covered awards in the most recent cost accounting period, reaches $50 million. A contractor between those two figures is CAS-covered and has no Disclosure Statement at all. Seven of our articles collapsed that distinction. The plainest instance told readers that contractors with modified CAS coverage must file a Disclosure Statement, which is the opposite of what the regulation says. Another placed the filing trigger at the modified coverage threshold, off by a factor of twenty. Four more instructed readers to amend a Disclosure Statement without saying who actually has one. We rewrote every affected passage, including the tables, action headings and summary boxes where the same claim was repeated. Two related errors were corrected in the same pass. CAS 9904.410 and CAS 9904.418 were described as binding CAS-covered contractors generally; both are full-coverage standards that start at $50 million. And several passages named the contracting officer as the person who resolves the cost impact of an accounting practice change, where FAR 30.606(a)(1) gives that authority solely to the cognizant Federal agency official.

Before

“Contractors with modified CAS coverage must file a Disclosure Statement and follow CAS 401, 402, 405, and 406. And, elsewhere: contractors above the modified coverage threshold must file one.”

After

Modified CAS coverage means four standards: CAS 401, 402, 405, and 406. It does not mean a Disclosure Statement. That obligation starts at a single CAS-covered award of $50 million or more, or $50 million or more in net CAS-covered awards during the most recent cost accounting period. A contractor can be CAS-covered, bound to consistency under CAS 401, and have no Disclosure Statement to be tested against.

Primary source

48 CFR 9903.202-1(b) sets the Disclosure Statement trigger at $50 million. 48 CFR 9903.201-2(a) sets full coverage at the same figure. 48 CFR 9903.201-2(b)(1) states that modified coverage "requires only" compliance with 9904.401, 9904.402, 9904.405 and 9904.406. 48 CFR 9903.201-1(b)(2) exempts negotiated contracts not in excess of the TINA threshold as adjusted for inflation; FAR 15.403-4(a)(1) prints that threshold as $2.5 million. FAR 30.606(a)(1): "the CFAO has the sole authority for negotiating and resolving the cost impact."

Why it matters: A contractor between $2.5 million and $50 million is exactly the reader this site is written for, and we sent that reader to look for a filing that does not exist. The cost is not abstract. A firm that believes it owes a Disclosure Statement prepares one it does not need, or worse, reads an instruction to amend one and concludes it is already out of compliance. The error also ran the other way: a firm told that CAS 410 governs its G&A allocation base would restructure its pools to satisfy a standard that does not reach it. Getting a threshold wrong in either direction costs a small contractor real money and real time.

CR-015 August 13, 2026

We described an enacted statutory threshold as a proposal that had not taken effect. The reverse was true: the statute changed and the regulation has not caught up

Article: How to Reduce Your Indirect Rates: 7 Strategies That Win More Government Contracts

What changed: Our article told readers that the FY2026 National Defense Authorization Act "proposes" raising the CAS contract applicability threshold to $35 million and that the change was "not yet effective." Section 1806(d)(1) of that Act amended 41 U.S.C. 1502(b)(1)(B) directly, and the United States Code has read $35,000,000 since December 2025. It is enacted law, not a proposal. What has not happened is the implementing rulemaking: the same subsection ordered regulations within 180 days and none have issued, so 48 CFR 9903 still describes the older cross-reference and that is what a contracting officer administers. We rewrote the passage to state both layers and to be explicit that which text governs a given award is a question for counsel and the contracting officer, not for an accountant. We also removed an executive compensation cap figure we could not trace to a primary source. FAR 31.205-6(p)(4)(ii) prints no dollar amount and points instead to a benchmark the Office of Federal Procurement Policy sets for each contractor fiscal year, so the article now points readers there rather than repeating a number.

Before

“If you are CAS-covered (the codified per-contract trigger is $2.5M; the FY2026 NDAA proposes raising it to $35M, not yet effective), any change in cost accounting practice requires a Disclosure Statement amendment.”

After

Section 1806(d)(1) of the FY2026 NDAA amended the statute directly, and 41 U.S.C. 1502(b)(1)(B) has read $35,000,000 since December 2025. That same subsection ordered implementing regulations within 180 days and none have issued, so 48 CFR 9903 still reads to the old floor and that is what a contracting officer administers.

Primary source

41 U.S.C. 1502(b)(1)(B) and its amendment notes: "Pub. L. 119-60, s1806(d)(1)(A), substituted '$35,000,000, as' for 'of the amount set forth in section 3702(a)(1)(A) of title 10 as the amount is'." P.L. 119-60 s1806(d)(3): "Not later than 180 days after the date of the enactment of this Act, the Administrator for Federal Procurement Policy shall issue such regulations as are necessary to implement the amendments made by this subsection." FAR 31.205-6(p)(4)(ii) for the benchmark compensation amount.

Why it matters: Calling enacted law a proposal and calling a proposal enacted law are the same failure, and this site publishes on thresholds precisely because that distinction is hard and consequential. A reader who believes a threshold has not changed plans against the wrong number. The honest position on this particular threshold is uncomfortable and we now say it plainly: the statute and the regulation disagree, and nobody can tell you with certainty which one a given contracting officer will apply until the rule issues.

CR-012 August 4, 2026

Two pages described a 2 percent error in the G&A allocation base as if it produced an equal amount of questioned cost. It does not. The base error and the cost impact are different numbers, and we had overstated the exposure by roughly sevenfold

Article: Top 10 DCAA Audit Findings and How to Prevent Them and CPA Oversight Prevents Bookkeeping Mistakes That Trigger DCAA Findings

What changed: Both pages used the same illustration: a 2 percent error in the G&A allocation base on $5 million in direct costs. Two percent of $5 million is $100,000, and that arithmetic is right. What is wrong is what the $100,000 represents. It is the amount by which the allocation base is misstated. It is not the amount of questioned indirect cost. Indirect cost is allocated by applying a rate to a base, so an error in the base moves allocated cost by the base error multiplied by the rate, not by the base error itself. At a 15 percent G&A rate, a $100,000 base misstatement shifts roughly $15,000 of allocated cost. We had published the base error as though it were the cost impact. Both pages now state the two figures separately and show the multiplication. We also named the rate used in the illustration, because the answer depends entirely on it and a reader cannot check our arithmetic without knowing which rate we assumed.

Before

“A 2% error in the G&A allocation base on $5 million in direct costs creates $100,000 in questioned indirect charges across every CAS-covered contract.”

After

A 2% error in the G&A allocation base on $5 million in direct costs misstates the base by $100,000. The questioned amount is that base error multiplied by your G&A rate, not the base error itself, so at a 15% G&A rate it is roughly $15,000 spread across every CAS-covered contract.

Primary source

This is an arithmetic correction rather than a regulatory one, and it follows from how indirect cost allocation works under 48 CFR 9904.410 and FAR 31.203: an indirect cost rate is applied to an allocation base, so a change in the base changes allocated cost in proportion to the rate, not dollar for dollar. The underlying regulatory point in both articles, that DCAA verifies rates against the contractor’s disclosed allocation methodology and recalculates for the full fiscal year rather than the single period of the error, is unchanged and remains correct.

Why it matters: The error ran in the direction that frightens people. A small contractor reading that a routine base error creates $100,000 of questioned cost has been given a number roughly seven times the real one, on a subject where anxiety already drives spending. Overstating audit exposure is not a harmless conservatism. It pushes contractors toward remediation they may not need, and it makes the genuinely serious findings harder to distinguish from the routine ones. We would rather a reader trust our numbers than fear them.

CR-013 August 4, 2026

Two worked examples did not follow from the numbers printed beside them. One overstated a monthly overhead impact by about twenty percent; the other understated our own cost comparison

Article: How to Track Contract Profitability: CLIN-Level Reporting for GovCon and What DCAA Bookkeeping Services Cost in 2026

What changed: On the contract profitability page, we described an overhead rate rising from 45 percent to 52 percent and said a $2 million contract would then carry $14,000 a month more in overhead. Seven percentage points applied to a $2 million base is $140,000 a year, which is about $11,700 a month. The $14,000 figure would require a rise of roughly 8.4 points, not 7. We corrected the figure and also named what the $2 million refers to, because the original sentence said a $2M contract and the arithmetic only works if $2 million is the allocation base rather than the contract value. On the bookkeeping cost page, our comparison table gives in-house cost as $86,500 to $132,000 a year against $18,000 to $48,000 outsourced, and we summarised that as a saving of 45 percent to 80 percent. The low end is right. The high end is not: the largest saving the table supports is $132,000 against $18,000, which is 86 percent. That correction runs in our own favour, which is precisely why it needed making. A number that flatters us is still wrong if it does not follow from the table above it.

Before

“A $2M contract suddenly carries $14,000/month more in overhead than you planned. And, on the cost comparison page: outsourcing to a CPA-managed firm saves small contractors 45% to 80% compared to in-house staffing.”

After

A contract with a $2M allocation base suddenly carries about $11,700 a month more in overhead than you planned, roughly $140,000 across a full year. And, on the cost comparison page: outsourcing to a CPA-managed firm saves small contractors 45% to 86% compared to in-house staffing.

Primary source

Both are recomputations from figures already published in the articles themselves. Seven percentage points of $2,000,000 is $140,000 a year and $11,666.67 a month. Against the published cost range, the smallest saving is $86,500 less $48,000, which is 44.5 percent and rounds to the 45 percent we had; the largest is $132,000 less $18,000, which is 86.4 percent.

Why it matters: A worked example is a promise that the reader can follow the arithmetic and reach the same answer. When they cannot, the credibility of every other number on the page drops with it, including the ones that are right. These two are small in dollar terms and neither changes the advice on the page, but a reader who checks our arithmetic should find it holds. One of the two understated our own case, and we corrected it on the same footing as the one that overstated a cost. The direction an error runs in should not decide whether it gets fixed.

CR-009 August 3, 2026

Schedule B and Schedule E of the incurred cost submission were labelled with the wrong cost pools, Schedule O was missing from the required list, and a second page mislabelled five schedule letters in one sentence

Article: How to Prepare Your Incurred Cost Submission (ICS) and Government Contractor CPA: When Your Bookkeeper Is Not Enough

What changed: Our incurred cost submission guidance described Schedule B as the fringe benefits pool and Schedule E as the G&A expense pool and allocation base. Both labels were wrong. FAR 52.216-7(d)(2)(iii) lists the required data as items (A) through (O), and item (B) is General and Administrative expenses while item (E) is the claimed allocation bases. The DCAA ICE Model uses the same lettering and names its worksheets accordingly. Fringe is not Schedule B at all: in the ICE Model it is a separate worksheet named Fringe that feeds Schedule A. Separately, the article opened by saying the data is organised across Schedules A through O, then printed tables that stopped at N, omitting Schedule O entirely. Schedule O is contract closing information for contracts physically completed in the fiscal year. We rebuilt the schedule table directly from the clause text, added the missing Schedule O row, and added a note explaining where fringe actually sits. On August 3, 2026 we found the same error class on a second page. Our article on when a bookkeeper is not enough described the submission as including Schedule B for direct costs by contract and subcontract, Schedules E, F and G for fringe, overhead and G&A rate calculations, and Schedule H for other indirect cost pools. Every letter in that sentence was wrong, and the description belonging to Schedule H had been attached to Schedule B. We replaced it with the lettering read directly from the clause.

Before

“B - Indirect cost pool detail (fringe benefits pool). E - G&A expense pool and allocation base. And, on the second page: the submission includes Schedule B (direct costs by contract/subcontract), Schedules E/F/G (fringe, overhead, G&A indirect rate calculations), and Schedule H (other indirect cost pools).”

After

B - General and Administrative expenses (final indirect cost pool), by element of cost per the chart of accounts. E - Claimed allocation bases, by element of cost, used to distribute indirect costs. F - Facilities capital cost of money factors computation. G - Reconciliation of the books of account to claimed direct costs. H - Direct costs by contract and subcontract. Fringe benefits are not Schedule B. In the ICE Model, fringe has its own worksheet, named Fringe, which feeds Schedule A.

Primary source

FAR 52.216-7(d)(2)(iii), items (A) through (O), read against the eCFR text of 48 CFR 52.216-7 (title 48 issue date July 30, 2026) and re-read against the current eCFR rendering on August 3, 2026; DCAA Manual 7641.90, Information for Contractors (November 2023), Figure 13, Model Incurred Cost Proposal Schedules, whose Schedule A through O lettering matches the clause item for item

Why it matters: A contractor building an incurred cost submission from our table would have labelled their fringe pool as Schedule B and their allocation bases as G&A. DCAA reviews the submission against the FAR lettering, so mislabelled workpapers invite an adequacy question before anyone looks at the numbers. The missing Schedule O is the same problem in the other direction: a reader working from a list that stops at N files without contract closing information, and an incomplete submission is returned. The second page compounded it, because a reader who checked one article against the other would have found two different sets of letters and no way to tell which was right. All of these errors were ours, and they sat in the pages that are supposed to be the reference.

CR-010 August 3, 2026

We attributed a vendor statistic to a press release that does not contain it, and our software pricing row mixed two different subscription bases under a per-user label

Article: When to Upgrade from QuickBooks: 8 Signs You Have Outgrown It

What changed: Two separate errors on one comparison page. First, we stated that Deltek Costpoint has 88 percent NIST 800-171 control coverage, and we cited that figure twice, to two different documents: a Deltek press release of April 30, 2025 in our comparison table, and Deltek published compliance documentation in the body text. We searched the full text of both versions of that press release and both of Deltek current compliance pages. The figure appears in none of them. We could not source it anywhere, so we removed it rather than re-cite it, and replaced it with what Deltek does state on a page that is live today. Second, our comparison table labelled a row per-user cost and gave a range of about 156 to 447 dollars per month. Those are single-user base rates from two different subscription types, an annual rate and a monthly rate, presented as one continuous range. Our own article text, forty lines below the table, said a ten-user annual subscription runs about 903 dollars per month, which is roughly 90 dollars per user and well below the 156 dollar figure our table gave as its floor. We relabelled the row and restated the figures to match. We also replaced a verification link that returned a 404 error, which appeared twice on the page as an instruction to readers to check the vendor status themselves.

Before

“CMMC Level 2 Ready (88% NIST 800-171 coverage per Deltek press release Apr 30, 2025). And in the body: Costpoint also supports CMMC Level 2 readiness with 88% NIST 800-171 control coverage per Deltek published compliance documentation. And the pricing row: Per-user cost, ~$156 to $447/month per user.”

After

FedRAMP Moderate Equivalency (not full Authorization); supports CMMC Level 2/3 as a cloud service provider. Deltek states that GCCM is listed on the FedRAMP Marketplace and meets the requirements for supporting CMMC Level 2 and Level 3 certification as a cloud service provider. Hosting on a compliant platform does not by itself make a contractor CMMC compliant. And the pricing row: List price (single user), ~$156 to $226/mo annual (Silver to Platinum); Diamond ~$447/mo, with a note recording that a ten-user annual subscription runs about $903 per month, or roughly $90 per user.

Primary source

Deltek press release, Costpoint GovCon Cloud Moderate Completes FedRAMP Moderate Equivalency Assessment, April 30, 2025, full text retrieved from both PRNewswire release 302442178 and deltek.com and searched literally: zero occurrences of 88, of 800-171, or of Level 2. Deltek compliance pages at deltek.com/company/security-and-trust/compliance/ and deltek.com/industries/government-contracting/compliance/, both retrieved August 3, 2026, which state that GCCM is listed on the FedRAMP Marketplace meeting the requirements for supporting DFARS 7012 and CMMC Level 2/3 certification as a cloud service provider, and which also contain zero occurrences of 88. Pricing figures reconciled against our own article body text.

Why it matters: A reader comparing accounting systems could have carried the 88 percent figure into a vendor evaluation or a board memo, and if they had followed our citation to check it, they would not have found it, because it is not there. A number with a confident source attached is more dangerous than a number with no source at all, because it invites the reader to stop checking. The pricing error is the more expensive one in practice: a contractor with ten users budgeting from our table would have planned for roughly 1,560 dollars a month at the low end when our own article said the figure is about 903. Both errors sat on a page whose entire purpose is helping a small contractor decide whether to spend money on new software.

Show the 9 earlier corrections

CR-011 August 3, 2026

Nine pages treated the FY2026 NDAA cost accounting threshold changes as one change on one date. They are three changes on three different clocks, and our pages were wrong in both directions: five overstated what had taken effect, two understated it, and six repeated an exemption Congress had repealed

Article: The 2026 FAR Overhaul: What Changes in Your Accounting and FAR Class Deviations 2026: What Changed and What It Means for Your Books and FAR and CAS Changes in 2025-2026 and NDAA 2026 Threshold Changes: CAS and Pricing Impact and DCAA Accounting System Checklist and DCAA Compliance Guide for Small GovCon Firms and Fringe, Overhead, and G&A Rates Explained and TINA Compliance Threshold 2026 and What to Look for in a GovCon Bookkeeping Provider

What changed: The FY2026 NDAA changed these thresholds by different mechanisms, and the mechanism decides what binds. Section 1804(c) amended 10 U.S.C. 3702(a) directly, raising the DoD certified cost or pricing data threshold to $10 million for prime contracts entered after June 30, 2026, and it ordered no rulemaking at all. Section 1806(d)(1) amended 41 U.S.C. 1502(b)(1)(B) directly, writing $35,000,000 into the statute, but paragraph (3) of the same subsection also gave the Administrator for Federal Procurement Policy 180 days to issue implementing regulations, and that deadline passed with nothing issued. Section 1806(a) amended nothing at all; it only directs a rule raising full CAS coverage from $50 million to $100 million, and that rule is also overdue. We had collapsed all of this into one change with one effective date. Four errors followed. First, we stated that full CAS coverage now triggers at $100 million. It does not; 48 CFR 9903.201-2 still reads $50 million, and so does the Disclosure Statement trigger at 9903.202-1. Second, we applied the date "contracts entered after June 30, 2026" to the CAS changes. That date belongs to the TINA amendment and is written into 10 U.S.C. 3702(a) itself; the CAS provisions carry no contract-date condition. Third, we gave the old CAS applicability baseline as $2 million. It was $2.5 million, because the pre-amendment statute defined it by cross-reference to the inflation-adjusted TINA threshold. Fourth, and running the other way, our DCAA compliance guide described the $35 million figure as "proposed, not yet effective" and told readers to verify enactment at congress.gov, while our TINA article said three times that the increase applied "if enacted as reported." Both were written before the bill was signed and neither was updated after. We also corrected two things no reader had flagged. We had said the $7.5 million trigger-contract exemption was still in force. It is not: Section 1806(d)(1)(B)(iv) struck it from 41 U.S.C. 1502, and 48 CFR 9903.201-1(b)(7) still prints it only because the implementing rule is overdue. And none of these pages mentioned the exemption that answers the question for most of our readers before any dollar threshold does: 48 CFR 9903.201-1(b)(3) exempts contracts and subcontracts with small businesses from all CAS requirements, at any value, and always has. That is now stated on every page in the set. A ninth page, our list of questions to ask a GovCon bookkeeping provider, carried the same three problems and was corrected with them: it gave the repealed $7.5 million exemption as current, put modified CAS coverage between $2.5 million and $50 million when the statutory applicability figure is now $35 million, and did not mention the small business exemption at all. Separately, our FAR and CAS changes article described the rescission of CAS 404, 408, 409 and 411 as a proposal awaiting a final rule. The final rule published on July 8, 2026 and takes effect on August 7, 2026, and it does not treat the four standards alike: CAS 408 and 411 are wholly rescinded, while most but not all of CAS 404 and 409 is rescinded with the remainder relocated.

Before

“Full CAS coverage now triggers at $100 million in annual contract awards, up from $50 million. The per-contract CAS applicability threshold jumps from $2 million to $35 million. These changes take effect for contracts awarded after June 30, 2026. And, on our DCAA compliance guide: CAS coverage threshold (FY2026 NDAA: proposed, not yet effective). And, on our TINA article: $10,000,000 per FY2026 NDAA Sec. 1804(c), if enacted as reported.”

After

The three changes run on three clocks. The DoD certified cost or pricing data threshold is $10 million by statute for prime contracts entered after June 30, 2026, with no rulemaking attached; civilian agencies were not part of that amendment and stay at $2.5 million. Contract-level CAS applicability reads $35 million in 41 U.S.C. 1502, but Section 1806(d)(3) ordered implementing regulations within 180 days and none have issued, so most practitioner commentary treats the increase as taking effect through that rulemaking. Full CAS coverage did not move at all and remains $50 million, along with the Disclosure Statement obligation that follows it. Before any of these figures matter, check 48 CFR 9903.201-1(b)(3): small businesses are exempt from all CAS requirements at any dollar value.

Primary source

Codified text read literally at uscode.house.gov on August 3, 2026. 41 U.S.C. 1502(b)(1)(B) now reads "in excess of $35,000,000, as adjusted in accordance with applicable requirements of law", with the amendment note recording that Pub. L. 119-60 Section 1806(d)(1)(A) substituted "$35,000,000, as" for "of the amount set forth in section 3702(a)(1)(A) of title 10 as the amount is". The statutory note under the same section carries Section 1806(d)(3) verbatim: "Not later than 180 days after the date of the enactment of this Act, the Administrator for Federal Procurement Policy shall issue such regulations as are necessary to implement the amendments made by this subsection". The repeal of the trigger-contract exemption is recorded in the same notes: Section 1806(d)(1)(B)(iv) "struck out cl. (iv) which read as follows: a contract or subcontract with a value of less than $7,500,000 if, when the contract or subcontract is entered into, the segment of the contractor or subcontractor that will perform the work has not been awarded at least one contract or subcontract with a value of more than $7,500,000 that is covered by the standards"; current 1502(b)(1)(C) contains only clauses (i) through (iii). 10 U.S.C. 3702(a)(1)(A) now reads "in the case of a prime contract entered into after June 30, 2026, the price of the contract to the United States is expected to exceed $10,000,000". 41 U.S.C. 3502, the civilian authority, was not amended by Pub. L. 119-60 and still reads $2,000,000 against a June 30, 2018 anchor. Enrolled text of Section 1806 read subsection by subsection at govinfo. Regulation text from eCFR, title 48, issue date July 8, 2026: 9903.201-2(a) "Full coverage applies to contractor business units that (1) Receive a single CAS-covered contract award of $50 million or more; or (2) Received $50 million or more in net CAS-covered awards during its preceding cost accounting period"; 9903.201-1(b)(3) "Contracts and subcontracts with small businesses"; FAR 15.403-4 "$2.5 million for prime contracts awarded on or after July 1, 2018". Part 9903 contains zero occurrences of $100 million or $35 million and thirteen of $50 million, and that zero is meaningful because a control search of the same text returns forty-four occurrences of "Cost Accounting Standards". Federal Register API: RIN 0348-AB85 returns exactly one document, the proposed rule of March 20, 2026, whose own text states "The proposal also eliminates the $7.5 million trigger contract threshold ... Section 1806 of the 2026 NDAA fully codified the OMB legislative proposal"; RIN 0348-AB90 returns the final rule published July 8, 2026, effective August 7, 2026, wholly rescinding CAS 408 and 411 and rescinding most provisions of CAS 404 and 409.

Why it matters: These pages tell a contractor whether a compliance regime reaches them, and being wrong costs money in both directions. A contractor reading that full CAS coverage had moved to $100 million could have stopped maintaining a Disclosure Statement they are still required to file. A contractor reading that the $35 million figure was merely proposed could have kept paying for CAS infrastructure while the statute had already moved. A contractor relying on the $7.5 million trigger-contract exemption would have been relying on a provision Congress repealed in December. And a small business reading any of these pages would have worked through three dollar thresholds to reach a conclusion that 48 CFR 9903.201-1(b)(3) had already settled for them before the first one. The uncomfortable part is that one of these errors was introduced by caution. We wrote "proposed, not yet effective" to avoid overstating a change, and that caution became a false statement the day the bill was signed. A hedge that has gone stale is not a safe harbour; it is an error with good manners.

CR-008 August 2, 2026

FAQ answer told contractors who missed the July 6, 2026 deadline that nothing remained, when a second election was still open to them

Article: Section 174A Catch-Up Election: The Route Still Open

What changed: Our Section 174A article carried an FAQ answer titled "What happens if I miss the July 6, 2026 deadline?" It stated that remaining unamortized 2022-2024 R&D keeps amortizing on the original five-year TCJA schedule, and closed with "No second chance for closed years." July 6, 2026 was the correct deadline for one route, the small business retroactive election under OBBBA Section 70302(f)(1)(A). It was never the deadline for the separate recovery election under Section 70302(f)(2)(A), which lets any taxpayer, with no gross receipts test, recover the entire remaining unamortized balance in the first tax year beginning after December 31, 2024 or ratably across that year and the next. That election is made on the timely filed original return including extensions. A contractor reading our FAQ after July 6 would reasonably conclude the opportunity was gone. We rewrote the article around the surviving route, replaced the deadline countdown with the extension calendar, and kept the closed route visible in the comparison table so readers can see which door shut and which did not.

Before

“What happens if I miss the July 6, 2026 deadline? You lose the catch-up election permanently for any tax year already closed by IRC 6511. Remaining unamortized 2022-2024 R&D keeps amortizing under the original five-year domestic schedule from TCJA Section 174. Foreign R&D continues on the 15-year track. No second chance for closed years.”

After

July 6, 2026 closed only the small business retroactive election under OBBBA Section 70302(f)(1)(A), which reopened tax years 2022 through 2024. The recovery of unamortized amount election under Section 70302(f)(2)(A) is separate, carries no gross receipts test, and is made on the timely filed original return for the first taxable year beginning after December 31, 2024, including extensions. For calendar-year filers that is September 15, 2026 for partnerships and S corporations, and October 15, 2026 for C corporations and individuals.

Primary source

Rev. Proc. 2025-28 (sections 3, 7.02 and 8); P.L. 119-21 Section 70302(f)(1)(A) and Section 70302(f)(2)(A)

Why it matters: This is the correction that costs money if it goes unmade. A contractor holding a six-figure unamortized R&D balance, reading our FAQ the week after July 6, would have concluded the deduction was locked away for years and stopped looking. The election that was still open to them is worth real working capital, and the window runs to their extended filing date. Being right about the deadline we named is not enough when the answer we gave sends the reader away.

CR-007 July 16, 2026

CMMC Phase 2 (Level 2 C3PAO third-party assessment) suspended by DoD; the November 10, 2026 date is no longer a live requirement

Article: CMMC Compliance Articles: Phase 2 Suspension Reframe

What changed: On July 13, 2026, DoD suspended CMMC Phase 2 (CIO memo 26-P-1023), halting the Level 2 C3PAO third-party assessment requirement scheduled to begin November 10, 2026. A 60-day CMMC Reform Task Force review is underway. Our CMMC articles described the November 2026 date as a firm requirement, accurate when written and overtaken by the suspension. We reframed every Phase 2, November 2026, and C3PAO-required statement across four articles (CMMC Accounting Requirements, CMMC Compliance Costs, CMMC Assessment Cost by Level, FAR Class Deviations 2026) and the site glossary to state the suspension and the pending review. Phase 1 self-assessment guidance and the FAR 31 cost-allowability analysis are unchanged.

Before

“Phase 2 (November 10, 2026): Level 2 C3PAO third-party assessments required. Contractors handling CUI must budget for the C3PAO assessment path after that date.”

After

DoD suspended CMMC Phase 2 on July 13, 2026 (CIO memo 26-P-1023), halting the Level 2 C3PAO assessment requirement scheduled for November 10, 2026. A 60-day Reform Task Force review is underway, and Phase 1 self-assessment obligations remain in force. The FAR 31.201-2 cost-allowability analysis applies to any CMMC cost a contractor still incurs.

Primary source

DoD CIO memo 26-P-1023 (July 13, 2026); DFARS Case 2019-D041, 90 FR 43560; 32 CFR Part 170

Why it matters: A published date presented as a firm deadline becomes a liability the moment the government moves it. Contractors pricing C3PAO assessment costs into 2026 proposals on our timeline needed the suspension the day it landed. Tracking the change and correcting fast is the standard we hold.

CR-004 May 18, 2026

FAR 31.201-4 verbatim allocation language misattributed

Article: How to Calculate Your Indirect Rate: A Step-by-Step Guide

What changed: Earlier drafts attributed the phrase "beneficial or causal relationship" to FAR 31.201-4. That language is CAS 9904.418-40 wording, which applies only to fully CAS-covered contractors. FAR 31.201-4 itself reads "relative benefits received or other equitable relationship" and applies broadly. The distinction matters when explaining allocability to non-CAS-covered small businesses, who answer to FAR 31, not CAS.

Before

“Allocability requires a beneficial or causal relationship between the cost and the cost objective [FAR 31.201-4].”

After

Allocability under FAR 31.201-4 requires that the cost be incurred specifically for the contract, benefit both the contract and other work and be distributable in reasonable proportion to the benefits received, or be necessary to the overall operation of the business. The "beneficial or causal" language belongs to CAS 9904.418-40, which applies only to contractors under full CAS coverage.

Primary source

FAR 31.201-4; CAS 9904.418-40

Why it matters: A small contractor reading the wrong allocation standard might assume CAS-grade allocation rigor applies when it does not. The article was advising contractors above their actual regulatory burden.

CR-005 May 18, 2026

Practitioner-curated audit findings list framed as DCAA-canonical

Article: Top 10 DCAA Audit Findings and How to Prevent Them

What changed: The original article presented a Top 10 list as if DCAA publishes a canonical taxonomy of findings. DCAA does not. The DCAM (Defense Contract Audit Manual) lists audit procedures and risk areas; it does not rank a "top 10." We reframed the article as practitioner-curated based on engagement experience, with explicit citation to the DCAM sections that describe each finding type. We also corrected FAR 31.205-51 framing (the section exists and covers alcoholic beverages; an earlier review had incorrectly recorded it as nonexistent) and added CAS 418 applicability gates throughout.

Before

“DCAA publishes its top 10 audit findings every year. Here is the FY2024 list.”

After

DCAA does not publish a ranked "top 10" findings list. The DCAM (Defense Contract Audit Manual) describes audit procedures by area. Based on our engagement experience and DCAM Chapters 5 through 10, the most common findings on small-contractor incurred cost audits include timekeeping deficiencies, unallowable cost inclusion, indirect rate calculation errors, and allocability documentation gaps.

Primary source

DCAM Chapters 5 through 10; FAR 31.205 (cost principles)

Why it matters: Calling a practitioner list "DCAA-canonical" overstates what the agency has actually said. The list is still useful as practitioner experience. The framing was the error.

CR-006 May 18, 2026

FAR 31.205-6 subsection citations wrong in retirement and remuneration framing

Article: The 2026 Compensation Cap: What It Means for Your Indirect Rates

What changed: Earlier drafts cited FAR 31.205-6(p)(2) for the retirement contribution rule. That subsection covers pre-June 24, 2014 senior executive caps. The applicable subsection for the general compensation definition is FAR 31.205-6(p)(1)(i). A separate paragraph cited FAR 31.205-6(a) for "all forms of remuneration"; subsection (a) covers reasonableness. The "all forms of payment" language lives in FAR 31.205-6(d). We corrected both. We also re-verified the CY2025 cap of $671,000 against the DCAA Memorandum for Regional Directors and the Aprio and Redstone GCI calculations.

Before

“The compensation cap under FAR 31.205-6(p)(2) limits all forms of remuneration under FAR 31.205-6(a).”

After

The compensation cap mechanism lives in FAR 31.205-6(p)(1)(i), which defines compensation for cap purposes. All forms of payment are addressed in FAR 31.205-6(d). The CY2025 cap is $671,000 per OFPP and DCAA Memorandum 24-PSP-009(R).

Primary source

FAR 31.205-6(d); FAR 31.205-6(p)(1)(i); DCAA Memorandum 24-PSP-009(R)

Why it matters: Subsection-letter accuracy is the difference between an auditor agreeing with you and an auditor reading your article back to your face on Tuesday morning. We got it wrong. We fixed it.

CR-003 May 15, 2026

DFARS 252.242-7005 and 252.242-7006 conflated: withholding vs system criteria

Article: DCAA Compliant Timekeeping: Setup Guide for Government Contractors

What changed: Multiple articles attributed payment withholding authority to DFARS 252.242-7006. The actual withholding clause is DFARS 252.242-7005, which carries the 5 percent and 10 percent rates and the 45-day corrective action plan deadline. DFARS 252.242-7006 sets the 18 accounting system criteria. We also updated the "significant deficiency" framing to "material weakness" per DFARS Case 2021-D006 effective January 17, 2025.

Before

“DFARS 252.242-7006 authorizes the contracting officer to withhold up to 5 percent on flexibly-priced contracts.”

After

DFARS 252.242-7005 authorizes payment withholding (5 percent for one system deficiency, 10 percent for two or more, per (e)(1) through (e)(3)). DFARS 252.242-7006 sets the 18 accounting system criteria and the procedural framework for initial and final determinations. The terminology updated to "material weakness" under DFARS Case 2021-D006 effective January 17, 2025.

Primary source

DFARS 252.242-7005(e); DFARS 252.242-7006(c)

Why it matters: Citing the wrong clause when explaining withholding risk lets the auditor refute the article on inspection. The two clauses do different work. Mixing them is a structural error we found on six articles and corrected on all of them.

CR-001 May 14, 2026

Three-pool indirect rate model framed as regulatory mandate

Article: Fringe, Overhead, and G&A Rates Explained for Government Contractors

What changed: Our article opened with the claim that DCAA treats indirect costs as three pools: fringe, overhead, and G&A. Two former DCAA auditors flagged this on May 6, 2026. The actual rule, FAR 31.203(c), requires logical cost groupings with no specific pool count. The three-pool model is common practice for cost-reimbursement contractors, not a regulatory requirement. CAS 9904.418-40 sets a beneficial or causal allocation standard, but only for contractors under full CAS coverage. We rewrote the opening, every section header that implied the mandate, and the closing summary.

Before

“DCAA treats indirect costs as three pools: fringe, overhead, and G&A. Every government contractor structures their accounting this way.”

After

FAR 31.203(c) requires logical cost groupings. Most cost-reimbursement contractors use three pools (fringe, overhead, G&A) in practice, but the rule does not name a pool count. A single-rate or two-tier structure can satisfy 31.203(c) when activities are homogeneous, and complex operations may need more than three pools.

Primary source

FAR 31.203(c); CAS 9904.418-40

Why it matters: Treating common practice as a mandate is how brands lose credibility on the very rules they teach. A contractor with one contract type and one office does not need three pools to satisfy FAR 31.203(c). Forcing them into a structure that does not match their operations is the wrong advice.

CR-002 May 14, 2026

FAR 42.709 penalty structure inverted: default is 1x, not 2x

Article: 7 Costly Accounting Mistakes New Government Contractors Make

What changed: Earlier drafts described the FAR 42.709 penalty for unallowable indirect costs as 2x by default. The actual rule under FAR 42.709-2 is 1x for the first occurrence. The 2x penalty applies only when the cost was previously determined unallowable in writing in a prior audit, claim, or proposal. We also corrected the citation chain: the $1,000,000 threshold lives in FAR 42.709-1, not in the penalty clause itself.

Before

“Including unallowable costs in your indirect rate proposal triggers a 2x penalty under FAR 52.242-3.”

After

Per FAR 42.709-2(a), the penalty for unallowable indirect costs is the amount of the unallowable cost (1x). Per FAR 42.709-2(b), the 2x penalty applies only when the same cost was previously determined to be unallowable in writing. The $1,000,000 threshold for the penalty clause lives in FAR 42.709-1.

Primary source

FAR 42.709-1; FAR 42.709-2(a) and (b)

Why it matters: Doubling the perceived penalty scares small contractors out of indirect rate proposals entirely. The actual first-occurrence exposure is half what the article implied. Calibrated risk is the standard.

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