We reported on the new CAS applicability threshold of $700,000 right here.  One issue with the implementation of the higher threshold was how to deal with FAR solicitation provisions and contract clauses, which continued to use the old, superseded, threshold of $650,000.  In our previous article (link above) we wrote—

One issue with this rule change is how to apply it to subcontracts under existing prime contracts.  Although the CAS regulations have been revised, no similar revision has been made (yet) to the CAS Administration rules in FAR Part 30, nor have any revisions been made to the 52.230 series of CAS-related contact clauses.  At the moment, the FAR language continues to use the now outdated $650,000 CAS applicability threshold.

We were not the only ones to figure out the problem.  In fact (as we reported) one commenter raised the issue to the CAS Board itself, only to be told that addressing the issue was “beyond the authority of the CAS Board” and needed to be addressed by the FAR Councils.  Given the FAR Council’s rule-making process, it will take some time—perhaps measured in months—to revised the FAR to conform to the CAS regulations.

Richard Ginman, current Director, Defense Procurement and Acquisition Policy (DPAP) decided that the DOD couldn’t wait for the FAR Councils to act.  On January 31, 2012, DPAP issued a Class Deviation to DCMA Contracting Officers, providing them with revised solicitation provisions and contract clauses.  The Class Deviation is linked here.  The new provisions and clauses are to be used by Contracting Officers in “new solicitations and resultant contracts,” effective immediately.

The CAS-related provisions and clauses include the series 52.230-1 through 52.230-5.  The provisions/clauses are to be used as directed by FAR 30.201-3 and 30.201-4—except the prescriptions in those FAR regulations “shall” be modified to read with the new CAS threshold of $700,000, instead of the current language, which contains the old, superseded, threshold.

For DOD Contracting Officers (and, presumably, for DOD Prime Contractors), problem solved.