DCAA rewrote seven chapters of its Contract Audit Manual in September

01What DCAA reissued this month

DCAA publishes the manual as one PDF per chapter and replaces each file when it reissues the chapter. Its index lists 19 files today, and seven of them carry a September 2026 date.

Most of these chapters are shorter, and some by a lot. Chapter 8, Cost Accounting Standards, now runs to six pages. Chapter 9, Cost Estimates and Price Proposals, went from 233 numbered paragraphs to 70, and it is the newest revision on the list, dated September 21, 2026. Chapter 12, on terminations, delay and requests for equitable adjustment, went from 111 to 68.

A shorter chapter is not necessarily a looser one, and what the cuts mean for audit practice is DCAA's to say. What they change for certain is citation. Paragraph numbers are how people cite the manual, and in a chapter that goes from 130 numbered paragraphs to 10, most of the old numbers no longer exist.

Chapter 7 is the one change of subject. DCAA's index now titles it Fraud. We read that chapter closely in a separate piece.

02The manual is not law, and it says so

Start with what the manual is. It is DCAA's guidance to its own auditors, and its Foreword is plain about how it expects to be used.

The material in this manual is instructive. Reference to this manual should not be made in audit reports or correspondence addressed to offices other than those of DCAA.

Tribunals have taken the manual at its word. In Advanced Powder Solutions, Inc. v. United States, the Court of Federal Claims noted that "the DCAM itself specifically instructs auditors to avoid citing the DCAM" in audit reports or correspondence outside the agency. In a protest by Battelle Memorial Institute, GAO said the manual "is for use by DCAA personnel, and is not a mandatory or binding regulation for procuring agencies".

In IAP Worldwide Services, Inc., the ASBCA said the same about the cost guidebook that grew out of the manual: "the guidebook is not binding on us".

Not binding does not mean irrelevant. In an attorney fee dispute, J.F. Taylor argued that DCAA's executive compensation method rested on "a manual that is not published and does not have the force of regulation". In its October 2013 decision the Board kept its finding that the government's position was substantially justified, partly because the method had been in the manual for years. The manual shows what DCAA told its auditors to do, and that is often exactly what a dispute is about.

03How courts and boards use it

We searched the full text of every decision this platform holds at six tribunals for the manual by name, then read each hit. The Armed Services Board accounts for 14 of the 24. The Federal Circuit (360 opinions on file) and the SBA Office of Hearings and Appeals (1,194 decisions) do not cite it at all.

The largest group, nine decisions, uses the manual to explain how something is done: the Eichleay formula, the range of reasonableness for executive pay, disposal credits in a termination settlement, provisional billing rates. In five more it sits in the record without deciding anything. The four that said what the manual is are the ones part 02 quoted. Each decision below opens on its own page on this site.

04When the manual is read against the government

This is the use that matters most to a contractor. When DCAA's own guidance says an auditor should do something and the auditor did not, a board will notice. In Voxtel, Inc., the government rejected indirect costs after a nomenclature review, a read of account names. The manual says "a nomenclature review alone is not a sufficient basis to reject a category of indirect expenses", and the Board added:

Ironically, the same criticism could be leveled at the government

The same move works on narrower points. In Technology Systems, Inc., the Board quoted DCAA's own guidance that the auditor "should not insist on a work product if other evidence provided is sufficient to determine the nature and scope of the actual work performed". In Turner Construction Company, the Civilian Board held that a voucher paragraph the agency relied on "does not apply to T&M contracts or to changes under a fixed-price contract".

In Sikorsky Aircraft Corp. v. United States, the Court of Federal Claims read the manual's instructions on when CAS noncompliance should be caught. The government had contracted on the very practices it later called noncompliant, and the court concluded that "this instruction is enough to allow Sikorsky to state a plausible claim" that its own rights were affected. And in the Boeing and Raytheon offset appeals, the Board noted that DCAA's own manuals had allowed the offsetting at issue.

The practical point for a rebuttal: when an audit finding departs from the procedure the manual sets out, quote the manual, at the revision in effect when the audit was done.

05The passages they quoted, and where they are now

A manual citation is only as good as the revision behind it, and this month proved it. We took every passage a tribunal quoted word for word and looked for the same words in the manual DCAA publishes today.

The Eichleay sentence survived word for word. In Venergy Group, LLC, the Board quoted that total billings are "revenues for all contracts (including Government and commercial) recognized for the period of actual contract performance including the delay/suspension and extended performance periods". The revision of September 18, 2026 carries the same words at 12-609.2, and Chapter 12 no longer has a paragraph 12-804.2. The other paragraph the Board cited that day, CAM 12-805.1, is not in the new chapter at all.

Six of the nine passages are gone. The Court of Federal Claims built part of its reasoning in Sikorsky on CAM 8-302.1, which called CAS audit responsibility a "continuous requirement". The September 17, 2026 Chapter 8 carries neither the paragraph nor the phrase. The Chapter 9 paragraph the court cited beside it, 9-1206, did not survive the revision of September 21, 2026. The nomenclature passage the Board relied on in Voxtel is not in the Chapter 6 revision of August 19, 2026.

Not everything went this month. In 2023 the Civilian Board quoted CAM 1-403.1 on auditors and contracting officers sharing information. That sentence was dropped in the revision of July 16, 2026; the paragraph number is still there, with different words under it. And the Foreword's rule about not citing the manual outside DCAA, the one the Court of Federal Claims relied on, is still 0-002, unchanged.

What this means for you is simple. A citation to the manual without a revision date now points at a paragraph that may not exist. Cite the chapter's date the way the Board did in Venergy, and keep the PDF you relied on. Before you quote an older decision's manual citation back to an auditor, check whether the words are still there.

06Researching the manual and the case law in GovConDash

Everything in this piece came out of two parts of the platform: the Audit Readiness tab, which holds DCAA's guidance, and the decision tabs, which hold the case law. They are built to be used together.

To do what this piece did for your own issue, take the manual paragraph an auditor cited. Search the decision tabs for it, read how the boards treated it, then open it in the reader to see whether it still says the same thing. Try CAM 6-608.2, the nomenclature passage from Voxtel, or CAM 12-609.2, where the Eichleay text sits now.

Documents and data used in this piece

Every quotation above was checked against a stored copy of its source before this page was written, 63 checks in all. Each passage from the current manual was also found in the PDF on DCAA's own site on September 23, 2026. Counts were computed from the data, not typed. The decisions were found by searching for the manual by name and read one by one. Each link below opens the publisher's own site or document.

This piece is commentary on published audit guidance and on published decisions. It is not legal advice, and it is not a determination about any contractor, contract or audit. The Contract Audit Manual is guidance to DCAA personnel and does not itself create obligations for a contractor. The grouping of decisions by use is our reading; the words each decision is described by are its own.

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Read the manual your auditor is working from, and the cases that read it

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