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Jules Martin

Jules Martin

September 28, 2026

DCAA rewrote six chapters of its Contract Audit Manual in August

If your audit response, your claim or your brief cites a paragraph of DCAA's Contract Audit Manual, check that it is still there. From August 19 to 28, 2026, DCAA reissued six chapters. The five that kept their subject went from 596 numbered paragraphs to 126, and Chapter 11 kept its number but now covers something else.

Boards of contract appeals and the Government Accountability Office have cited ten paragraphs of these chapters, every one in Chapter 6, the incurred cost chapter. Only two of those paragraph numbers still exist. This piece shows what DCAA reissued, which decisions are affected and what happened to each paragraph they cite.

The short version

  1. 1Most of the earlier text is gone. Of the 7,426 sentences in the revisions DCAA replaced, about 9 percent are still printed, word for word, in anything DCAA publishes.
  2. 2Chapter 11 is a different chapter. It used to cover contractor compliance with contract financial management requirements. It is now titled Performance Audits and Agreed-Upon-Procedures Engagements.
  3. 3The decided cases reach only Chapter 6. Of the 13 decisions that cite a numbered paragraph of the manual, eight cite one in an August chapter, and all eight cite Chapter 6.
  4. 4Eight of the ten cited paragraph numbers no longer exist. Of the five passages a decision quoted, three are no longer printed anywhere.
  5. 5Cite the manual by its revision date. DCAA replaces the file when it reissues a chapter, so name the revision you relied on and keep a copy of it.

Two terms used throughout

Numbered paragraph
The manual is written in numbered paragraphs, such as 6-104.1. The first number is the chapter.
Still printed
A sentence is still printed when it appears word for word in something DCAA publishes today: the manual, its cost guidebook, its audit programs or its audit guidance memos. A sentence DCAA reworded counts as gone.
Six grids of squares, one per Contract Audit Manual chapter DCAA reissued in August 2026, each filled to the percent of the earlier revision's sentences DCAA still prints word for word: Chapter 2 17.6 percent, Chapter 3 13.5 percent, Chapter 5 19.8 percent, Chapter 6 1.3 percent, Chapter 11 1.3 percent, Chapter 14 11.5 percent
Each grid is one chapter. Each filled square is one percent of the earlier revision's sentences that are still printed.

01What DCAA reissued in August

DCAA publishes the manual as one PDF per chapter, listed on its index, and replaces the file when it reissues a chapter. Of the 19 chapters on the index, six carry an August date:

Reissued by DCAA, August 19 to 28, 2026

Every chapter that kept its subject got shorter. Chapter 6, the incurred cost chapter, lost the most: 241 paragraphs became 11, and 1.3 percent of its earlier sentences are still printed. Chapter 5, on business systems, kept the most, at 19.8 percent. Chapter 14 was already on a revision dated April 2, 2026, and still went from 166 paragraphs to 27.

A dot chart of numbered paragraphs in each August chapter before and after the reissue: Chapter 2 99 to 46, Chapter 3 43 to 30, Chapter 5 47 to 12, Chapter 6 241 to 11, Chapter 11 11 to 14, Chapter 14 166 to 27
The dark dot is the revision before, the pale dot the August 2026 revision. Chapter 11 sits apart because its number now belongs to a different subject.

For you, a shorter chapter means two things. The paragraph you used to point to may not be in the chapter DCAA publishes today. And most of the old wording can no longer be quoted from anything DCAA publishes.

02Chapter 11 is a different chapter now

The Chapter 11 that DCAA replaced was dated August 31, 2020. It covered "contractor compliance with contract financial management requirements", and its first section opened:

This section provides guidance for auditing contractual limitations on costs, funds, and payments.

CAM 11-101, August 31, 2020

The chapter DCAA published on August 28, 2026 carries the same number and a new title, Performance Audits and Agreed-Upon-Procedures Engagements. Of the 79 sentences in the old chapter, one is still printed.

The old chapter is where the manual discussed the limitation of cost and funds clauses. If you cite Chapter 11 on those clauses, you are now citing a chapter about something else. Cite the old one by its date.

03The cited paragraphs are all in Chapter 6, and most are gone

GovConDash collects the decisions of four forums that cite the manual. They are the Armed Services Board of Contract Appeals (ASBCA), the Civilian Board of Contract Appeals (CBCA), the Court of Federal Claims and the Government Accountability Office (GAO). We read every decision that cites it, 24 in all, and noted each paragraph number cited.

Of those 24 decisions, 13 cite a numbered paragraph, and eight of them cite one in a chapter DCAA reissued in August. Every one of those paragraphs is in Chapter 6, the chapter on incurred cost audits. None of Chapters 2, 3, 5, 11 and 14 is cited by paragraph number in any decision.

The eight decisions come from the ASBCA, the CBCA and GAO. They were decided between 2011 and 2023 and cite editions of the manual from 2009 to 2023.

For each cited paragraph we asked two questions of the Chapter 6 that DCAA published on August 19, 2026. Is the paragraph number still there? And where the decision quoted the manual, are the quoted words still printed?

A table of the ten Chapter 6 paragraphs that decisions cite, marking for each whether the number is still in the chapter (two are) and, for the five quoted passages, whether the words are still in the chapter (two are) or anywhere DCAA publishes (two are)
Each row is one cited paragraph, with the forum and the year of the decision that cites it.

What happened to each of the ten cited paragraphs

Gone from the chapter: seven

  • CAM 6-414.3 Commercial salary websites

    Battelle Memorial Institute (GAO, 2020). The decision cites this paragraph without quoting it.

  • CAM 6-414.4 The ten percent range of reasonableness for executive pay

    Metron, Inc. (ASBCA, 2012, citing the December 2009 manual). The decision cites this paragraph without quoting it.

  • CAM 6-501 Charging a program manager direct or indirect

    Helionix Systems, Inc. (GAO, 2011). The decision cites this paragraph without quoting it.

  • CAM 6-608.2 A nomenclature review alone

    Voxtel, Inc. (ASBCA, 2023, citing the 2015 manual). The decision quotes "should not be accepted or rejected solely on the basis of a nomenclature review". Those words are no longer printed anywhere.

  • CAM 6-705.1 What provisional billing rates are for

    Tyonek Global Services, LLC; Depot Aviation Solutions, LLC (GAO, 2019). The decision quotes "used for interim reimbursement purposes until settlement is reached on final indirect cost rates". Those words are no longer printed anywhere.

  • CAM 6-707.2 Closing out a delinquent proposal

    Voxtel, Inc. (ASBCA, 2023, citing the 2015 manual). The decision quotes "determines that it is unlikely that an auditable proposal is forthcoming". Those words are no longer printed anywhere.

  • CAM 6-1008 Reconciling invoiced hours on vouchers

    Turner Construction Company (CBCA, 2017). The decision cites this paragraph without quoting it.

Moved to a new number: one

  • CAM 6-103.1 Audit scope is a matter of judgment

    HPM Corporation (CBCA, 2023, citing the April 2023 manual). The decision quotes "is a matter of audit judgment". Those words are now at CAM 6-103.

Still at the same number: two

  • CAM 6-102.1 The auditor's primary objective

    HPM Corporation (CBCA, 2023). The decision quotes "in whatever form they may be presented". Those words are still at this number.

  • CAM 6-104.1 Risk-based sampling of incurred cost proposals

    Advanced Technologies Group, Inc. (ASBCA, 2020, citing the 2013 manual). The decision cites this paragraph without quoting it. The number is still in the chapter, under the title Determining Sampling Eligibility.

One loss matters more than the rest. In Voxtel, Inc., the government had rejected indirect costs after a nomenclature review, which is a read of account names, and never tested transactions. The Board held DCAA's own manual against it. The sentence the Board quoted is one of the three that are no longer printed anywhere.

A dropped number does not undo a decision. Decisions have always cited the edition in front of them: Metron, Inc., decided in 2012, cites the December 2009 manual. What changes is what you can hand an auditor or a contracting officer today. If your argument rests on one of these paragraphs, cite it with its revision date and keep a copy of that revision, because DCAA no longer publishes it.

04Reading both revisions in GovConDash

Everything in this piece came out of two places on GovConDash: the Audit Readiness tab and the public decision pages.

Audit Readiness / Contract Audit Manual

Every chapter, with its earlier revision

The reader keeps the revision DCAA replaced beside the one it publishes, so a paragraph number from an old audit report or decision still opens. Free with an account.

Public decision pages

The decisions themselves

Each decision named above has its own page on this site, linked where it appears in this piece.

The Contract Audit Manual sub-tab of the Audit Readiness tab: a search bar over the whole manual and a card for each chapter carrying its revision date, with Chapters 2, 3, 5, 6 and 11 dated in August 2026 and each marked as having an earlier revision
The Contract Audit Manual sub-tab, signed in. Each August chapter card carries DCAA's date and a badge for the earlier revision the reader keeps. Click to open the capture full size.

Try CAM 6-608.2, the nomenclature passage from Voxtel, or CAM 6-705.1 on billing rates. Each opens in the revision that carries it.

Documents and data used in this piece

Every quotation and every cited paragraph number above was checked against a stored copy of its source before this page was written, 60 checks in all. Each August chapter was also compared with the PDF on DCAA's own site on September 28, 2026. Only sentences of 60 characters or more were searched for, because a shorter one proves little by being found. Counts were computed from the data, not typed. Each link below opens the publisher's own site or document.

The manual, as DCAA publishes it

The decisions that cite the August chapters

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 words each decision is described by are its own.

GovConDash.ai

Cite the manual your auditor is actually using

The Contract Audit Manual reader keeps every chapter DCAA replaced beside the one it publishes, and tells you when a paragraph number has dropped out. Free with an account.

Keep reading

DCAA Rewrote Seven Chapters of Its Contract Audit Manual in September

The month that followed: the chapters DCAA reissued in September, how decisions have used the manual, and where the passages they quoted are now.