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B-198620 1 (1981-08-13)

handle is hein.gao/gaobabjbq0001 and id is 1 raw text is: 

                  COMPTROLLER GENERAL OF THE UNITED STATES
                           WASHINGTON D.C. 20548


PLRD/GP-40                                 August 13, 1981
B-198620


The Honorable James J. Blanchard
Chairman, Subcommittee on Economic
  Stabilization
Committee on Banking, Finance and
  Urban Affairs                                             ,,.. ..
House of Representatives              ,j, yj 0 L, LOW              :

Dear Mr. Chairman:

     This is in response to your June 29, 1981, letter in which
you raised two   - sues related to Cost Accounting Standards (CAS).
First, you pointed out that before any attempt was made to amend
or repeal CAS 409, Depreciation of Tangible (Capital) Assets,
an independent agency should further examine all of the issues
involved. Second, you asked to be apprised of the status of any
current GAO reviews dealing with Cost Accounting Standards.

     We agree that an examination and review should be made prior
to changing any of the Cost Accounting Standards promulgated under
Public Law 91-379. As you pointed out CAS 409 underwent extensive
research in support of its promulgation. The report of the Defense
Industrial Base Panel of the House Committee on Armed Services,
dated December 31, 1980, and the Department of Defense (DOD) Memo-
randum dated April 30, 1981, both include a common element, in that
they suggest changes to CAS 409 as a means of offering incentives
for industry to invest in tangible capital assets. It should be
remembered, however, factors other than CAS 409 which bear directly
on this point. CAS 414, for example, is one factor; DOD's profit
policy is another.

     Before an apparently simple solution, such as amending or
repealing CAS 409 is attempted, all of the factors that have been
identified as affecting additional capital investment should be
examined and a set of recommendations should be developed that
would deal with all of the issues. This would include considera-
tion of the current DOD profit policy, CAS 414, and corporate man-
agement's orientation toward long-term investment. In particular,
the position to avoid is one where corrective action is taken that
deals only with some of the factors involved and thus provides no
real assurance that the remaining impediments do not negate the
attainment of the goal of improving the investment climate. The
recommendations dealing with CAS 409 should not be segregated from
other issues in this rather complex area dealing with investment
incentives.

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