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091257 1 (1978-10-10)

handle is hein.gao/gaobacuex0001 and id is 1 raw text is: 





                                October 10,  1978


 The Honorable John C, Stenats
 Chairman, Committee on Armed Services
 United States Senate

 Dear John;

      You have before you, by referral from  thp Senate Governmental
 Affairs Comdttee,  S, 1264, the Federal Acquinition Act  of 1977'
 This bill grove out of the work of the Federal Procurement  Comnisnion
 of which I was a member,  Aside from that, we  in GAO have a very sub-
 stantial interest in it.  There is one provision  in S. 1264 which con-
 corns me a great deal,  Tht  has to do with  the waiver or exemption
 provisions in aection 509.  This provision would  override the work of
 the Cost Accounting Standardo Board, of which  I a  the Chairman, with
 respect to waivers or exemptitns from those standards  in a way which
 I believe would cause tremendous confusion in  the Dofense Department
 and among Defense contractors.

      The Cost Accounting Standards board currently  has a statutory
 responsibility for making judgments of this  type and we have  ssuoed
 a number of regulations which exempt small busineries  and other con-
 tractors who do a small percentage of their businces with  Government.
 To require contractors to adhere to boIt.h the Board requirements as
 well as those written into the statute would be  terribly confusing
 and wasteful.

      I hope very much that you will take a look at  this provision.
 Your staff has a great deal of backup material on  it from our office.
 I would be delighted to visit with you personally about  the matter
 if that would be helpful.

      Beet wishes.

                                Sincerely,



                                Elmer B. Stacte

cc:  OCR

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