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091262 1 (1979-02-16)

handle is hein.gao/gaobacuey0001 and id is 1 raw text is: 091262 February 16, 1979 The Honorable Layton Chiles United States Senate Dear Layton: This letter is by way of followup on our recent discussion with respect to the provision included in Section 509(c)(3) of fs.5, the proposed Federal Acquisition Reform ACt and the concerns erpressed by the Cost Accounting Standards Board wth respect to the inclusion of cost accounting standards in the proposed exemption. The provilon referred to above to substantially the same as the corresponding provision of 8.1264 which was introduced in the Senate dusing the 95th Congrecs and its predecessor Section 307 of S.3005 of the 94th Congress. As noted in our commento on the prior bills, Section 509(c)(3), if adopted, would result in duplicating responet- bilitio assigned to the Board by Public Law 91-379, which established it in 1970. As you know, the Board has granted a number of exemptions and waivers under its authority in this statute. These exemptions, once approved, have the effect of law. Unless certain of those were modified or repealed, the confusion in tnduotry and in the agencies would be very considerable should Section 509(c)(3) be enacted. I believe that you are well aware of other concerns which we have with respect to the provioioa in S.5. I continue to believe that Section 509(c)(3) is not a workable approach and would result in a far larger paperwork burden than the exemption provision which has been granted by the Board to take into account the problems of small business and commercial establishments having a small percentage of their total busineus devoted to contracts coming within the purview of cost accounting standards. I. .o t

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