Federal Disclosure Statements (DS-2)

Understanding CASB Federal DS-2 requirements for our three Universities

Public law requires certain contractors and subcontractors to comply with Cost Accounting Standards and to disclose in writing and follow consistently their cost accounting practices. The Cost Accounting Standards Board (CASB) Federal Disclosure Statement (DS-2) is the mechanism used to meet this requirement. The DS-2 requires universities to describe their educational institution, cost accounting system, cost accounting practices, disclose service centers with revenue >= $1 million and federal project revenue >= $250,000, and more. Specifically, the DS-2 has a direct correlation to our facilities and administrative rate methodology and proposals.

Universities which receive $50 million or more in federal awards during a fiscal year or have CAS covered contracts are required to maintain an accurate DS-2 and comply with the disclosed cost accounting practices. They must also compile and file the DS-2 with the federal government. In addition, original DS-2s are required to be amended when the university incurs a change in their accounting practices. However, typically the university’s DS-2 is revised in coordination with their related Facilities & Administrative (F&A) rate proposal process and not all revisions are the result of a cost accounting change.

Our Universities’ original DS-2s and Revisions are required to be submitted to our F&A cognizant agency, the Office of Naval Research (ONR). ONR then contracts with the Defense Contract Audit Agency (DCAA) to perform audits of the original DS-2s and related Revisions. Once the federal audits have been performed and the DS-2s/Revisions appropriately revised where necessary, DCAA submits their audit reports to ONR. ONR reviews the reports and ultimately grants approval of the DS-2s/Revisions.

System Government Costing responsibilities

The University of Illinois System Government Costing office is responsible for compiling, revising, submitting, supporting, and working with the federal government to obtain approval of Urbana-Champaign and Chicago’s DS-2s and Revisions.

View Disclosure Statements (DS-2s) for your University (requires University login and 2FA identification)

Frequently Asked Questions

Question: Why have some of the DS-2 Revisions been approved by the federal government and other Revisions have not been approved?

Answer: The University does not have control over the federal government’s audit and approval process. In past years the DS-2 has not been a top priority for the federal government to review. That is changing, however federal government resources have generally been the reason that our Universities DS-2s have not been reviewed and approved. Our office continues to approach the federal government each year to obtain approval of all DS-2 versions. Regardless the most recent DS-2 Revisions for each University represent our current accounting practices.