By Thomas A. Lemmer and Tyson J. Bareis: The Pension Protection Act of 2006 (“PPA”) gave the Cost Accounting Standards (“CAS”) Board (“CASB”) until January 2010 to bring CAS into compliance with PPA. That did not occur. In late 2011, the CASB issued a final rule (the “final rule”) purporting to harmonize CAS 412 and 413 with PPA, effective Feb. 27, 2012.