OTA contracts that were supposed to bypass FAR are now layered with FAR-like requirements by risk-averse COs

Other Transaction Authorities were created to let DoD contract with non-traditional defense companies without the full FAR/DFARS compliance burden. In practice, Contracting Officers trained in FAR-based procurement add FAR-like requirements (DCAA-compliant accounting, certified cost or pricing data, CAS compliance) to OTA agreements because they fear audit findings. A startup choosing OTA to avoid FAR paperwork discovers the same compliance requirements attached informally. This persists because COs face personal liability for contracting violations but no consequences for being overly conservative, creating an asymmetric incentive to add requirements rather than streamline.