CDA Claim (CDA)
A CDA Claim is a written demand for money, time, or contract relief under the Contract Disputes Act (41 USC 7101-7109), filed with the contracting officer for a final decision.
What Is a CDA Claim?
A CDA Claim, often referred to simply as a claim, is a written assertion submitted by a contractor (or by the government against a contractor) seeking specific relief under a contract. A claim differs from a routine invoice or a request for equitable adjustment: it explicitly invokes the Contract Disputes Act and demands a final decision from the contracting officer.
Claims may seek recovery for change orders that were not definitized, government-caused delays, breach of contract, contract interpretation disputes, or termination costs. The CDA claim is the formal step that triggers the contracting officer's duty to issue a written final decision within sixty days (or notify the contractor of the date a decision will be issued for claims over $100,000).
The final decision, in turn, is the appealable event that gives the contractor access to a Board of Contract Appeals or the Court of Federal Claims.
Key Characteristics
CDA claims have several defining attributes. They must be in writing and must be submitted to the contracting officer.
They must request a sum certain or other specific relief; vague or open-ended demands are not claims. Claims over $100,000 must include a CDA certification stating that the claim is made in good faith, that the supporting data are accurate, that the amount accurately reflects the contract adjustment, and that the certifier is authorized.
They must be submitted within six years of accrual under the CDA statute of limitations. They are governed by FAR Subpart 33.2 (Disputes and Appeals).
They produce a final decision that is the foundation for any later appeal. Each characteristic shapes how a contractor structures, certifies, and submits a claim.
How It Works in Government Contracting
CDA claims operate at a defined sequence. First, a dispute arises between the contractor and the government over costs, time, scope, or interpretation.
The contractor often attempts informal resolution or submits a request for equitable adjustment (REA) first. Second, if the REA does not resolve the dispute, the contractor converts it into a CDA claim by adding a written demand for a final decision and, if the amount exceeds $100,000, the CDA certification.
Third, the contracting officer reviews the claim and issues a written final decision: granting it, denying it in whole or part, or asking for more time. Fourth, the contractor may appeal an adverse final decision to a Board of Contract Appeals within ninety days of receipt or to the Court of Federal Claims within twelve months.
Fifth, the Board or Court adjudicates the claim on the record. Interest accrues on the claim from the date the contracting officer received it, at the Treasury rate specified in the CDA.
Real-World Example
A federal agency awards a $5 million construction contract. During performance, the government issues a change order that increases the scope by $400,000.
The contractor performs the additional work and submits an REA for $400,000 plus thirty days of schedule extension. The contracting officer offers $250,000 and ten days.
The contractor and contracting officer cannot reach agreement after sixty days of negotiation. The contractor converts the REA into a CDA claim by adding a written demand for a final decision and the required CDA certification (because the amount exceeds $100,000).
The contracting officer issues a final decision at $275,000 and fifteen days. The contractor appeals to the Civilian Board of Contract Appeals within ninety days.
The CBCA holds a hearing, accepts evidence on both sides, and issues a decision awarding $375,000 and twenty-five days. The contractor receives the additional payment plus interest from the date the contracting officer received the claim.
Regulatory Framework
CDA claims are governed by the Contract Disputes Act (41 USC 7101-7109) and FAR Part 33 (Protests, Disputes, and Appeals). The CDA establishes the jurisdictional requirements: a claim must be in writing, submitted to the contracting officer, seek specific relief, and (over $100,000) include the CDA certification.
FAR 33.207 sets out the certification language; FAR 33.211 governs the contracting officer's final decision; FAR 33.213 governs interest. Appeals are governed by Board of Contract Appeals rules and by 28 USC 1491 for the Court of Federal Claims.
The CDA also includes a six-year statute of limitations from accrual. Failure to comply with the certification or submission requirements can result in dismissal of the claim, which is why contractors structure claims with these requirements in mind from the beginning.
Why It Matters for Contractors
CDA claims are the contractual mechanism by which contractors recover costs and time when negotiation fails. Without the CDA process, contractors would have no formal way to challenge a contracting officer's adverse decision short of breach litigation.
Claims interact with cost accounting (because the claim amount must reflect actual costs and be supported by job cost records), with past performance (because a contractor's claims posture affects evaluator perception), and with change orders and REAs (because most claims arise from unresolved change order disputes). Contractors that handle claims well treat the documentation discipline as ongoing: capturing time, cost, and impact data as performance occurs, not when a dispute arises.
The contractors that handle claims poorly find themselves trying to reconstruct events months or years later, with weaker evidence and higher litigation costs.
Common Misconceptions
Any letter to the contracting officer is a CDA claim.
No. A claim must be in writing, demand a sum certain or specific relief, request a final decision, and (over $100,000) include the CDA certification. Without these elements, the document is an REA or correspondence, not a claim, and does not start the final decision clock or interest accrual.
Filing a claim damages the contractor's relationship with the agency.
Not necessarily. Claims are a contractual right, and the CDA process is well established. Contractors that document carefully and assert claims professionally typically preserve their working relationships and their past performance ratings.
The contracting officer's final decision is the end of the road.
No. The final decision is appealable to a Board of Contract Appeals (within ninety days) or to the Court of Federal Claims (within twelve months). The Board or Court reviews the claim on its merits, including evidence beyond what was before the contracting officer.
Frequently Asked Questions
What is the deadline to appeal a contracting officer's final decision?
Ninety days to a Board of Contract Appeals or twelve months to the U.S. Court of Federal Claims. The deadline is calculated from the date the contractor receives the final decision.
When is the CDA certification required?
When the claim amount exceeds $100,000. The certification must state that the claim is made in good faith, the data are accurate, the amount accurately reflects the adjustment, and the certifier is authorized to certify.
How quickly must the contracting officer issue a final decision?
Within sixty days for claims of $100,000 or less. For claims over $100,000, the contracting officer must, within sixty days, either issue a decision or notify the contractor of the date a decision will be issued.
Does interest accrue on a CDA claim?
Yes. Interest accrues from the date the contracting officer receives the claim until payment, at the Treasury rate established under the CDA. Interest is in addition to the claim principal.
Related Government Contracting Topics
Change Order: Government-directed modification to contract scope, schedule, or terms; often the underlying event for a claim.
Contracting Officer: Authorized federal official who issues final decisions on CDA claims.
Bid Protest: Distinct mechanism for challenging a contract award or solicitation, not the same as a CDA claim.
Past Performance: Track record on prior contracts; can be affected by how contractors pursue and resolve claims.
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