A nontraditional defense contractor is an entity that is not currently performing and has not performed, for at least the one-year period preceding the issue date of the Spectrum Request for Prototype Proposals, any contract or subcontract for the Department of Defense that is subject to full coverage under the cost accounting standards prescribed pursuant to section 1502 of title 41 and the regulations implementing such section. Chapter 99 of Title 48, has a clear set of requirements for full coverage under Cost Accounting Standards and then a separate set of requirements for educational institutes. While we do allow member organizations to self-certify, it is our understanding that educational institutions are subject to special CAS and not full CAS.

Please see the following and attached from the DCAA Audit Manual:
8-103.1 Educational Institutions-CAS
Contracts and subcontracts with educational institutions are subject to special CAS coverage (see13-209). Contracts and subcontracts performed by federally funded research and development centers operated by educational institutions are subject to CAS coverage for commercial companies.