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TINA Lite: DoW’s New “Shopping List” Sheds the Excess Data

By Evan Sherwood and Phillip Seckman
October 5, 2026
  • General
  • Government Contracts
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The Department of War has rolled out guidance on TINA Lite. If implemented effectively, it could speed up negotiations, clarify what constitutes cost or pricing data subject to certification, and reduce post-award audit risk and disputes. The concept is straightforward: instead of the sprawling disclosure obligations that have long haunted federal procurements, contractors and contracting officers establish a focused “shopping list” of data to submit and certify. If it’s not on the list, it’s not required. Period.

The TINA Lite guidance comes at a time of new focus on cost or pricing “transparency.” On August 18, 2026, Deputy Secretary of War Steve Feinberg announced that “contracting officers must have access to actual cost information at both the prime and supplier levels for these contract actions [above $10 million, except for Commercial Off-the-Shelf items] to support the determination of fair and reasonable pricing.” He underscored that point in a follow-up memo on September 14, 2026, explaining that COs have the “option” to “see through the prime contractor to the suppliers when needed.” Simultaneously, the September 14, 2026 memo emphasized that for those outside the “CAS covered core,” the government needed to rely on data as maintained in the ordinary course of business under generally accepted accounting principles. So, as DoW seeks to attract new entrants to the defense industrial base, it is also looking for ways to clarify what cost or pricing data must be disclosed and certified. It is in this environment that TINA Lite may give contractors a workable solution to meet DoW’s needs and manage the risks of sharing certified cost or pricing data.

Here’s what the TINA Lite program looks like in practice, and why contractors should be paying attention.

Read the full article at Dentons.com

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Evan Sherwood

About Evan Sherwood

Evan Sherwood is a partner in the Dentons Government Contracts-US practice, counseling federal contractors on Contract Disputes Act (CDA) claims, the cost accounting standards (CAS), cost allowability, requests for equitable adjustment (REAs), commercial products/services contracting, contract terminations for convenience / default, and related audits, litigations, and investigations.

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Phillip Seckman

About Phillip Seckman

Phillip Seckman represents clients concerning government and commercial contract matters. His practice spans a broad range of subjects related to federal procurement law, state and local procurement law, and complex federal regulatory issues. He concentrates his practice in the areas of commercial item acquisitions, GSA schedule contracting, cybersecurity, compliance, internal investigations, and bid protests (both federal and state). A significant component of his practice involves government contract cost allowability, proper cost accounting, and contract cost and pricing issues.

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