CAS Pricing and Engagement Classification Under SSARS 27

CAS pricing has largely left the billable hour behind, and in 2025 the profession redrew the standards line underneath CAS engagements themselves. This post covers both: how firms structure CAS pricing, what the benchmark data actually says, and how SSARS 27 changed the classification question for financial statements prepared inside an advisory engagement.

This is the third post in a three-part series on building and running a CAS practice. Part 1, What Is a CAS Firm covers scope and the service ladder. Part 2, Running a CAS Practice covers staffing, cadence, and technology.

CAS pricing models: the structures

Five structures cover nearly everything in use. Most practices run a hybrid.

• Fixed fee: a stated monthly price for a stated scope. Simple to sell, dangerous without scope discipline, because scope creep comes straight out of margin.
• Value-based: priced on the outcome the client buys rather than the inputs. Most common at the CFO and insights level, where the deliverable is a decision, not a document.
• Subscription or retainer: tiered packages, typically bronze-silver-gold style, with defined service levels. The dominant pattern for standardized financial CAS.
• Hourly: the legacy model, now the exception in CAS.
• Hybrid: a fixed base for the recurring scope plus defined rates or project fees for out-of-scope work. In practice, most mature CAS engagements end up here.

The benchmark data is blunt about where the profession has landed. The 2024 CPA.com and AICPA PCPS CAS Benchmark Survey found "only 10% of respondents still employing hourly billing as the primary pricing method," down from 53% in 2018, per the Journal of Accountancy's coverage of the same survey. The structural reason is straightforward: CAS sells a continuous service with a predictable monthly cost, and hourly billing makes the one thing the client values most, predictability, impossible.

One more data point for firms formalizing their approach: in the same survey, practices with a formal written CAS business plan reported $27,761 in median average annual client revenue, nearly $10,000 more than all respondents. That is an association in a self-selected survey of 206 practices, not proof that writing a plan raises fees, but it is consistent with the pattern that deliberate practices price deliberately.

What you will not find in this post is a recommended monthly fee or margin target. Published medians describe other firms' books of business, not your market, your client sizes, or your scope. Price from your own cost to deliver and the value of the decision support, and treat any benchmark number as context.

Engagement classification: what SSARS 27 changed

Here is the standards question every CAS practice has lived with: when a firm prepares financial statements as part of a recurring advisory engagement, is that an AR-C Section 70 preparation engagement under the SSARSs, or part of the consulting work?

In 2025 the AICPA's Accounting and Review Services Committee answered it. SSARS 27, Applicability of AR-C Section 70 to Financial Statements Prepared as Part of a Consulting Services Engagement, clarifies that AR-C Section 70 excludes financial statements prepared as part of a consulting services engagement performed under CS Section 100.

The operating rule, as laid out in CPA.com's FAQ on the clarification, turns on the engagement's primary objective. Where the preparation of financial statements is the primary objective, the work falls under the SSARSs, as it always has. Where it is not the primary objective, because the engagement's purpose is recurring process support, advisory work, or other consultative services, the firm can elect to conduct the entire engagement under the consulting standards.

The classification carries real consequences. Per the same FAQ, work performed under the SSARSs falls under the quality management system and peer review, while work performed under the consulting standards does not fall under the quality management system or peer review. The professional floor does not move, though: the FAQ is explicit that the responsibilities under the Code of Professional Conduct, including due professional care, are the same whether the work is performed under SSARS 21, AR-C Section 70, or CS Section 100.

The effective date gives firms time to get the analysis right: SSARS 27 is effective for the preparation of financial statements for periods ending on or after December 15, 2026, with early implementation permitted.

Three practical implications for a CAS practice:

1. The engagement letter is the classification. Write it to say what the engagement's primary objective is, and make sure the letter, the work, and the deliverables tell the same story.
2. An election to work under CS Section 100 is a quality decision, not just a compliance one. Leaving peer review's scope does not lower the standard of care, and firms should decide deliberately what internal review replaces it.
3. Mixed books of business need a policy. A firm with both SSARS preparation engagements and CS Section 100 advisory engagements should be able to say, client by client, which is which and why.

Niches and growth: what the data supports

The 2024 survey's most quoted finding is about industry specialization: practices earning more than half their revenue from defined industry niches reported 38% higher median CAS revenue and 51% higher net revenue per client than all respondents, with construction, professional services, not-for-profit, and retail the most common niches.

Read that as an association, not a mechanism. The survey is a self-selected sample of 206 practices, and practices that reported niche concentration also reported higher revenue; nothing in the data proves that niching produced it. The plausible story is that specialization enables standardization, and standardization is what the rest of this series is about. The case for picking a niche in the first place, including how to prune a generalist client base to get there, is in How to Grow Past Taking Every Client.

Frequently asked questions about CAS pricing and classification

How do CAS firms price their services?

Mostly on fixed or subscription structures: a stated monthly fee for a defined scope, often in tiered packages, with value-based pricing at the CFO and insights level and hybrid arrangements for out-of-scope work. Hourly billing is now the exception; the 2024 CPA.com and AICPA PCPS benchmark survey found only 10% of respondents using it as their primary pricing method.

Do CAS engagements require peer review?

It depends on classification. Financial statement preparation performed under the SSARSs falls under peer review and the quality management system. Under SSARS 27, an engagement whose primary objective is not financial statement preparation can be performed entirely under CS Section 100, and consulting-standards work does not fall under peer review. The Code of Professional Conduct applies either way.

What is SSARS 27?

SSARS 27 is the AICPA Accounting and Review Services Committee's clarification that AR-C Section 70, the preparation standard, excludes financial statements prepared as part of a consulting services engagement under CS Section 100. It is effective for the preparation of financial statements for periods ending on or after December 15, 2026, and early implementation is permitted.

Is value-based pricing realistic for CAS?

At the advisory level, yes, because the client is buying decision support with a knowable value rather than a stack of processed transactions. At the financial CAS level, most firms find subscription tiers more workable: the scope is standardized, so the price can be too. Many practices run both, with the tier covering the recurring scope and value pricing applied to CFO-level work.