Performance-Based Earned Value
Dept. of Government Efficiency (DOGE)
White Paper: "Common Sense Project Management: “When you come to a fork in the road…”, 12/18/24
Letters to DOGE, Congressmen, DoD Officials, and OMB
DOGE:
Musk, Subj: F-35 Idiots are the Taxpayers, not the Builders, Rev.1, 11/30/24 (correction of letter, 11/28/30)
You got it wrong in your F-35 post: "idiots are still building fighter jets like the F-35."
The idiots are not the F-35 builders...the taxpayers are. The contractors are smart enough to grab profits while building and selling a weapon system that fails to perform.
Subj: Recommendations to Drive Out Waste and Fraud at DOD, 11/12/24
Excerpts:
Pres.-elect Trump’s DOGE announcement today included commitments to drive out massive waste and fraud, drive large scale structural reform, and give the people a smaller Government, with more efficiency and less bureaucracy. There is low-hang fruit to accomplish these objectives by reforming how DOD acquires weapon systems and other major capital assets.
Simply:
- Get rid of regulations (FAR and DFARS) and compliance reviews for managing...cost plus contracts...to be compliant with “Earned Value Management System” (EVMS) guidelines in the EVMS Standard EIA-748. EIA-748 is a sham set of rules...like GAAP but full of loopholes and ambiguities that allow the contractor to submit false reports of cost and schedule performance.
- Replace award fees...based on subjective criteria. Use incentives to deliver products that work, on time, instead of merely executing “statements of work.”
- Reduce the DCMA compliance review work force and reassign...to be systems engineers and to focus on the product. We need engineers, not bean counters.
- Background and detailed implementation plans...in the white paper, EVM: “When you come to a fork in the road…” —Paul Solomon 7/25/2024.
Congressmen, Senators
Waxman letter, June 22, 2007, Subject: Award Fees and Contract Oversight
Excerpts: Award fee criteria must be revised to ensure that fee shall be paid based on the contractor meeting cost, schedule, and performance goals.
Skelton letter, 3/28/10, Subject: Panel on Defense Acquisition Reform
Excerpts:
Neither the DFARS EVMS clause 252.234-7002 nor its cited EVMS guidelines in EIA-748 require that contractors report progress toward achieving quality or technical goals that are specific and measurable. EIA-748 states that earned value is a “measurement of only the quantity of work” and that “quality and technical content of work performed are controlled by other means.” Guideline...describes the use of technical performance goals to measure progress as an option, not a requirement.
DoD’s Report to Congress, DoD EVM Performance, Oversight, and Governance, stated: contractors “keep EVM metrics favorable and problems hidden.” The deficiency in DFARS and EIA-748 enables contractors to report metrics that are more favorable than actual conditions and to defer reporting of real problems.
...acquisition managers...cannot be assured that a contractor’s performance metrics are valid or accurate...neither the GAO nor any other agency ever validated that EVMS truly integrates cost, schedule and quality/technical performance or that it provides accurate status and Estimate at Completion. There is a need to transform EVMS into a more valuable acquisition management tool that will provide early warning of performance problems.
letter...10/29/24, concluded...“Please provide legislative support to Dr. LaPlante that will enable him to tear down that barrier to entry to the defense industrial base and to replace botched, manipulated, meaningless, EVM metrics with outcome-based metrics. “
...introduce specific legislation that will...address the opinion piece that you and three HASC colleagues published, “Future of US defense depends on culture shift prioritizing innovation,” October 18. Excerpts from that opinion:
- DoD...slow and costly acquisition process hamstrung by a focus on the process and rigid requirements rather than fielding a capability and achieving results.
- Large programs...are built around onerous requirements or meaningless metrics rather than...desired outcomes.
Joni Ernst letter, 11/26/24, Subject: Happy Thanksgiving to You, Mr. Musk, and Mr. Ramaswamy
DoD Officials
My assessments and recommendations:
- Modernize SE processes to leverage DE and MBSE.
- DoD still has work to do to align its test activities with the new Adaptive Acquisition Framework (AAF) and to ensure that test and evaluation processes are properly structured to assess software-intensive systems.
- Details are in the white paper, Integrating the Embedded Software Path, MBSE, and DE with Program Management.
Lt. Gen. Masiello (DCMA) letter, 11/16/24, Subj: DCMA EVM Award Fee Guidance
Excerpts:
...fourth letter to your office, since 2021, regarding the silence in the DCMA EVMS compliance review process and DCMA EVMS Compliance Metrics (DECM) on the use of technical performance measures (TPM).
...DCMA’s failure, in the DoD E VM Implementation Guide (EVMIG), to use award fees to penalize contractors that do not base schedule performance data and earned value on technical performance.
Wasted DCMA Effort to Collect and Analyze EVM Compliance Metrics
Much of DCMA’s EVM compliance review effort is a waste of taxpayers’ money and diverts the attention of contractor and DoD personnel from building a product that works to executing and monitoring a failed process. Per the white paper, “EVM: “When you come to a fork in the road…”, 7/25/2024: highly skilled EVM specialists waste time and money reviewing data anomalies in contractually required, automated DECMs.” DECMs provide answers to process questions that are not useful to the program manager.
OMB
Excerpts:
As pointed out in the President's Management Agenda, CAP Goal 11: “Yet major acquisitions often fail to achieve their goals because many Federal managers lack the program management and acquisition skills required to successfully manage and integrate large and complex acquisitions into their projects. These shortcomings are compounded by complex acquisition rules that reward compliance over creativity and results.”
Current Recommendations to OMB: The following recommendations, if implemented, will fill the VCS vacuum, help to close the GAO findings, and help to meet legislative requirements:
(1) Adopt the VCSs for P/PM from the PMI, including ANSI/PMI 19-006-2019 in concert with PMBOK® Guide, instead of OMB-developed standards and
(2) Replace EIA-748 in the Capital Programming Guide with ANSI/PMI 19-006-2019 in concert with PMBOK® Guide.
(3) Revise the 5-year strategic plan for implementing the PMIAA to include these recommendations.
Excerpts:
The recent letter to Mr. Zients includes the objectives of the recommended reforms, as follows:
These reforms are still needed to reach the following objectives:
1. Acquire needed weapons within Pres. Biden’s budgetary goals.
2. Increase transparency and accountability regarding acquisition of capital assets.
a. Require contractors to submit valid reports of cost, schedule, and technical performance.
b. Identify unfavorable variances requiring corrective actions sooner.
c. Identify programs that should be cancelled, including Nunn-McCurdy breaches, years earlier. Achieve HASC Chairman Smith’s objective:
i. “We have wasted a spectacular amount of money on weapons systems that either haven’t worked at all or who have not lived up to their promise. The failure we wind up tolerating is failure on a massive freaking scale. Think F-35.”
ii. “I want to stop throwing money down that particular rathole.”
3. Remove a barrier to entry to potential commercial bidders on defense contracts.
4. Improve Program/Project Management (P/PM) training of civilian and military personnel.
Regarding Rep. Speier’s Markup Last year, Rep. Speier introduced a markup to the NDAA for FY 2021 that was included as HR 6395, Sec. 1745, Requirements Relating to P/PM. Unfortunately, that provision was receded per the Conference Report. I have requested that she reintroduce it in the current markup. See the letter to her, subj: Request to Resubmit HR 6395, Sec. 1745, in NDAA for FY 2022,dated July 2, 2021. If passed, it would amend Sec. 503.c.1.D of Title 31, USC by striking “consistent with widely accepted standards” and inserting “in accordance with standards accredited by ANSI.” Please support that acquisition reform.
Letter to Hon. Russell Vought, Director-nominee Office of Management and Budget, Subj: “When you come to a fork in the road…”, dated November 23, 2024.
Letter to OMB Director Shalanda Young, Subj: Transition Actions for You and Chief of Staff Zients, dated November 24, 2024