The current standard is the ANSI EIA Standard 748D, published in January 2019. The NDIA Integrated Program Management Division submitted a draft revision, EIA-748E, for balloting and approval by SAE International, the voluntary consensus body. Paul Solomon raised a procedural complaint to the SAE Systems Management Council (SMC), arguing that EIA-748E constitutes a business standard rather than an engineering standard, and that it falls outside the purview of the SAE G-27 Systems Engineering Committee's charter, according to the SMC rules.
Shortcomings of the EIA 748 guidelines, which render it 'not fit for use,' are detailed in the white paper, 'Outcome-Based Metrics Plus SE' = Integrated Program Management and in the following section. Engineering best practices are also discussed in the white paper that focuses on integrating the Embedded Software Path, Model-Based Systems Engineering, MOSA, and Digital Engineering (DE) with Program Management, aligning with the EIA 748 guidelines.
EIA-748D, published in January 2019, must be revised or reaffirmed every five years to comply with the ANSI EIA standard 748. The NDIA Integrated Program Management Division has submitted a draft revision, EIA-748E, for balloting and approval by SAE International, the voluntary consensus body (VCS). Paul Solomon submitted an appeal to the SAE Systems Management Council (SMC), arguing that the EIA 748 guidelines, specifically EIA-748E, are a business standard rather than an engineering standard, which he claims falls outside the scope of the SAE G-47 Systems Engineer Committee's charter.
Additional information is included in the following letters to Dept. of War and OMB officials, as well as in the white papers that reference the ANSI EIA Standard 748 and the EIA 748 guidelines discussed therein.
This is not an engineering standard; it is a business standard that falls outside the scope and technology area of the G-47 SE Committee. It does not represent best practices in engineering concerning (4) quality and (5) other areas that conform to broadly accepted engineering practices or specifications for a product, process, procedure, or test method. Additionally, it does not align with the ANSI EIA Standard 748 or the EIA 748 guidelines, and it is not within the scope of SAE International’s policies or the SMC Org. and Operating Procedures, including the EIA-748 guidelines.
Warfighting Capabilities. The reforms should lead to expedited outcomes and implementation of DE. Both objectives require outcome-based metrics. Consequently, the reforms should abandon the NDIA’s EVMS standard, ANSI EIA Standard 748, and replace it with Project Management Institute (PMI) standards and guides. The GAO provided justification to utilize PMI documents, aligning with EIA 748 guidelines and ensuring compliance with EIA-748 guidelines.
Gen. Thompson is committed to developing and delivering a DE ecosystem that allows the Space Force to rapidly mature innovative concepts into integrated solutions, ultimately enhancing warfighting capabilities. I urge you to consider my advice for the Space Force’s success. The ongoing reliance on the ANSI EIA Standard 748, which lacks guidance on engineering practices, DE, and product scope, undermines the effective implementation of DE and hinders the achievement of schedule and cost benefits outlined in the EIA 748 guidelines.
Best practices that should be added to the revised documents include:
· The product baseline and the Minimum Viable Product (MVP) as well as the Minimum Viable Capability Release (MVCR) baselines, in line with the ANSI EIA Standard 748.
· Collection of DE metrics to assess schedule progress and quality towards the MVP and MVCR, adhering to EIA 748 guidelines.
· Automated requirements traceability to completion criteria in the schedule, following EIA-748 guidelines.
· Measures used to track progress towards completing MVPs and MVCRs within the digital thread, ensuring compliance with EIA 748 standards.
Request that SAE Int. cancel the ANSI EIA Standard 748, specifically the EIA-748 guidelines, because it is deemed 'not fit for use.'
Since September 3, letters have been posted on my website that outline key engineering best practices. These practices align with the ANSI EIA Standard 748 and the EIA 748 guidelines, which are essential for any system engineering or project management standard.
Neither version of the NDAA for FY 2026 includes an acquisition reform that was first recommended to Ike Skelton in 2010. He marked up the NDAA for FY 2011 to add a provision on EVMS, which should align with the ANSI EIA Standard 748. Please address EVMS in conference with the SASC along with other acquisition reforms mentioned in my letter to Dep. Sec. of War Feinberg dated 10/24, subject: Additional Engineering Best Practices Absent from the EIA-748 guidelines. Additionally, coordinate with OMB Director Vought to fix the outdated OMB policy regarding the EIA 748 guidelines.
A prioritized menu of actions to quickly leverage the benefits of a digital engineering ecosystem while adhering to the ANSI EIA Standard 748, including the EIA 748 guidelines.
Eliminate a corrupt business process that is overly complicated, overregulated, and overdue for reform, specifically regarding the ANSI EIA Standard 748. Influence the SAE Council ballot by informing them that you agree with my stance. Additionally, inform Dep. Sec. Feinberg and OMB Director Vought that the EIA 748 guidelines are unfit for use.
(ASW(MC)) James Caggy affirmed that he will leverage SE and DE practices, along with rigorous foundational engineering activities early in the capability life cycle, to achieve improved cost, schedule, and performance results. Additionally, I urge you to take action on my procedural appeal to SAE International regarding the draft EIA/748E, which aligns with the ANSI EIA Standard 748 and the EIA 748 guidelines.
Two issues require your attention.
1. Initiate the process to terminate the DFARS Earned Value Management System (EVMS) clause in accordance with the EIA 748 guidelines.
2. Obtain the benefits of the digital engineering (DE) ecosystem ASAP.
By doing so, we can remove an obstacle to institutionalizing 'going digital, including program management,' a goal established by Gen. Duke Richardson and myself during his tenure with SAF/AQ in 2022, which aligns with the ANSI EIA Standard 748.
A non-value-added layer of bureaucracy that should be eliminated is the DCMA organization that reviews compliance with the earned value management system (EVMS) business process according to the EIA-748 guidelines, which are part of the ANSI EIA standard 748.
Eliminating the driving DFARS EVMS clause will require statutory authority and a revision to OMB policy. Please include DoW’s intent to obtain such authority and policy revision in the final memo, 'Transforming the Warfighting Acquisition System to Accelerate Fielding of Capabilities.'
Go beyond preparing options to cease compliance-focused training at DAU. Go the whole 9 yards and take actions to terminate EVMS compliance reviews that were outlined in my letter to PTDO OUSD(A&S) Morani, Subj: Further Reduction in Scope of DCMA EVMS Compliance Reviews – Surveillance, dated March 18, 2025, which also aligns with the ANSI EIA Standard 748 and the EIA 748 guidelines.
This letter augments my letter dated November 7, Subj: Compliance-focused Training at DAU and Other Savings. It incorporates the President’s Management Agenda (PMA) issued by OMB today. The PMA includes key management reform objectives to:
· Eliminate jobs in non-essential, non-statutory functions, aligning with the ANSI EIA Standard 748 principles.
· Eliminate data silos and duplicative data collection, emphasizing adherence to EIA 748 guidelines.
Amend S. 5618 to apply the EVMS exemption to all contractors. Support DOW objectives in the Acquisition Transformation Strategy to measure progress by providing real-time and continuous access to program performance data, leveraging authoritative data sources, and automated reporting, while adhering to the EIA 748 guidelines. This approach ensures that outcome-focused metrics align with the ANSI EIA Standard 748.
Pending revision to SAE/EIA-748 EVMS Std. (EIA-748E) is unfit for use as a voluntary consensus standard. Silent on risk responses and rework, technical performance measures, and product scope. It does not support the Acquisition Transformation Strategy to remove unnecessary process and regulations, to leverage existing authoritative data sources, including contractor data and automated reporting mechanisms to assess program performance. EVM data is not trustworthy and may be manipulated.
Terminate effort to revise the EVM System Interpretation Guide, used to assess EVMS compliance and the EVM Implementation Guide.
Immediately reduce costs and focus management on speedy product delivery, not on compliance with the process. Of course, the end goal is elimination of the DFARS EVMS clause and implementation of outcome-based metrics within the digital engineering ecosystem.
NDAA FY 2016, Sec. 809, established an advisory panel (Panel) to streamline and improve the efficiency and effectiveness of the defense acquisition process and to make recommendations for the amendment or repeal of regulations. In 2018, the Panel reported that "another substantial shortcoming of EVM, as defined by ANSI EIA Standard 748, is that it does not measure product quality. According to the EIA 748 guidelines, a program could perform ahead of schedule and under cost based on EVM metrics but still deliver a capability that is unusable by the customer."
Traditional measurement using EVM, as outlined in the ANSI EIA Standard 748, provides less value to a program compared to an Agile process where the end user continuously verifies that the product meets the requirement. While the EIA 748 guidelines have been required for most large software programs, they have not effectively prevented issues related to cost, schedule, or performance.
The current system focuses on process, not product. Former ASN(RDA) Sean Stackley noted that this focus diverts PMs' attention from the fundamentals of cost, schedule, and performance, contributing significantly to negative acquisition outcomes. This perspective aligns with the views of many stakeholders whom the Section 809 Panel met, and one stakeholder aptly described it as 'mission becoming secondary to perfection of the contract.' Furthermore, adherence to the ANSI EIA Standard 748 and its EIA 748 guidelines is essential to ensure that project management remains aligned with key objectives, rather than getting lost in procedural perfection.
The Commission on Planning, Programming, Budgeting, and Execution Reform Final Report, 2024, includes an assessment of the Department of Defense’s (DoD) use of performance metrics, such as those outlined in the ANSI EIA Standard 748. These EIA 748 guidelines indicate that the metrics provide information solely on the pace of spending, rather than on the actual value received. Furthermore, while Earned Value Management (EVM) systems claim to evaluate expenditures against established delivery benchmarks according to the EIA 748 guidelines, they have faced longstanding criticism for being easily manipulated and inadequate for their intended purpose.
In September 2009, the DoD submitted the Defense Support Team EVM Report to Congress, titled 'DoD EVM Performance, Oversight, and Governance.' Excerpts from the report indicate that the utility of EVM, particularly in relation to the ANSI EIA Standard 748, has declined to a level where it no longer serves its intended purpose. Contractors may circumvent proper EIA 748 guidelines to maintain favorable EVM metrics and keep problems hidden. The end result is that many defense contractors struggle to accurately predict outcomes.
Programs could report 100 percent of earned value according to the ANSI EIA Standard 748, even when behind schedule in validating requirements, completing the preliminary design, meeting weight targets, or delivering software releases that meet the EIA 748 guidelines. The Program Manager should ensure that the Earned Value Management (EVM) process measures the quality and technical maturity of technical work products, rather than just the quantity of work performed. The EIA 748 guidelines dictate that the EV process is only reliable and accurate if systems engineering products are costed and included in the EVM.
Note: Download the corresponding PDF files from the Downloads section below to understand the ANSI EIA Standard 748 and the EIA 748 guidelines.
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