The current standard is EIA-748D, published in January 2019. The NDIA Integrated Program Management Div. submitted a draft revision, EIA-748E, for balloting and approval by SAE International, the voluntary consensus body. Paul Solomon submitted a procedural complaint to the SAE Systems Management Council (SMC), alleging that EIA-748E is a business standard, not an engineering standard, and that it is not within the scope of the SAE G-27 Systems Engineering Committee's charter, per the rules of the SMC.
Shortcomings of EIA-748 EVMS Standard, which make it "not fit for use," are in the white paper, "Outcome-Based Metrics Plus SE" = Integrated Program Management and in the section below. Engineering best practices are in the white paper Integrating the Embedded Software Path, Model-Based Systems Engineering, MOSA, and Digital Engineering (DE) with Program Management.
EIA-748D, published in January 2019 must be revised or reaffirmed every five years. The NDIA Integrated Program Management Div. 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), alleging that, because EIA-748E is a business standard not an engineering standard, it is not within the scope of the SAE G-47 Systems Engineer Committee's charter.
Additional information is in the following letters to Dept. of War and OMB officials and the white papers cited therein.
not an engineering standard. is a business standard, outside of the scope and technology area of the G-47 SE Committee. not a best practice on the engineering of (4) quality, and (5) other areas conforming to broadly accepted engineering practices or specifications for a product, process, procedure, or test method. systems. not within the scope of SAE International’s policies or of the SMC Org. and Operating Procedures.
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, SAE/EIA-748, and replace it with Project Management Institute (PMI) standards and guides. The GAO provided justification to utilize PMI documents.
Gen. Thompson committed to develop and deliver a DE ecosystem that enables the Space Force to rapidly mature innovative concepts into integrated solutions and deliver warfighting capabilities faster. Please consider my advice for the Space Force’s success.
The continued use of EIA-748, which is silent on engineering practices, DE, and the product scope, is antithetical to the effective use of DE and to attaining the schedule and cost benefits of the DE ecosystem.
best practices that should be added to the revised documents include:
· The product baseline and the Minimum Viable Product (MVP) and Minimum Viable Capability Release (MVCR) baselines.
· collection of DE metrics of schedule progress and quality towards the MVP and MVCR.
· Automated requirements traceability to completion criteria in the schedule.
· Measures used to track progress towards completing MVPs and MVCRs in the digital thread.
Request that SAE Int. cancel the EIA-748D EVMS Standard because it is “not fit for use."
Letters since September 3 are posted on my website. They include engineering best practices that should be in a system engineering or project management standard.
Neither version of the NDAA for FY 2026 includes an acquisition reform first recommended to Ike Skelton in 2010. He marked up the NDAA for FY 2011 to add a provision on EVMS. Please address EVMS in conference with the SASC along with other acquisition reforms that are in my letter to Dep. Sec. of War Feinberg dated 10/24, subj: Additional Engineering Best Practices Absent from the EIA-748 EVM. Also, coordinate with OMB Director Vought to fix outdated OMB policy.
Prioritized menu of actions to obtain the benefits of a digital engineering ecosystem ASAP.
Eliminate a corrupt business process that is overly complicated, overregulated and overdue for reform, EVMS. Influence the SAE Council ballot by informing it that you agree with me. Inform Dep. Sec. Feinberg and OMB Director Vought that EIA-748 is unfit for use.
(ASW(MC)) James Caggy affirmed that he will leverage SE and DE practices and rigorous foundational engineering activities early in the capability life cycle leads to improved cost, schedule, and performance results. Take action on my procedural appeal to SAE International, the accrediting organization for the draft EIA/748E.
Two issues require your attention.
1. Initiate process to terminate DFARS Earned Value Management System (EVMS) clause.
2. Obtain benefits of digital engineering (DE) ecosystem ASAP.
Remove an obstacle to institutionalizing “going digital including program management,” a goal that was established by Gen. Duke Richardson and myself when he was with SAF/AQ in 2022.
A non-value-added layer of bureaucracy that should be eliminated is the DCMA org. that reviews compliance with the earned value management system (EVMS) business process per the EVMS standard, EIA-748.
Elimination of 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 in my letter to PTDO OUSD(A&S) Morani, Subj: Further Reduction in Scope of DCMA EVMS Compliance Reviews – Surveillance, dated March 18, 2025.
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, leverage authoritative data sources, and automated reporting, and outcome focused metrics.
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 is that it does not measure product quality. A program could perform ahead of schedule and under cost according to EVM metrics but deliver a capability that is unusable by the customer.
"Traditional measurement using EVM provides less value to a program than an Agile process in which the end user continuously verifies that the product meets the requirement.” “EVM has been required on most large software programs but has not prevented cost, schedule, or performance issues.”
“The current system focuses on process, not product. Former ASN(RDA) Sean Stackley said this focus takes PMs’ attention away from the fundamentals of cost, schedule, and performance, and is one of the major contributors to negative acquisition outcomes. This perspective is shared by many stakeholders with whom the Section 809 Panel met and was aptly described by one stakeholder as “mission becoming secondary to perfection of the contract.”
Commission on Planning, Programming, Budgeting, and Execution Reform Final Report, 2024, Assessment of DoD’s use of performance metrics include: • These metrics provide information only on the pace of spending, not on the value received. • EVM systems purport to assess expenditures against established delivery benchmarks but have long been criticized as easily manipulated and inadequate to the task.
DoD report to Congress. In Sept. 2009, DoD submitted the DoD Defense Support Team EVM Report to Congress: DoD EVM Performance, Oversight, and Governance. excerpts follow: "Utility of EVM has declined to a level where it does not serve its intended purpose...Contractors may circumvent proper EVM practices to keep EVM metrics favorable and problems hidden." End result: Many defense contractors cannot accurately predict outcomes.
Programs could report 100 percent of earned value...even though behind schedule validating requirements, completing the preliminary design, meeting weight targets or delivering software releases that meet the requirements. Program Manager should ensure that the EVM process measures the quality and technical maturity of technical work products instead of just the quantity of work performed. EV process is reliable and accurate only if systems engineering products are costed and included in EVM.
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