Letters may be downloaded from Downloads section below.
Acquisition managers cannot be assured that a contractor’s performance metrics are valid or accurate. Neither the GAO nor other agencies ever validated that EVMS truly integrates cost, schedule and quality/technical performance or that it provides accurate status and Estimate at Completion. Transform EVM into a more valuable tool...provide early warning of performance problems on a consistent basis. Contractors may circumvent EVM practices to keep EVM metrics favorable and problems hidden.
Letters may be downloaded from Downloads section below.
NDIA SAE/EIA-748 standard has loopholes and deficiencies that enable contractors to submit flawed, inaccurate data to the military. Even if a DCMA compliance review determines that a contractor is compliant with the guidelines, the loopholes enable a contractor to overstate progress and understate final costs.
Letters may be downloaded from Downloads section below.
GAO report, GAO-20-44 Improving Program Management, dated December 2019, corroborates my assertion that PMI documents are consistent with widely accepted standards for program and project management (P/PM) planning and delivery.
o PMI documents are widely accepted standards for P/PM
o Utilized worldwide
o Generally recognized as leading practices for P/PM
o Approved by the American National Standards Institute (ANSI).
EIA-748 no longer a Voluntary Consensus Standard per OMB criteria.
DOD can develop acquisition processes and regulatory or contract requirements that should be applied both to Agile and traditional (aka “waterfall”) methods. 4. Be applicable to software development and to the complete weapon system.
USC requires OMB to “Adopt governmentwide standards, policies, and guidelines for Program/Project Management...that are ‘‘consistent with widely accepted standards.’’ H.R. 6395 would amend that section,by striking ‘‘consistent with widely accepted standards’’ and inserting ‘‘in accordance with standards accredited by the American National Standards Institute (ANSI).’’
We also reward contractors for process, not for results, on cost plus award fee contracts that require the use of EVM....However, DoD uses subjective award fee criteria that have nothing to do with excellent cost, schedule, or technical performance or with making real progress towards completing “a freaking product at the end of the day.”
If the EVMS clause is retained, please enact legislation to require that the reported earned value be based on real-time and iterative data collection, management, analysis, and feedback loops from the digital test and evaluation environment, not on the manipulated, estimated quantity of work performed.
S. 2296, SEC. 823. EXEMPTIONS FOR NONTRADITIONAL DEFENSE CONTRACTORS, exempts those contractors from the DFARS EVM System clause. Now, please introduce legislation, during conference with the SASC, to also exempt traditional defense contractors from the Defense Federal Acquisition Regulation Supplement 252.234–7002 requirement.
Revive a bill that was proposed by former Rep. Jackie Speier in the Chairman’s Mark, En Bloc #1, of the NDAA for FY 2022.
(also, to SASC Chairman Roger Wicker) my recommendations to eliminate barriers to entry and to institutionalize digital engineering (DE) are in the current legislation. As a result, DOD will have improved knowledge of the technical maturity of new technologies and remaining risks before entering major capability acquisitions. By that time, SAEs will use DE and data driven analysis without the distraction of manipulated EVM data.
Please amend the NDAA during joint conference to apply the following component of that provision, as augmented with “Minimum Viable Products,” to all major capability acquisitions. overcome the lack of outcome-based metrics and the absence of the product scope in the EVMS standard, SAE/EIA-748.
(also to Wicker) Shortcomings of the NDAA: The NDAA that was signed did eliminate barriers to entry but failed to institutionalize digital engineering or to eliminate the statute that requires the DFARS EVMS clause for traditional contractors. Your objectives would be achieved more quickly and at less cost if a common set of reference architectures, standards, and best practices of the use of DE tools, as well as the DE tools themselves, be selected and institutionalized in DOD.
Letters may be downloaded from Downloads section below.
...addresses the provision in HR 3838 that each service acquisition executive use data-driven analysis “to manage trade-offs among life-cycle costs, delivery schedules, performance objectives, technical feasibility, and procurement quantity objectives to ensure acquisition and sustainment programs deliver the best value.” A contractor, whether traditional or nontraditional, should self-certify such accordance without the burden of compliance reviews.
I have been dealing with your committee since March 2010. The traditional contractors and NDIA have, once again, obstructed progress. Please present probing questions to the witnesses at the hearing on Wednesday and ensure that they answer them candidly and unambiguously.
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.
Letters may be downloaded from Downloads section below.
increase your oversight of Lockheed Martin’s (LM) digital engineering (DE) improvements and use of outcome-based metrics. oversight actions to include all DE Capability Elements in the requirements for certification on improvements. The four DE Capability Elements are: 1. DE ecosystem. 2. Digital models (Including digital twins). 3. Digital threads. 4. Digital artifacts.
the proposed certification of the F-35 digital twin models is a band aid, not a cure. Please limit procurements until you get a DE ecosystem and outcome-based metrics. Don’t let the program managers off the hook and settle for digital twins. Get certification of a DE ecosystem with outcome-based metrics.
previous letters recommended oversight and legislation regarding the use of DE and outcome-based metrics on the F-35 Block 4 subprogram and the Sentinel program. Provide the same oversight of the Collaborative Combat Aircraft Increment 1 Program (CCA). This request complements my letter to Dr. Meink, Subj: Use of DE on CCA Program, dated 1/1/26.
Since 2021, I recommended oversight and legislation regarding DE and outcome-based metrics on the F-35 Block 4, LGM-35A Sentinel, and CCA programs. Ask questions to determine if:
1. All DE capability elements are integrated.
2. Outcome-based metrics are being used to manage the program.
3. There is a digital thread between those metrics, the digital models, and the digital artifacts.
4. “Botched metrics” are still used (especially, EVMS metrics). Ask the CCA questions during Sentinel oversig
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