Letters to Trump Transition Team and Director, OMB Letters may be downloaded from Downloads section below.
Contractors often exploit permissive EVMS guidelines and submit monthly contract performance reports (CPR) that overstate cost and schedule performance and understate the estimated completion costs and schedule. The CPRs often fail to provide an early warning of pending funding shortfalls and delays to providing working weapons to the warfighters. EVMS, as currently regulated and practiced, enables government waste and includes gimmicks.
Ambiguities and omissions in guidelines allow contractors to report progress that is based on flawed, misleading metrics. Compliance and oversight costs can be eliminated. Finally, a contractor may be EVMS-compliant yet fail to report situational awareness of cost, schedule, and technical performance and provide early warning of program problems and risk. Commission on PBBE Final Report: EVM systems have long been criticized as easily manipulated and inadequate to the task.
”The Navy’s system of keeping metrics and reporting facts is murky and flawed at best-misleading at worst.” You led a “frank conversation about the Navy’s PM failures, flawed use of metrics, and lack of transparency.”…your assessment of the Navy’s flawed metrics and lack of transparency is systemic in DoD. One root cause is the DFARS EVMS clause.
Letters may be downloaded from Downloads section below.
The deficiency enables a contractor to be compliant with the EVMS guidelines yet fail to report valid performance towards meeting a program’s cost, schedule, and technical objectives. EVMS does not provide sufficient guidance to link reported earned value with progress towards meeting the quality or technical performance requirements of the customer (Quality Gap). Instead, EVMS waives a requirement to link EV to technical performance.
Letters may be downloaded from Downloads section below.
Replace the current Voluntary Consensus Standard (VCS) for EVMS with the new VCS from the Project Management Institute (PMI. he PMI EVM Standard should be used in concert with A Guide to the Project Management Body of Knowledge, (PMBOK® Guide). EIA-748 does not meet either of the VCS criteria that it be both effective and not “impractical.”
EIA-748 is a mid-20th Century relic which is ineffective and impractical. It is recommended that the Capital Programming Guide and federal regulations be updated to cite the PMI documents. Finally, the PMI documents should also be used as a source to develop P/PM training.
(1) Adopt the Voluntary Consensus Standards 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.
Letters may be downloaded from Downloads section below.
PMA, CAP Goal 11: complex acquisition rules that reward compliance over creativity and results. Replace EIA-748 in the Capital Programming Guide with ANSI/PMI 19-006-2019 in concert with PMBOK® Guide.
SAE International, has policies and procedures which specify that a standard include specific performance requirements for quality and broadly accepted engineering practices or specifications. EIA-748E does not meet those criteria. Additional justification and detailed recommendations with an implementation plan are in the white paper, EVM: “When you come to a fork in the road….”
Pres. Trump has not met his commitments, in 2016, to: 1. Apply his business techniques to defense programs and to complete projects “under budget and ahead of schedule.” 2. Accomplish savings through common sense reforms that eliminate government waste. Consult with Dep. Sec. Feinberg to ensure closure of unfinished business from 2016 and to incorporate the modernization recommendations such as integrating digital engineering and program management.
Request that SAE Int. cancel the EIA-748D EVMS Standard it is “not fit for use.” It does not meet the criteria of OMB Circular A-119. EIA-748 does not contain specific performance requirements that are required by SAE for a standard that is used for: (1) design standards, (3) minimum performance standards, (4) quality (5) other areas conforming to broadly accepted engineering practices or specifications for a material, product, process, procedure.
We use cookies to analyze website traffic and optimize your website experience. By accepting our use of cookies, your data will be aggregated with all other user data.