CANCELLED BY PN 04-19

06-06

Procurement Information Circular


March 29, 2006

 

INTERIM INSTRUCTIONS FOR IMPLEMENTING EARNED VALUE MANAGEMENT (EVM) ON NASA CONTRACTS

 

PURPOSE:  To provide a class deviation to implement the Earned Value Management (EVM) coverage contained in NASA Interim Directive (NID) NM 7120-40 to NPR 7120.5C, NASA Program and Project Management Processes and Requirements, and the rescission of NPD 9501.3A, Earned Value Management, and NPR 9501.3, Earned Value Management Implementation on NASA Contracts.

 

BACKGROUND:  An NID to NPR 7120.5C has been issued to articulate the new EVM policy.  The NID requirements are in conflict with the previously established EVM and cost performance reporting requirements in NPD 9501.3A and NPR 9501.3.  Accordingly, those latter two documents are being rescinded.

 

GUIDANCE:  The new NASA policy for requiring contractors to implement EVM is as stated in the enclosed class deviation.  Contracting officers shall insert the revised provision at 1852.242-74 and the revised clause at 1852.242-75 in solicitations and contracts in accordance with the instructions in the deviation.

 

EFFECTIVE DATE:  This Procurement Information Circular (PIC) is effective as dated and shall remain in effect until canceled or superseded.  It is planned to be superseded and cancelled when the NFS is revised to reflect the updated NPR 7120.5 requirements and the pending FAR EVM coverage.

 

POINTS OF CONTACTS:  For EVM implementation issues, Jerald Kerby, Deputy Chair, EVM Working Group, (256) 544-3243, email: Jerald.G.Kerby@nasa.gov; for contract issues, Ken Sateriale, Office of Procurement/Contract Management Division, (202) 358-0491, email: ken.sateriale@nasa.gov.

 

 

Tom Luedtke

Assistant Administrator for Procurement

 

Enclosures

 

DISTRIBUTION:

  PIC List



Enclosure 1

 

This PIC provides a class deviation to revise the NFS as indicated below:

 

Subpart 1842.74--Earned Value Management

1842.7401   Earned Value Management Systems (EVMS).
     When an offeror or contractor is required to provide an EVMS plan to the Government in accordance with NASA Policy Directive 
(NPD) 9501.3, Earned Value Management, the contracting officer shall forward a copy of the plan to the cognizant administrative contracting officer (ACO) to obtain the assistance of the ACO in determining the adequacy of the proposed EVMS plan.

[Earned value management system (EVMS) is a project management tool that effectively integrates the project work with cost, schedule and performance elements for optimum project planning and control.  The qualities and operating characteristics of an earned value management system are described in American National Standards Institute (ANSI)/Electronics Industries Alliance (EIA) Standard – 748, Earned Value Management Systems.  (See OMB Circular A-11, Part 7).

 

1842.7402 Applicability of EVMS to NASA contracts.

   (a) EVMS has two different levels of rigor and the contract must specify which level is being required.

(1) The more stringent level requires the contractor to implement its EVMS in accordance with the EVM formal guidelines specified in the ANSI/EIA-748 standard.  Implementation of EVMS at the guidelines level is required for applicable contracts expected to exceed $50M or more.  Application of EVMS at the guidelines level for contracts below $50M is at the discretion of the project manager and would satisfy the requirement of paragraph (a)(2) of this section .

         (2) The more flexible level requires the contractor only to implement its EVMS in accordance with the EVM principles specified in ANSI/EIA-748.  Implementation of EVMS at the principles level is required for applicable contracts over $20M, but not exceeding $50M.  Application of EVMS at the principles level for contracts below $20M is at the discretion of the project manager.

   (b) When EVMS is required, EVM reporting by ccontractorss must submit reports (e.g. Contract Performance Report) must be based on their EVMS that has either been recognized by –

         (1) The cognizant administrative contracting officer (ACO) as compliant with the ANSI/EIA-748 standard; or

         (2) NASA as compliant with ANSI/EIA-748 principles when EVMS is implemented at the principles level.

   (c) If EVMS is being implemented at the guidelines level and the offeror does not have an EVMS that has been recognized by the ACO as compliant with ANSI/EIA-748, the offeror must provide an EVMS implementation plan with its proposal, and the contracting officer shall forward a copy of that plan to the cognizant ACO to obtain assistance in determining its adequacy.

 

1842.7403 Applicability of EVMS to NASA subcontracts.

   When EVMS is applicable to a prime contract, the requirement may must be flowed down to subcontracts according to the same prescriptions for its use at the prime contractor level (see 1842.7404) of the type dollar value described in 1842.7404(a) at the mutual agreement of the project manager and contractor.   The subcontractors and the level of compliance requirement (i.e. guidelines or principles) must be specified in paragraph (f) of the clause at 1852.242-75, Earned Value Management System.]

 {The cross reference to 1842.7404(a) doesn’t capture the types of contacts that are excluded from EVM in the prescription for the provision }

1842.7402   Solicitation provisions and contract clauses.
     (a)  When the Government requires Earned Value Management, the contracting officer shall insert: [--]
           (1a)  The provision at 
1852.242-74, Notice of Earned Value Management System, in solicitations; and
           (2b)  The clause at
1852.242-75, Earned Value Management System, in solicitations and contracts.
     (b)  The contracting officer shall insert the clause at
1852.242-76, Modified Cost Performance Report, in solicitations and contracts requiring modified cost performance reporting (see NPD 9501.3, Earned Value Management).
     (c)  The contracting officer shall insert the provision at
1852.242-77, Modified Cost Performance Report Plans, in solicitations for contracts requiring modified cost performance reporting (see NPD 9501.3).

 

[1842.7404   Solicitation provisions and contract clauses.
   (a)  Except as provided in paragraph (c) of this section, the contracting officer shall insert the provision at 1852.242-74, Notice of Earned Value Management System, in solicitations for
cost-reimbursement and incentive contracts for development or production, including flight and ground support projects, and institutional projects (facility, IT investment, etc.), with a value exceeding $50M.  The contracting officer shall use the clause with its Alternate I when the contract value exceeds $20M but is less than $50M.

   (b)  The contracting officer shall insert the clause at 1852.242-75, Earned Value Management System, in solicitations and contracts with a value exceeding $50M that include the provision at 1852.242-74.  When the contract value exceeds $20M but is less than $50M, the contracting office shall use the clause with its Alternate I.

   (c) EVM provisions and clauses shall not be used on contracts for –

         (1) Engineering support services and routine services such as janitorial services or grounds maintenance services; or

         (2)  Basic and applied research or advanced technology development, unless expressly authorized by the project manager.]

 

1852.242-74 Notice of Earned Value Management System.

   As prescribed in 1842.7402[4] [(a)](a)(1), insert the following provision:

NOTICE OF EARNED VALUE MANAGEMENT SYSTEM
(March 1999 [Deviation])

   (a) The offeror shall provide documentation that the cognizant Administrative Contracting Officer (ACO) has recognized that:

(1) The proposed earned value management system (EVMS) complies with the EVMS criteria of NASA Policy Directive (NPD) 9501.3, Earned Value Management, or DoD 5000.2-R, Mandatory Procedures for Major Defense Acquisition Programs and Major Automated Information Systems Acquisition Programs; or

(2) T[t]he company [Earned Value Management System (EVMS)] system conforms [complies] with [the guidelines in] the full intentions of the guidelines presented in ANSI/EIA Standard 748, Industry Guidelines for Earned Value Management Systems. 

   (b) If the offeror proposes to use a system that [currently] does not meet the requirements of paragraph (a) of this provision, the successful offeror shall submit a plan  for compliance with the NASA EVM[S guidelines, for Contracting Officer approval.] criteria as described in NPD 9501.3. 

         (1) The plan shall --

               (i) Describe the EVMS the offeror intends to use in performance of the contract;

               (ii) Distinguish between the offeror's existing management system and modifications proposed to meet the criteria[guidelines];

               (iii) Describe the management system and its application in terms of the criteria[guidelines];

                (iv) Describe the proposed procedure for administrationof the criteria as applied to subcontractors; and 

               (v) Provide documentation describing the process and results of any third-party or self-evaluation of the system's compliance with EVMS criteria. ;

               [(iv) Provide documentation describing the process and results, including  Government participation, of any third-party or self-evaluation of the system's compliance with EVMS guidelines ; an

               (v) Provide a schedule of events leading up to Government acceptance of the Contractor’s EVMS.  This schedule should include a Progress Assessment Review no later than 30 days after contract award and the formal Compliance Review as soon as practicable  ;

               (vi) Describe the proposed procedure for application of the EVMS requirements to subcontractors; and

               (vii)  Describe how the offeror will ensure EVMS compliance for each subcontractor subject to the flowdown requirement in paragraph (c) whose EVMS has not been recognized by the cognizant ACO as compliant according to paragraph (a).] ]

         (2) The Government will review the offeror's plan for EVMS [implementation] before contract award. The offeror shall provide information and assistance as required by the Contracting Officer to support review of the plan.

   (c) prescription for its application at NFS 4The [o]Offerors shall identify in [its] their proposals the major subcontractors, or major subcontracted efforts if major subcontractors have not been selected, planned for application of EVMS.  The prime contractor and the Government shall agree to subcontractors selected for application of EVMS and the level of implementation.

{I’m confused by the rewrite of this paragraph (c).  In the first sentence, you reference the threshold in 7402(a).  There are two thresholds in this paragraph - $20M and $50M.  Also, this cross reference doesn’t capture the types of contacts that are excluded from EVM in the prescription for the provision.  I’m not sure what the first half of the 3rd sentence is saying.  Ensuring compliance is a contractual obligation and shouldn’t be referenced in a provision. Are you trying to say that the offeror needs to get assurance from the sub that it’s EVMS has been recognized by the ACO, or submit a plan for doing so?  Is the second half of the 3rd sentence saying that the subs plan for getting ACO recognition needs to be incorporated into the plan submitted by the offeror?}   

(c)  [The EVMS requirement shall be flowed down to subcontracts in accordance with the criteria in NFS 1842.7403.]  Offerors [The offeror] shall identify in their proposals [its offer] the subcontractors, or major subcontracted effort if major subcontractors have not been selected, planned for application of [subject to the] EVMS [requirement].  The prime contractor and the Government shall agree to subcontractors selected for application of EVMS  [Before contract award, the offeror and NASA will agree on the subcontractors subject to the EVMS requirement and the level of compliance (i.e., guidelines or principles)].      

(End of provision)

 

[Alternate I (Deviation)

   As prescribed in 1842.7404(a), substitute the following paragraph (b) for paragraph (b) of the basic provision:

            (b)(1) If the offeror proposes to use a system that does not meet the requirements of paragraph (a) of this provision, the offeror shall submit a plan for Contracting Officer approval demonstrating how the company EVMS complies with the following principles specified in ANSI/EIA Standard 748:

                        (i) Plan all work for the project to completion. 

                        (ii) Break down the project work into finite pieces that can be assigned to a responsible person or organization for control of technical, schedule, and cost objectives.  

                        (iii) Integrate project work, schedule, and cost objectives into a performance measurement baseline plan against which accomplishments may be measured, and control changes to the baseline.

                        (iv) Use actual costs incurred and recorded in accomplishing the work performed.

                        (v) Objectively assess accomplishments at the work performance level.

                        (vi) Analyze significant variances from the plan, forecast impacts, and prepare an estimate at completion based on performance to date and work to be performed.

                        (vii) Incorporate Earned Value Management into the project’s decision-making and review processes.

    (2) The plan shall –

                        (i) Describe the EVMS the offeror intends to use in performance of the contract;

                        (ii) Distinguish between the offeror's existing management system and modifications proposed to meet the principles;

                        (iii) Describe the management system and its application in terms of the principles;

                        (iv) Describe the proposed procedure for administration of the principles as applied to subcontractors; and

                        (v) Provide documentation describing the process and results, including any Government participation, of any third-party or self-evaluation of the system's compliance with EVMS principles.

  (3) NASA will review the offeror's plan before contract award. The offeror shall provide information and assistance as required by the Contracting Officer to support review of the plan.]

 

1852.242-75 Earned Value Management Systems.

   As prescribed at 1842.7402[4(b)]   (a)(2), insert the following clause:

EARNED VALUE MANAGEMENT SYSTEM
(MARCH 1999) [(Deviation)]

   (a) In the performance of this contract, the Contractor shall use: [--]

(1) A[a]n earned value management system (EVMS) that has been recognized by the cognizant Administrative Contracting Officer (ACO) as complying with the [guidelines specified in] criteria provided in NASA Policy Directive 9501.3, Earned Value Management, or DoD 5000.2-R, Mandatory Procedures for Major Defense Acquisition Programs and Major Automated Information Systems Acquisition Programs; or

(2) A company EVMS that the ACO has recognized as conforming with the full intentions of the guidelines presented in ANSI/EIA Standard 748, Industry Guidelines for Earned Value Management Systems.

(b) If, at the time of award, the Contractor's EVMS has not been recognized by the cognizant ACO per paragraph (a) of this clause as or the Contractor does not have an existing cost schedule control system (C/SCS) that has been accepted by the Government, the Contractor shall apply the Contractor's EVMS to the contract and be prepared to demonstrate to the ACO that its system complies with the EVMS criteria referenced in paragraph (a) of this clause.

   [(b) If, at the time of award, the Contractor's EVMS has not been recognized by the ACO as complying with the EVMS guidelines, the Contractor shall apply the system to the contract and shall take timely action to implement its plan to obtain compliance.  The Contractor shall follow and implement the approved compliance plan in a timely fashion.  The Government will conduct a Compliance Review to assess the contactor’s compliance with its plan, and if the Contractor does not follow the approved implementation schedule or correct all resulting system deficiencies identified as a result of the compliance review within a reasonable time, the Contracting Officer may take remedial action, that may include, but is not limited to, a reduction in fee.]

   (c) The Government may [will] review quire [require] integrated baseline reviews. Such reviews shall be scheduled as early as practicable and should be conducted within 180 calendar days after contract award, [or] exercise of significant contract options, [;] or [within two months after distribution of a supplemental agreement that implemented a significant funding realignment or effected a significant change in contract requirements.] incorporation of major contract modifications. The objective of the integrated baseline review is for the Government and the Contractor to jointly assess areas, such as the Contractor's planning, to ensure complete coverage of the statement of work, logical scheduling of the work activities, adequate resourcing, and identification of inherent risks.  [The objective of IBRs is for the Government and the Contractor to jointly assess the Contractor's baseline to be used for performance measurement to ensure complete coverage of the statement of work, logical scheduling of the work activities, adequate resourcing, and identification of inherent risks.]

   (d) Unless a waiver is granted by the ACO, Contractor proposed EVMS changes require approval of the ACO prior to implementation. The ACO shall advise the Contractor of the acceptability of such changes within 30 calendar days after receipt of the notice of proposed changes from the Contractor. If the advance approval requirements are waived by the ACO, the Contractor shall disclose EVMS changes to the ACO and provide an information copy to the NASA Contracting Officer at least 14 calendar days prior to the effective date of implementation.

   (e) The Contractor agrees to provide access to all pertinent records and data requested by the ACO or a duly authorized representative. Access is to permit Government surveillance to ensure that the EVMS complies, and continues to comply, with the criteria referenced in paragraph (a) of this clause.

   (f) The Contractor shall [be responsible for ensuring that] require the subcontractors specified [identified] below to comply with the [EVMS requirements at the specified level.  If the subcontractor does not have an EVMS that has been recognized by the ACO as compliant with ANSI/EIA 748, the prime contractor shall conduct Compliance Reviews of subcontractors’ EVMS in the same manner as described at paragraph (b) of this clause.] specified of this clause: (Insert list of applicable subcontractors [and the level of compliance (i.e., guidelines or principles)])

   [(g) If the contractor identifies a need to deviate from the agreed baseline by working against an Over Target Baseline or Over Target Schedule, the contractor shall submit to the Contracting Officer a request for approval to begin implementation of an Over Target Baseline or Over Target Schedule.  This request shall include a top-level projection of cost and/or schedule growth, whether or not performance variances will be retained, and a schedule of implementation for the rebaselining.  The Government will authorize or deny the request within 30 calendar days after receipt of the request.  Failure of the Government to respond within this 30-day period constitutes approval of the request.  For cost-reimbursement contracts, the contract budget baseline shall exclude changes for cost growth increases, other than for authorized changes to the contract requirements.]

(End of clause)

 

[Alternate I (Deviation)

  As prescribed in 1842.7404(b), substitute the following paragraph (a) for paragraph (a) of the basic clause:

            (a) In the performance of this contract, the Contractor shall use an earned value management system (EVMS) that has been recognized by the cognizant ACO as complying with the guidelines of ANSI/EIA-748, Industry Guidelines for Earned Value Management Systems, or by NASA as complying with the principles specified in ANSI/EIA Standard 748.  In applying EVM to this contract, the contractor need only comply with the following principles as opposed to complying with the ANSI/EIA 748 guidelines:

(1) Plan all work for the project to completion.

                        (2) Break down the project work into finite pieces that can be assigned to a responsible person or organization for control of technical, schedule, and cost objectives.

                        (3) Integrate project work, schedule, and cost objectives into a performance measurement baseline plan against which accomplishments may be measured, and control changes to the baseline.

                        (4) Use actual costs incurred and recorded in accomplishing the work performed.

                        (5) Objectively assess accomplishments at the work performance level.

                        (6) Analyze significant variances from the plan, forecast impacts, and prepare an estimate at completion based on performance to date and work to be performed.

                        (7) Incorporate Earned Value Management into the project’s decision-making and review processes.]

 

1852.242-76 Modified Cost Performance Report.

As prescribed in 1842.7402(b), insert the following clause:

MODIFIED COST PERFORMANCE REPORT
(MARCH 1999)

(a) The Contractor shall use management procedures in the performance of this contract that provide for:

(1) Planning and control of costs;

(2) Measurement of performance (value for completed tasks); and

(3) Generation of timely and reliable information for the Modified Cost Performance Report (M/CPR).

(b) As a minimum, these procedures must provide for:

(1) Establishing the time-phase budgeted cost of work scheduled (including work authorization, budgeting, and scheduling), the budgeted cost for work performed, the actual cost of work performed, the budget at completion, the estimate at completion, and provisions for subcontractor performance measurement and reporting;

(2) Applying all direct and indirect costs and provisions for use and control of management reserve and undistributed budget;

(3) Incorporating changes to the contract budget base for both Government directed changes and internal replanning;

(4) Establishing constraints to preclude subjective adjustment of data to ensure performance measurement remains realistic. The total allocated budget may exceed the contract budget base only after consultation with the Contracting Officer. For cost-reimbursement contracts, the contract budget base shall exclude changes for cost growth increases, other than for authorized changes to the contract scope; and

(5) Establishing the capability to accurately identify and explain significant cost and schedule variances, both on a cumulative basis and a projected-at-completion basis.

(c) The Contractor may use a cost/schedule control system that has been recognized by the cognizant Administrative Contracting Officer (ACO) as:

(1) Complying with the earned value management system criteria provided in NASA Policy Directive 9501.3, Earned Value Management, or DoD 5000.2-R, Mandatory Procedures for Major Defense Acquisition Programs and Major Automated Information Systems Acquisition Programs; or

(2) Conforming with the full intentions of the guidelines presented in ANSI/EIA Standard 748, Industry Guidelines for Earned Value Management Systems.

(d) The Government may require integrated baseline reviews. Such reviews shall be scheduled as early as practicable and should be conducted within 180 calendar days after contract award, exercise of significant contract options, or incorporation of major modifications. The objective of the integrated baseline review is for the Government and the Contractor to jointly assess areas, such as the Contractor's planning, to ensure complete coverage of the statement of work, logical scheduling of the work activities, adequate resourcing, and identification of inherent risks.

(e) The Contractor shall provide access to all pertinent records, company procedures, and data requested by the ACO, or authorized representative, to:

(1) Show proper implementation of the procedures generating the cost and schedule information being used to satisfy the M/CPR contractual data requirements to the Government; and

(2) Ensure continuing application of the accepted company procedures in satisfying the M/CPR data item.

(f) The Contractor shall submit any substantive changes to the procedures and their impact to the ACO for review.

(g) The Contractor shall require a subcontractor to furnish M/CPR in each case where the subcontract is other than firm-fixed-price, time-and-materials, or labor-hour; is 12 months or more in duration; and has critical or significant tasks related to the prime contract. Critical or significant tasks shall be defined by mutual agreement between the Government and Contractor. Each subcontractor's reported cost and schedule information shall be incorporated into the Contractor's M/CPR.

(End of clause)

1852.242-77 Modified Cost Performance Report Plans.

As prescribed in 1842.7402(c), insert the following provision;

MODIFIED COST PERFORMANCE PLANS
(MARCH 1999)

(a) The offeror shall submit in its proposal a written summary of the management procedures it will establish, maintain, and use in the performance of any resultant contract to comply with the requirements of the clause at 1852.242-76, Modified Cost Performance Report.

(b) The offeror may propose to use a cost/schedule control system that has been recognized by the cognizant Administrative Contracting Officer as:

(1) Complying with the earned value management system criteria of NASA Policy Directive 9501.3, Earned Value Management, or DoD 5000.2-R, Mandatory Procedures for Major Defense Acquisition Programs and Major Automated Information Systems Acquisition Programs; or

(2) Conforming with the full intentions of the guidelines presented in ANSI/EIA Standard 748, Industry Guidelines for Earned Value Management Systems.

In such cases, the offeror may submit a copy of the documentation of such recognition instead of the written summary required by paragraph (a) of this provision.

(End of provision)

1852.242-76 Modified Cost Performance Report.

As prescribed in 1842.7402(b), insert the following clause:

MODIFIED COST PERFORMANCE REPORT
(MARCH 1999)

(a) The Contractor shall use management procedures in the performance of this contract that provide for:

(1) Planning and control of costs;

(2) Measurement of performance (value for completed tasks); and

(3) Generation of timely and reliable information for the Modified Cost Performance Report (M/CPR).

(b) As a minimum, these procedures must provide for:

(1) Establishing the time-phase budgeted cost of work scheduled (including work authorization, budgeting, and scheduling), the budgeted cost for work performed, the actual cost of work performed, the budget at completion, the estimate at completion, and provisions for subcontractor performance measurement and reporting;

(2) Applying all direct and indirect costs and provisions for use and control of management reserve and undistributed budget;

(3) Incorporating changes to the contract budget base for both Government directed changes and internal replanning;

(4) Establishing constraints to preclude subjective adjustment of data to ensure performance measurement remains realistic. The total allocated budget may exceed the contract budget base only after consultation with the Contracting Officer. For cost-reimbursement contracts, the contract budget base shall exclude changes for cost growth increases, other than for authorized changes to the contract scope; and

(5) Establishing the capability to accurately identify and explain significant cost and schedule variances, both on a cumulative basis and a projected-at-completion basis.

(c) The Contractor may use a cost/schedule control system that has been recognized by the cognizant Administrative Contracting Officer (ACO) as:

(1) Complying with the earned value management system criteria provided in NASA Policy Directive 9501.3, Earned Value Management, or DoD 5000.2-R, Mandatory Procedures for Major Defense Acquisition Programs and Major Automated Information Systems Acquisition Programs; or


(2) Conforming with the full intentions of the guidelines presented in ANSI/ANSI/EIA Standard 748, Industry Guidelines for Earned Value Management Systems.

(d) The Government may require integrated baseline reviews. Such reviews shall be scheduled as early as practicable and should be conducted within 180 calendar days after contract award, exercise of significant contract options, or incorporation of major modifications. The objective of the integrated baseline review is for the Government and the Contractor to jointly assess areas, such as the Contractor's planning, to ensure complete coverage of the statement of work, logical scheduling of the work activities, adequate resourcing, and identification of inherent risks.

(e) The Contractor shall provide access to all pertinent records, company procedures, and data requested by the ACO, or authorized representative, to:

(1) Show proper implementation of the procedures generating the cost and schedule information being used to satisfy the M/CPR contractual data requirements to the Government; and

(2) Ensure continuing application of the accepted company procedures in satisfying the M/CPR data item.

(f) The Contractor shall submit any substantive changes to the procedures and their impact to the ACO for review.

(g) The Contractor shall require a subcontractor to furnish M/CPR in each case where the subcontract is other than firm-fixed-price, time-and-materials, or labor-hour; is 12 months or more in duration; and has critical or significant tasks related to the prime contract. Critical or significant tasks shall be defined by mutual agreement between the Government and Contractor. Each subcontractor's reported cost and schedule information shall be incorporated into the Contractor's M/CPR.

(End of clause)

1852.242-77 Modified Cost Performance Report Plans.

As prescribed in 1842.7402(c), insert the following provision;

MODIFIED COST PERFORMANCE PLANS
(MARCH 1999)

(a) The offeror shall submit in its proposal a written summary of the management procedures it will establish, maintain, and use in the performance of any resultant contract to comply with the requirements of the clause at 1852.242-76, Modified Cost Performance Report.

(b) The offeror may propose to use a cost/schedule control system that has been recognized by the cognizant Administrative Contracting Officer as:

(1) Complying with the earned value management system criteria of NASA Policy Directive 9501.3, Earned Value Management, or DoD 5000.2-R, Mandatory Procedures for Major Defense Acquisition Programs and Major Automated Information Systems Acquisition Programs; or

(2) Conforming with the full intentions of the guidelines presented in ANSI/ANSI/EIA Standard 748, Industry Guidelines for Earned Value Management Systems.

In such cases, the offeror may submit a copy of the documentation of such recognition instead of the written summary required by paragraph (a) of this provision.

(End of provision)


Enclsoure 2 - Clean Version of Clauses

 

1852.242-74 Notice of Earned Value Management System.

   As prescribed in 1842.7404(a), insert the following provision:

NOTICE OF EARNED VALUE MANAGEMENT SYSTEM
(March 1999 [Deviation])

            (a) The offeror shall provide documentation that the cognizant Administrative Contracting Officer (ACO) has recognized that the company Earned Value Management System (EVMS) complies with the guidelines in ANSI/EIA Standard 748, Industry Guidelines for Earned Value Management Systems.      

   (b) If the offeror proposes to use a system that currently does not meet the requirements of paragraph (a) of this provision, the offeror shall submit a plan  for compliance with the EVMS guidelines, for Contracting Officer approval. 

         (1) The plan shall --

               (i) Describe the EVMS the offeror intends to use in performance of the contract;

               (ii) Distinguish between the offeror's existing management system and modifications proposed to meet the guidelines;

               (iii) Describe the management system and its application in terms of the guidelines;

               (iv) Provide documentation describing the process and results, including Government participation, of any third-party or self-evaluation of the system's compliance with EVMS guidelines ; an

               (v) Provide a schedule of events leading up to Government acceptance of the Contractor’s EVMS.  This schedule should include a Progress Assessment Review no later than 30 days after contract award and the formal Compliance Review as soon as practicable  ;

               (vi) Describe the proposed procedure for application of the EVMS requirements to subcontractors; and

               (vii)  Describe how the offeror will ensure EVMS compliance for each subcontractor subject to the flowdown requirement in paragraph (c) whose EVMS has not been recognized by the cognizant ACO as compliant according to paragraph (a). ]

         (2) The Government will review the offeror's plan for EVMS implementation before contract award. The offeror shall provide information and assistance as required by the Contracting Officer to support review of the plan.

   (c) prescription for its application at NFS 4The [o]Offerors shall identify in [its] their proposals the major subcontractors, or major subcontracted efforts if major subcontractors have not been selected, planned for application of EVMS.  The prime contractor and the Government shall agree to subcontractors selected for application of EVMS and the level of implementation.

{I’m confused by the rewrite of this paragraph (c).  In the first sentence, you reference the threshold in 7402(a).  There are two thresholds in this paragraph - $20M and $50M.  Also, this cross reference doesn’t capture the types of contacts that are excluded from EVM in the prescription for the provision.  I’m not sure what the first half of the 3rd sentence is saying.  Ensuring compliance is a contractual obligation and shouldn’t be referenced in a provision. Are you trying to say that the offeror needs to get assurance from the sub that it’s EVMS has been recognized by the ACO, or submit a plan for doing so?  Is the second half of the 3rd sentence saying that the subs plan for getting ACO recognition needs to be incorporated into the plan submitted by the offeror?}   

(c)  The EVMS requirement shall be flowed down to subcontracts in accordance with the criteria in NFS 1842.7403.  The offeror shall identify in its offer the subcontractors, or major subcontracted effort if major subcontractors have not been selected, subject to the EVMS requirement.  Before contract award, the offeror and NASA will agree on the subcontractors subject to the EVMS requirement and the level of compliance (i.e., guidelines or principles).      

(End of provision)

 

Alternate I (Deviation)

   As prescribed in 1842.7404(a), substitute the following paragraph (b) for paragraph (b) of the basic provision:

            (b)(1) If the offeror proposes to use a system that does not meet the requirements of paragraph (a) of this provision, the offeror shall submit a plan for Contracting Officer approval demonstrating how the company EVMS complies with the following principles specified in ANSI/EIA Standard 748:

                        (i) Plan all work for the project to completion. 

                        (ii) Break down the project work into finite pieces that can be assigned to a responsible person or organization for control of technical, schedule, and cost objectives.  

                        (iii) Integrate project work, schedule, and cost objectives into a performance measurement baseline plan against which accomplishments may be measured, and control changes to the baseline.

                        (iv) Use actual costs incurred and recorded in accomplishing the work performed.

                        (v) Objectively assess accomplishments at the work performance level.

                        (vi) Analyze significant variances from the plan, forecast impacts, and prepare an estimate at completion based on performance to date and work to be performed.

                        (vii) Incorporate Earned Value Management into the project’s decision-making and review processes.

    (2) The plan shall –

                        (i) Describe the EVMS the offeror intends to use in performance of the contract;

                        (ii) Distinguish between the offeror's existing management system and modifications proposed to meet the principles;

                        (iii) Describe the management system and its application in terms of the principles;

                        (iv) Describe the proposed procedure for administration of the principles as applied to subcontractors; and

                        (v) Provide documentation describing the process and results, including any Government participation, of any third-party or self-evaluation of the system's compliance with EVMS principles.

  (3) NASA will review the offeror's plan before contract award. The offeror shall provide information and assistance as required by the Contracting Officer to support review of the plan.

 

1852.242-75 Earned Value Management Systems.

   As prescribed at 1842.7404(b), insert the following clause:

EARNED VALUE MANAGEMENT SYSTEM
(MARCH 1999) [(Deviation)]

  (a) In the performance of this contract, the Contractor shall use an earned value management system (EVMS) that has been recognized by the cognizant Administrative Contracting Officer (ACO) as complying with the guidelines specified in ANSI/EIA Standard 748, Industry Guidelines for Earned Value Management Systems.

   (b) If, at the time of award, the Contractor's EVMS has not been recognized by the ACO as complying with the EVMS guidelines, the Contractor shall apply the system to the contract and shall take timely action to implement its plan to obtain compliance.  The Contractor shall follow and implement the approved compliance plan in a timely fashion.  The Government will conduct a Compliance Review to assess the contactor’s compliance with its plan, and if the Contractor does not follow the approved implementation schedule or correct all resulting system deficiencies identified as a result of the compliance review within a reasonable time, the Contracting Officer may take remedial action, that may include, but is not limited to, a reduction in fee.

   (c) The Government will require integrated baseline reviews. Such reviews shall be scheduled as early as practicable and should be conducted within 180 calendar days after contract award or exercise of significant contract options; or within two months after distribution of a supplemental agreement that implemented a significant funding realignment or effected a significant change in contract requirements.  The objective of IBRs is for the Government and the Contractor to jointly assess the Contractor's baseline to be used for performance measurement to ensure complete coverage of the statement of work, logical scheduling of the work activities, adequate resourcing, and identification of inherent risks.

   (d) Unless a waiver is granted by the ACO, Contractor proposed EVMS changes require approval of the ACO prior to implementation. The ACO shall advise the Contractor of the acceptability of such changes within 30 calendar days after receipt of the notice of proposed changes from the Contractor. If the advance approval requirements are waived by the ACO, the Contractor shall disclose EVMS changes to the ACO and provide an information copy to the NASA Contracting Officer at least 14 calendar days prior to the effective date of implementation.

   (e) The Contractor agrees to provide access to all pertinent records and data requested by the ACO or a duly authorized representative. Access is to permit Government surveillance to ensure that the EVMS complies, and continues to comply, with the criteria referenced in paragraph (a) of this clause.

   (f) The Contractor shall be responsible for ensuring that the subcontractors identified below comply with the EVMS requirements at the specified level.  If the subcontractor does not have an EVMS that has been recognized by the ACO as compliant with ANSI/EIA 748, the prime contractor shall conduct Compliance Reviews of subcontractors’ EVMS in the same manner as described at paragraph (b) of this clause.  (Insert list of applicable subcontractors and the level of compliance (i.e., guidelines or principles)

   (g) If the contractor identifies a need to deviate from the agreed baseline by working against an Over Target Baseline or Over Target Schedule, the contractor shall submit to the Contracting Officer a request for approval to begin implementation of an Over Target Baseline or Over Target Schedule.  This request shall include a top-level projection of cost and/or schedule growth, whether or not performance variances will be retained, and a schedule of implementation for the rebaselining.  The Government will authorize or deny the request within 30 calendar days after receipt of the request.  Failure of the Government to respond within this 30-day period constitutes approval of the request.  For cost-reimbursement contracts, the contract budget baseline shall exclude changes for cost growth increases, other than for authorized changes to the contract requirements.

(End of clause)

 

Alternate I (Deviation)

  As prescribed in 1842.7404(b), substitute the following paragraph (a) for paragraph (a) of the basic clause:

            (a) In the performance of this contract, the Contractor shall use an earned value management system (EVMS) that has been recognized by the cognizant ACO as complying with the guidelines of ANSI/EIA-748, Industry Guidelines for Earned Value Management Systems, or by NASA as complying with the principles specified in ANSI/EIA Standard 748.  In applying EVM to this contract, the contractor need only comply with the following principles as opposed to complying with the ANSI/EIA 748 guidelines:

(1) Plan all work for the project to completion.

                        (2) Break down the project work into finite pieces that can be assigned to a responsible person or organization for control of technical, schedule, and cost objectives.

                        (3) Integrate project work, schedule, and cost objectives into a performance measurement baseline plan against which accomplishments may be measured, and control changes to the baseline.

                        (4) Use actual costs incurred and recorded in accomplishing the work performed.

                        (5) Objectively assess accomplishments at the work performance level.

                        (6) Analyze significant variances from the plan, forecast impacts, and prepare an estimate at completion based on performance to date and work to be performed.

                        (7) Incorporate Earned Value Management into the project’s decision-making and review processes.