Compliance

Introduction to the Cost and Software Data Reporting (CSDR) Reporting Requirements

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A common client request is to assist them with sorting through the various DoD contractual reporting requirements and contract value reporting thresholds that apply. We frequently run into situations where a contractor needs clarification on why they have a Cost and Software Data Reporting (CSDR) requirement and whether they should seek to waive the requirement. Subcontractors to a prime often question the requirement to provide actual cost data directly to the DoD, especially for Firm Fixed Price (FFP) contracts.

Background

CSDRs are the primary means the DoD uses to collect data on the development, production, and sustainment costs incurred by contractors performing DoD acquisition contracts. It is a DoD system for collecting actual costs, software data, and related business data. The resulting data repository serves as the primary source for contract cost and software data for most DoD resource analysis efforts including cost database development, applied cost estimating, cost research, program reviews, analysis of alternatives (AoAs), and life cycle cost estimates.

CSDR reporting requirements are determined by the contract value regardless of the acquisition phase and contract type. In general, CSDR reporting is required for Acquisition Category I-II programs and Information System (IS) programs valued at more than $50M. They can also be required for Middle Tier Acquisition programs (greater than $20M) and other programs (greater than $100M). Risk can also be a determining factor regardless of the contract value.

DoD Instruction (DoDI) 5000.73, Cost Analysis Guidance and Procedures (March 2020), provides additional details about the cost data reporting. Table 1 in the 5000.73 lists the cost reporting requirements contract value thresholds. The DoD Manual 5000.04 Cost and Software Data Reporting (May 2021) is the primary requirements document for the development, implementation, and operation of the DoD CSDR system to ensure data reported is accurate and consistent.

About CADE

The Office of the Secretary of Defense Cost Assessment and Program Evaluation (OSD CAPE) established the Cost Assessment Data Enterprise (CADE), a secure web-based information system that hosts the controlled unclassified CSDR repository, the Defense Acquisition Cost Information Management System, and the forward pricing rate library. CADE also contains a selected acquisition report database, a contracts database, data analytics capabilities, and a library containing cost estimating content such as cost analysis requirement descriptions and cost estimates. CADE is access-controlled, and available through the public-facing CADE Portal website.

Similar to the cost estimating and proposal pricing functions within contractor’s organizations that rely on historical actual costs to assess the validity of a proposed cost estimate, independent and sound cost estimates are vital for effective DoD acquisition decision making and oversight. CADE plays a critical role in capturing the expenditure, technical, and programmatic data after contract execution in a consistent manner to enable independent cost estimating and analysis. This cost estimate data is essential to support efficient and effective resource allocation decisions throughout the planning, programming, budgeting, and execution process for the DoD.

CSDR Reporting Requirements

There are a series of Data Item Descriptions (DIDs) for this reporting requirement.  Some forms are submitted electronically using DoD defined XML schemas, Excel, or JSON encoded data in accordance with a File Format Specification (FFS) and Data Exchange Instruction (DEI). The list of DIDs are as follows. These DIDs can be downloaded from the CADE website.

  • Contract Work Breakdown Structure, DI-MGMT-81334D (May 2011).
  • Cost Data Summary Report, DI-FNCL-81565C (May 2011), DD Form 1921, XML Schema.
  • Functional Cost-Hour Report, DI-FNCL-81566C (September 2015), DD Form 1921-1, XML Schema.
  • Progress Curve Report, DI-FNCL-81567C (May 2011), DD Form 1921-2, XML Schema. 
  • Sustainment Functional Cost-Hour Report, DI-FNCL-81992 (May 2011), DD Form 1921-5, XML Schema.
  • Contractor Business Data Report, DI-FNCL-81765C (March 2021), DD Form 1921-3, Excel. 
  • Software Development Report, DI–MGMT-82035A (October 2022), DD Form 3026-1, XML Schema. 
  • Software Maintenance Report, DI–MGMT-82035A (October 2022), DD Form 3026-2, XML Schema.
  • Enterprise Resource Planning (ERP) Software Development Report, DI-MGMT-82035A (October 2022), DD Form 3026-3, XML Schema.
  • Cost and Hour Report (FlexFile), DI-FNCL-82162 (November 2017), JSON encoded data file following FFS and DEI.
  • Quantity Data Report, DI-MGMT-82164 (November 2017), JSON encoded data file following FFS and DEI.
  • Maintenance and Repair Parts Data Report, DI-MGMT-82163 (November 2017), Excel.
  • Technical Data Report, DI-MGMT-82165 (November 2017), Excel.

The Cost and Hour Report (FlexFile) and Quantity Data Report play a critical role in collecting cost data from contractors for the DoD data repository because they use JSON data encoding to organize the content. They are intended to replace the legacy 1921 series of paper-based formats including the DD 1921, 1921-1, 1921-2, and 1921-5. It also requires contractors to provide significantly more historical cost data than the 1921 formats. As a result, the DoD cost estimating community has additional insight into historical costs. The goal is to establish a common framework and standard nomenclature to collect data from different contractors, all of them with unique cost accounting structures, that are mapped to the DID, FFS, and DEI requirements for use in the data repository.

Establishing a Consistent, Repeatable Process to Produce the CSDR Data Deliverables

For contractors new to the CSDR reporting requirements and in particular, the FlexFile JSON data encoding, can appear to be daunting. That’s where software tools such as those from Midnite Dynamics can help. Midnite Dynamics specializes in assisting contractors with producing the CSDR data deliverables. 

Their software tool, C*CERT+, streamlines, automates, validates, and produces the legacy 1921 family of Excel and XML reports as well as the FlexFile and Quantity Data Report JSON submittals. C*CERT+ eliminates what otherwise is a manually intensive, resource draining, tedious and costly effort subject to recurring rejections. It is one thing to create the required legacy reports or FlexFile JSON files for submittal, it is another to pass the submittal validation process. C*CERT+ provides numerous data validations and analysis reports to ensure the data is 100% compliant before it is submitted. For example, the software includes over 90 FlexFile validations to ensure data compliance as illustrated in Figure 1.

Figure 1: Example of FlexFile data validation results.
Figure 1: Example of FlexFile data validation results.

The software includes a Validation and Remarks utility to analyze the source data details that could result in a Validation Trip. Remarks can be entered directly into the validation module for anything that requires an explanation. This is illustrated in Figure 2. This narrative is included with the data submittal.

Figure 2: Example of providing remarks about the FlexFile data content.

C*CERT+ also interfaces with existing EVM cost tools and accounting systems to produce the existing legacy 1921 reports, the FlexFile, and other data submittals as well as to consolidate separate projects/CLINs/task orders into a single contract report.

Once the C*CERT+ Standard Category Mapping Rules are set up, they can be shared throughout the corporation or business unit to establish a standard and repeatable process for producing the data deliverables. This mapping process translates the contractor’s source data into an output that matches the CSDR data submittal format rules. This saves a tremendous amount of time and makes it much easier to consistently produce the CSDR data deliverables. An example of the Mapping Rules is illustrated in Figure 3.

Figure 3: Mapping Rules translate contractor unique cost data into a format that matches the CSDR data submittal requirements.

Do your process and procedures or training materials need an update to include specific guidance for project control teams to produce required DoD contractual reports or data submittals using your tool sets of choice? Give us a call today at (714) 685-1730 to get started. 

Introduction to the Cost and Software Data Reporting (CSDR) Reporting Requirements Read Post »

Navigating EVMS Certification: A Step-by-Step Guide to Compliance

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Navigating EVMS Certification

In the complex landscape of project management, ensuring compliance with the EIA-748 Standard for Earned Value Management Systems (EVMS) Guidelines is a critical step for companies seeking to secure and successfully manage government contracts. Humphreys & Associates are leaders in earned value consulting, providing comprehensive strategies and solutions tailored to meet the rigorous requirements of the EVMS approval or certification process by a Cognizant Federal Agency (CFA). This article is the first part of a three-part series aimed at guiding organizations through the process of implementing a compliant EVMS and successfully completing a CFA EVMS compliance review.

Understanding the EVMS Approval or Certification Process

Achieving EVMS approval or certification by a CFA such as the Defense Contract Management Agency (DCMA) or the Department of Energy (DOE) is a structured process that requires careful planning and execution. The process begins with a thorough understanding of the EIA-748 Standard for EVMS Guidelines, which is the foundation for determining whether an EVMS is compliant. The EIA-748 Guidelines define the requirements to establish and maintain an effective EVMS. The approval or certification process involves several key steps, beginning with the initial application and concluding with the CFA formal determination a contractor’s EVMS complies with the Guidelines. Throughout this journey, organizations must demonstrate a thorough understanding of the Guideline requirements and how they are implemented within their project management framework as documented in their EVM System Description.

Steps to Achieve EVMS Certification

  1. Preparation and Self-Assessment: Conducting an internal review of the current project management processes and comparing them against the EIA-748 Standard for EVMS Guideline requirements is an important first step to identify gaps in the system that will need to be addressed.
  2. Training and Education: It is crucial for the team responsible for EVMS implementation to receive proper training to understand the Guideline requirements and how to apply them.
  3. System Description Development: A comprehensive EVM System Description that explains how the organization’s processes meet the EIA-748 Guideline requirements must be developed.
  4. Implementation: The EVMS must be implemented on a project, demonstrating the project team’s ability to use the EVMS and EVM data to manage the project, as well as the system’s functionality in a real-world scenario.
  5. Mock Compliance Review: An internal review, often with the help of an independent third party, should be conducted to verify the EVMS complies with the Guideline requirements as well as to verify the quality of the project’s schedule and cost data to provide timely and actionable information for managing the project.
  6. Formal Compliance Review: A CFA conducts a formal review of the EVMS. This includes reviewing the EVM System Description, performing a detailed examination of project schedule and cost data, conducting interviews with project personnel, and assessing how the EVMS has been implemented.

Importance of Complying with the EIA-748 Guidelines

Meeting the EIA-748 Guideline requirements is not just about compliance; it is about integrating a system that enhances the project management capabilities of an organization. A well-implemented EVMS facilitates better project control, provides early warning signs of performance issues, and supports informed decision-making. Compliance with the Guidelines is often a prerequisite for bidding on government contracts, making a formal EVMS approval or certification a strategic necessity for companies in the defense, aerospace, and construction industries, among others.

Key Requirements for an EIA-748 Compliant EVMS

The EIA-748 Standard for EVMS provides the basic guideline requirements for organizations to establish and implement a system that integrates project work scope with the schedule and cost components to enhance project planning and control. The Guidelines are organized into these process areas:

  • Organization: The organization guidelines focus on establishing the framework for decomposing a project’s scope of work to level where it is possible to identify management responsibility for the work scope, schedule, and cost components.
  • Planning, Scheduling, and Budgeting: The organization guidelines are the framework for the planning, scheduling, and budgeting process required to establish the performance measurement baseline, a common point of reference for measuring completed work and communicating the project’s current status.
  • Accounting Considerations: These guidelines focus on the recurring processes for determining progress and collecting the actual costs for work performed. The objective is to ensure alignment between the budget plan, performance claimed (earned value), and actual costs to continually assess and analyze project performance for potential corrective action.
  • Analysis and Management Reports: These guidelines facilitate the analysis and use of the performance data to proactively manage the project. An EVMS generates variance data that helps management to focus on areas that are not performing to plan for potential corrective action.
  • Revisions and Data Maintenance: The integrity of the performance measurement baseline must be maintained to manage the remaining work on a project. These guidelines focus on establishing a controlled process to document, authorize, track, and manage revisions to a project’s scope, schedule, and budget.

Frequency and Importance of Surveillance Reviews

Surveillance reviews are an important part of maintaining a compliant EVMS. Once the CFA has approved or certified a contractor’s EVMS, the contractor is responsible for implementing an annual self-surveillance or self-governance process to ensure the EVMS continues to be implemented on projects in an effective and consistent manner in compliance with the EIA-748 Guidelines. It also ensures the contractor’s EVMS process and procedures, training, and tools are actively maintained over time. The government customer also conducts surveillance for the life a contract, typically on an annual basis. This is a recurring evaluation of the contractor’s management control practices and samples of internal and external reported data. The focus is typically on major system activities, problem identification, and tracking any corrective actions to closure.

The successful implementation of an EVMS that complies with the EIA-748 Guideline requirements is a testament to an organization’s commitment to project excellence. It demonstrates a capability many government agencies require, making it an essential investment for businesses looking to expand their opportunities within this sector. The subsequent articles in this series will delve into the specifics of the EVMS implementation process and the intricacies of preparing for EVMS compliance and surveillance reviews.

Stay tuned to learn more about effective EVMS implementation for government contracts in our next blog, “Effective EVMS Implementation for Government Contracts: Roles and Challenges,” and how to prepare for surveillance or compliance reviews in “Preparing for EVMS Reviews: Strategies for Success with Humphreys & Associates.”

This article has provided an overview of the EVMS approval or certification process by a CFA and the importance of complying with EIA-748 Standard for EVMS Guidelines. 

Navigating EVMS Certification: A Step-by-Step Guide to Compliance Read Post »

Preparing for EVMS Reviews: Strategies for Success with Humphreys & Associates 

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Preparing for EVMS Reviews

Facing an Earned Value Management System (EVMS) compliance review can be an imposing prospect for any organization with EVMS contractual requirements. With strategic preparation and expert guidance from Humphreys & Associates, renowned for their leadership in earned value consulting, this necessity can be transformed into an opportunity for process improvement to ensure an effective and efficient EVMS can be implemented on any project. This comprehensive guide, the first in a three-part series, takes a closer look at the strategic approach necessary for preparing for a Cognizant Federal Agency (CFA) EVMS compliance review. CFAs include the Defense Contract Management Agency (DCMA) for DoD and NASA contracts and the Department of Energy (DOE). A CFA conducts a formal review to determine whether the contractor’s EVMS is compliant with the EIA-748 Standard for EVMS Guidelines. A formally approved or certified EVMS is an EVMS the CFA has determined to be compliant with the EIA-748 Guidelines.

Key Elements in Preparing for an EVMS Compliance Review

A successful EVMS compliance review is predicated on several fundamental elements. Being well-prepared in these areas can make the difference between a review that goes smoothly and one that uncovers issues that require corrective action.

  • Thorough Documentation: Proper documentation is the backbone of any review process. It’s essential to maintain an EVM System Description that explains how the system complies with the EIA-748 Guideline requirements as well as any agency specific EVMS requirements. This includes documented policies and procedures as well as process flowcharts illustrating system inputs and outputs with responsibility assignments.
  • Mock Reviews: Conducting internal mock reviews can serve as a rehearsal for the actual review. These practice runs help to uncover any weaknesses in the system and provide a chance to correct them beforehand. Mock reviews also help familiarize the team with the compliance review process, reducing anxiety and ensuring that everyone knows what to expect.
  • Continuous Training: Regular and comprehensive training ensures that project personnel are familiar with the EVMS processes, know how to use the EVM data, and understand the importance of their role in maintaining quality schedule and cost data. This training should be updated regularly to reflect any changes in EVMS requirements, software tools, or company procedures.
  • Data Integrity: The accuracy and completeness of project data are crucial. Regular validation checks should be conducted to ensure data in the EVMS are valid, reliable, and traceable. This includes verifying the project data aligns with the corporate financial records and that the system accurately reflects the project’s current status.
  • Stakeholder Engagement: Effective reviews require the cooperation and understanding of all stakeholders. Engaging them early in the review process helps ensure everyone is on the same page and that the roles and responsibilities are clearly defined. This engagement includes regular communication and involvement in the compliance review preparation process.

Assistance in the Review Preparation Process

Humphreys & Associates provides comprehensive services designed to support organizations throughout the compliance review preparation process. This includes:

  • Compliance Review Readiness Assessments: These assessments are crucial in determining the readiness of an organization’s system, personnel, and data quality for a compliance review. The assessment identifies areas of strength and those requiring improvement, enabling targeted action to enhance readiness.
  • Preparation Workshops: Workshops conducted by experienced consultants can train and prepare the team for the compliance. These sessions cover everything from the basics of EVM to the nuances of the review process, tailored to the specific needs of the organization.
  • Documentation Review: Prior to an compliance review, it’s beneficial to have an external review of the documentation that will be presented. This review can identify areas where additional information is needed and ensure that the documentation accurately reflects the EVMS and compliance with the EIA-748 Guidelines.
  • Support Services: During the review, having expert support available can alleviate the challenges that may arise. This includes on-the-spot advice and assistance in addressing the CFA’s questions and concerns. Should the CFA issue formal corrective action requests (CARs), Humphreys & Associates can assist with producing and implementing the corrective action plans (CAPs) to resolve the deficiencies as quickly as possible.

Common EVMS Review Findings and Remediation

There are several common findings that an EVMS compliance review might reveal that could potentially impact an organization’s ability to obtain a formal CFA EVMS compliance approval or certification. Being aware of these potential findings and understanding how to address them is key to success.

  • Inadequate Baseline Control: Maintaining a current and accurate performance measurement baseline is essential. When a government review team finds baseline control to be lacking, it’s often due to inadequate processes for incorporating changes into the baseline or failing to maintain traceability of the changes.
  • Insufficient Documentation: Documentation gaps can lead to findings of non-compliance. Government review teams need to see evidence that a complete set of processes are in place and that these processes are being followed. This includes having proper version control and evidence of management approvals.
  • Data Discrepancies: Differences between what’s reported in the project reports and the actual project data can indicate serious issues with data management systems. Ensuring that the EVMS software is properly configured, data validation checks are routinely performed, and that schedule and cost data align can prevent such discrepancies.

To address and prevent these common issues, Humphreys & Associates recommends a proactive stance, with robust change control processes, continuous enhancement of documented practices, and improvements to data management systems to ensure accuracy and traceability.

Preparing for an EVMS compliance review is a critical task that can significantly impact the management and success of government contracts. With the strategies provided here and the support of Humphreys & Associates, organizations can confidently navigate the EVMS compliance review process.

Explore the nuances of the implementation phase in “Effective EVMS Implementation for Government Contracts: Roles and Challenges,” and enhance your understanding of the certification process in “Navigating EVMS Certification: A Step-by-Step Guide to Compliance.”

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Updates to the Compliance Review Series of Blogs

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Time Lapse of Freeway representing the progress of time.

2020 Update

Humphreys & Associates has posted a 2020 update to the series of blogs discussing the DCMA Compliance Review (CR) process. “Compliance Review” is the term used for the formal EVM System review DCMA performs to determine a contractor’s compliance with the EIA-748 Standard for EVMS guidelines. This can also include, as applicable, Surveillance Reviews and Reviews for Cause (RFC).

DCMA used to follow a 16 Step compliance review process. This changed to an 8 Step process with the release of the DCMA Instruction 208 (DCMA-INST 208) titled “Earned Value Management System Compliance Reviews Instruction.” This Instruction has been rescinded and replaced with a set of DCMA Business Practices (BP). These Business Practices split out topics that the old DCMA Instruction 208 covered in one document. Whether you are a contractor new to the EVM contracting environment or a seasoned veteran, if the Earned Value Management System (EVMS) compliance and acceptance authority is the Defense Contract Management Agency (DCMA), these new Business Practices apply to you.

The four updated blogs include:

  • EVMS Compliance Review Series #1 – Prep for the DCMA Compliance Review Process. This blog presents the set of DCMA Business Practices (BP) that define the EVMS and Review process and specifically discusses Business Practice 6 “Compliance Review Execution.” It also discusses what you can expect should you need to complete the DCMA Compliance Review process through the 5 phases and 23 Steps outlined in BP6. It is critical you are able to complete each step in the process successfully the first time through to prevent delays. The best way to make sure you are prepared is to conduct one or more internal EVMS Mock Reviews, the topic for the next blog.
  • EVMS Compliance Review Series #2 – Conducting Internal Mock Reviews (Self Assessments). This blog discusses the importance of conducting a thorough internal review of your EVMS. You may or may not have the expertise in-house to conduct this simulation of a Compliance Review. An independent third party can help you prepare for a DCMA compliance review. The objective is to conduct the EVMS Mock Review to simulate everything DCMA will do. DCMA also expects a thorough scrub of the schedule and cost data – data traceability and integrity is essential.
  • EVMS Compliance Review Series #3 – Using Storyboards to Depict the Entire EVMS. Do you need a refresher on the role of storyboards in a compliance review? Storyboards can make a difference in training your personnel and explaining to the DCMA personnel how your EVMS works. Storyboards can take many forms, and if you don’t have one in place, consider starting with the flow diagrams in your EVM System Description.
  • EVMS Compliance Review Series #4 – Training to Prepare for Interviews. This blog highlights the importance of conducting training for your personnel, particularly the control account managers (CAMs), so they are able to complete successful interviews with DCMA personnel. H&A recommends completing a three step training process to proactively address any issues.

Help Preparing for a Compliance Review

Do you need help preparing for a DCMA compliance or surveillance review? Download the set of DCMA Business Practices and read our updated blogs so you have an idea of what is ahead. Humphreys & Associates can help you conduct a Mock EVMS Review, perform a data quality assessment, create a storyboard, or conduct EVMS interview training and mentoring for your personnel. Call us today at (714) 685-1730 or email us.

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Reviewing Authority Data Call – Not Just a Wish List

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Authority Data Call

Data Call

One of the most important items needed to prepare for an Earned Value Management System (EVMS) review is the data call. This is not just a list of random data; the reviewing authorities have a defined set of data items they want to review so they can evaluate the EVMS implementation and compliance.

Required Artifacts

Over the years the reviewing authorities have fine-tuned the review process and created a very specific list of required artifacts. They use these items to pre-determine the review focus areas so they are prepared to get right to the soft spots in the system and processes.

Formal Review Notification

The process begins when the contractor receives a notification from the reviewing authority that they will conduct a formal review of a project. This could be a Compliance Review (CR); an Integrated Baseline Review (IBR); standard Surveillance; or one of many other reviews conducted to determine the implementation or continued compliance of the EVMS processes and reports. Regardless of the type of review, one of the key items is the data call request. The data call is used to request project information, and could consist of 12 reporting periods, or more, of data. This will vary by agency, type of program, and type of review. In most cases, a minimum of three months of project data will be required; typically, however, 6 to 12 months of data would be requested.

Basic Reports

Some of the basic reports requested are the Contract Performance Reports (CPRs), Integrated Program Management Reports (IPMRs), or similar time phased project performance reports produced from the earned value (EV) cost tool database. The data call request includes the detail source data from the EV cost tool as well as the Integrated Master Schedule (IMS) from the beginning of the program. This source data is often delivered electronically to a customer following the IPMR or Integrated Program Management Data and Analysis Report (IPMDAR) Data Item Description (DID) prescribed data formats. The Baseline Logs are often also requested.

Quality Data

It is essential to provide quality data in response to the Review Authority data call. The entire review process can be derailed when data call items are incomplete or inaccurate. Some of the things to consider are:

  1. Make sure the list of requested items is fully understood (some nomenclature issues could cause an issue).
  2. The data should be available in the format required in the call.
  3. Determine the best way to support the data call delivery if it is not specified in the request. The data can be provided using electronic media such as thumb drive, as attachments to emails (the size of the files may prohibit this), or possibly establishing a secure access cloud server to store the data for the reviewing authority to retrieve.
  4. Contact the requesting reviewing authority to establish a meeting to discuss the data call. This meeting should be used to resolve or clarify any issues regarding the requested information, negotiate potential equivalents of the project data if it does not exactly match the requested information, and establish a method to transmit all data files.
  5. Develop an internal plan to monitor the progress of data collection. Be sure to have non-project personnel review the data for accuracy and compliance with the specifics in the data call.
  6. Submit the data call to the requesting authority, follow-up with a phone call or meeting to verify the reviewing authority received the data, can open all the files, and agrees the complete set of data has been provided.
  7. Follow-up with another call a few weeks before the review to check if the reviewing authority has any issues or problems in evaluating and understanding the data call information. Be willing to work with them until the authority is comfortable with the data.

[NOTE: The number of items on the list depends on (1) the agency conducting the review and on (2) the type of review being conducted. The number of items requested could vary from around 30 to 100 or more.]

Typical Data Call

Some of the basic items typically requested in the data call are:

  1. Earned Value Management System Description including the matrix of the System Description and related system documentation mapped to the 32 guidelines in the EIA-748 Standard for Earned Value Management Systems as well as to the current version of the reviewing agency’s EVMS Cross Reference Checklist.
  2. EVMS related policies, processes, procedures, and desktop instructions. Examples include organizing the work, scheduling, budgeting, work authorization, details about earned value techniques and how each is applied, change control, material planning and control, subcontract management, and risk/opportunity management.
  3. Organization charts down to the Control Account Manager (CAM) level.
  4. Accounting calendar.
  5. Project directives including the Statement of Work (SOW) pertaining to Program Management or Statement of Objectives (SOO), EVM clauses, and EVM Contract Data Requirements List (CDRLs) or Subcontract Data Requirements List (SDRLs).
  6. Work Breakdown Structure (WBS) Index and Dictionary.
  7. Responsibility Assignment Matrix (RAM) including budget detail at the CAM level.
  8. Project and internal work authorization documents.
  9. Integrated Master Plan (IMP) or milestone dictionary.
  10. Contract Budget Base Log, Management Reserve Log, and Undistributed Budget Log.
  11. Risk/opportunity identification and assessments, risk/opportunity management plan.
  12. Cost performance reports (all applicable formats) or datasets. Provide the reports or dataset in the format provided to the customer such as PDF, Excel, UN/CEFACT XML, or JSON encoded data per the DID on contract such as the CPR, IPMR, or IPMDAR.
  13. Integrated Master Schedule (IMS) submissions and related native schedule file. This includes the IMS summary report if required.
  14. IMS Data Dictionary.
  15. Most recent Contract Funds Status Report (CFSR) or equivalent funding status report.
  16. Variance Analysis Reports (VARs) or equivalent progress narrative reports as well as the internal and external variance thresholds.
  17. List of subcontractors including value and type (such as cost reimbursable, firm fixed price, time and materials) including the applicable purchase orders. When EVM requirements are flowed down to the subcontractors, provide a copy of subcontractor EVM related contractual requirements (CDRLs and DIDs).
  18. Major subcontractor CPRs, IPMRs, or equivalent cost performance reports (all applicable formats) or IPMDAR datasets.
  19. Major subcontractor IMS submissions.
  20. Previous audit or surveillance findings, resulting reports, corrective action plans, and resolution and tracking Logs.
  21. List of specific software toolsets used for accounting, scheduling, cost management, resource management, risk/opportunity management, or performance analysis.
  22. EVMS Storyboard and flowcharts.
  23. Chart of accounts, including cost element definition.
  24. Staffing plans or weekly/monthly labor reports.
  25. List or copy of contract modifications.
  26. Cost Accounting Standards (CAS) disclosure statement or equivalent internal corporate procedures.
  27. Baseline Change Requests.
  28. Any other data previously provided to the customer as part of a data call.
  29. Basis of Estimates (BOE) or historical data/productivity rates and efficiency factors.
  30. Estimate to Complete (ETC) and Estimate at Completion (EAC) documentation.
  31. Budget reports or control account plans by element of cost (labor hours and dollars, material dollars, and other direct cost dollars) and associated burdens or overhead costs.
  32. Actual cost reports.
  33. Open commitment reports.
  34. Bill of material including cost detail.
  35. Quantifiable Backup Data for percent complete work packages including MRP/ERP Reports for production work packages.

Reacquaint Yourself

The list includes items that are used frequently, as well as items that are used only at specific times during the project, and will probably be less familiar to the review team. As the collection of the data call items progresses, be sure to establish quick refresher sessions on the less frequently used documents and any other items where the review team might be having difficulty. As part of the process of gathering the data call items, be sure internal reviews are conducted to verify accuracy and traceability, verify the users of the data are familiar with the data content so they can be prepared to answer questions, and current data are available to the review team.

NOTE: This Data Call List is intended for general guidance in preparation for any agency review (e.g., DCMA, DOE, FAA, etc.). For example, in the past, the DCMA Compliance Review Data Call item list contained 102 specific items, but this number varies from review to review and has changed over the years.  The number is not as important as the quality of the data items that are delivered to the review authority.

First Impressions

The data call items will provide the first look at the project’s EVM data and process for many of the review team members. The review team members will have the data several weeks prior to the on-site review. They will be performing multiple validation checks using various analytical software tools as well as hands-on analysis of the information. If the data is incomplete, contains errors, and does not trace well, the review team will form a more negative opinion of the EVMS application.

Double Check the Data Call

The data analysis results will be a basis for where attention is focused during the on-site review, as it emphasizes areas that contain anomalies or indicates a lack of system integrity. Significant emphasis should be devoted to the data call items to ensure accuracy and compliance with the review authority’s requests, as it is a very positive way to begin the data call review.

A Humphreys & Associates EVM specialist is always available to answer questions. Give us a call or send an email.

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EVMS Compliance Review Series #4 – Training to Prepare for Interviews

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Updated November 10, 2017
Updated December 15, 2020

DCMA Compliance Review Series

This is the fourth topic in a series discussing the DCMA Compliance Review (CR) process. It is the second update to the original series #4 Blog that was based on the instruction book from the DCMA Website that identified the “DCMA 16 Step (and then their 8-Step [UPDATE #2]) EVMS Compliance Review Process.” This change was documented in the DCMA “Earned Value Management System Compliance Reviews Instruction (DCMA-INST 208).” This Instruction has been rescinded and replaced with a set of DCMA Business Practices (BP). These Business Practices split out topics the old DCMA Instruction 208 covered in one document. Whether you are a contractor new to the EVM contracting environment or a seasoned veteran, if the Earned Value Management System (EVMS) compliance and acceptance authority is the Defense Contract Management Agency (DCMA), these new Business Practices apply to you.

This is a continuing discussion about the interviews that are part of the optional contractor self-assessments and as part of conducting any Compliance Review, Surveillance Review, or Review for Cause (RFC). The DCMA uses a standard set of interview forms for the control account managers (CAMs), project managers, integrated product team (IPT) leads, risk managers, business managers, and accounting. Contractors should use similar interview questionnaires to simulate the DCMA interview process as closely as possible to prepare the CAMs and others for the DCMA interviews.

CAM Interviews are Critical

While it is important to have successful interviews with everyone, the CAM interviews are critical. The CAMs are the primary interview subjects during a compliance review. The CAMs must be able to demonstrate they have a full understanding of their scope of work and show how they use the company’s EVMS artifacts to manage their work on a day-to-day basis, in addition to the normal weekly or monthly business rhythm. The CAMs need to have a good understanding of their role to provide acceptable responses to interview questions and to be comfortable with the interview process.

CAMs must be able to demonstrate a working knowledge of:

  • EVM,
  • The 32 guidelines in the EIA-748 Standard for Earned Value Management Systems,
  • The company’s EVMS,
  • How to perform the applicable data traces for their scope of work, and
  • How they fit into the grand scheme of the project.

The CAMs must also have a level of proficiency with the project control toolsets. Many companies use electronic CAM notebooks integrated into the EVMS Storyboard to assist the CAMs.

Three-Step Training for CAMs

Conducting training for the CAMs is an important preparation step. Based on our long history of successfully preparing CAMs, project managers, and others for compliance reviews, Integrated Baseline Reviews (IBRs), or surveillance reviews, we suggest a three-step training process for the CAMs.

Set Expectaions

Step 1. Conduct training sessions for the CAMs on what is expected during a DCMA interview. This training can include conducting an example group interview the CAMs and others can observe. The group interview session typically includes an open discussion at the end to critique the interview process.

  • What were the good techniques?
  • What could be improved?
  • What are some things to avoid?

This helps to set expectations and provides a preparation guide for the people to be interviewed.

White Hat Interview

Step 2. Conduct “white hat” interview sessions with the CAMs. These are more one-on-one mentoring sessions to help the CAMs through the interview process. Providing feedback at the end of each session reinforces the learning process and increases their level of proficiency. This dry run helps the CAMs to feel more comfortable with the interview process. It also helps to increase their confidence level and ability to think on their feet.

Black Hat Interview

Step 3. Conduct “black hat” interview sessions with the CAMs. For these sessions, the interviewers conduct the interview as if they were members of the DCMA review team. If the CAM is unable to undergo a thorough interview, the session evolves into a mentoring session to help them through the process. The “black hat” interview sessions should continue until each CAM is comfortable with the interview process.

Identify Deficiencies

A summary of the findings from the interviews can help a company to be proactive in addressing known issues. The goal is to identify any deficiencies whether in the EVMS design, implementation, end-user knowledge, or data quality. Deficiencies can be reported in self-assessment Discrepancy Report (DR) forms along with the corrective action plans that will be implemented to resolve the issue.

It is far better for the company to find and address any issues as part of the internal self-assessment process than to have DCMA find them during the formal Compliance Review. This can make a difference in whether or not DCMA issues Corrective Action Requests (CARs) or recommends moving to the next step in the compliance review process.

Contact H&A to help train your Control Account Manager (CAM) with one-on-one mentoring, conducting mock review interviews, or as part of preparing for an Integrated Baseline Review (IBR). We can be reached at (714) 685-1730 or email us.

EVMS Compliance Review Series

EVMS Compliance Review Series #4 – Training to Prepare for Interviews Read Post »

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