Integrated Program Management Report (IPMR)

New IPMDAR DID and Implementation Guide

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ALERT- New IPMDAR DID and Implementation Guide

The New Integrated Program Management Data and Analysis Report (IPMDAR) Data Item Description (DID) and Implementation Guide

On March 12, 2020, the Defense Department (OUSD/AAP) instituted the new Integrated Program Management Data and Analysis Report (IPMDAR), issuing the Data Item Description (DID) Number: DI-MGMT-81861B.
The IPMDAR is to be used for solicitations and RFPs for contracts with an EV reporting Requirement starting from March 12, 2020 forward. The IPMDAR can also be applied to modified contracts or to existing contracts (under the old IPMR or CPR requirements), but this has to be through a bi-lateral agreement (Government Program Office and Contractor).

Significant Change

This IPMDAR is a significant change from the previous iterations, the Integrated Program Management Report (IPMR) and the old Contract Performance Report (CPR). The IPMDAR has dispensed with the delivery of physical reports (Formats 1 – 7 of the old IPMR/ CPR), instead now requiring contractors to provide three (3) specific electronic data sets:

  • The Contract Performance Dataset (CPD)
  • The Schedule, comprised of
    • The Native Schedule File and
    •  The Schedule Performance Dataset (SPD)
  • The Performance Narrative Report, comprised of
    • The Executive Summary and
    • The Detailed Analysis Report

The DID states: “The IPMDAR’s primary purpose to the Government is to reflect current contract performance status and the forecast of future contract performance.”

Integrated Program Management Data Analysis Report (IPMDAR) Implementation & Tailoring Guide

Implementation & Tailoring Guide

To help expedite the adoption of the New IPMDAR, on May 21, 2020, the AAP office also issued the 87-page Integrated Program Management Data Analysis Report (IPMDAR) Implementation & Tailoring Guide:
“This guide covers the application of the DID, how to tailor the DID in the Contract Data Requirements List (CDRL), and clarification on the intent of the DID.”

Interesting Features

The IPMDAR has introduced some interesting features that are clarified in the Guide:

  • The default reporting is at the Control Account, but there is the option to have Work Package Level reporting (negotiated item)
  • Reporting is by Hours and Elements of Cost (EOCs) (for either the CA or WP level)
  • Time-phased Future Baseline (BCWS) and ETC Forecast (for either CA or WP level)
  • Best Case/Worst Case/Most Likely EACs reported by hours and dollars
  • The Native Schedule is a direct export from the contractor’s scheduling tool
  • The SPD must match the CA or WP level negotiated
  • The Government may have any subcontractors provide the IPMDAR directly to the Government
    • Even if this is required, the subcontractors must still provide the IPMDAR data to their prime contractor
  • The IPMDAR reporting components must be delivered to EVM-CR not later than 16 business days after a contractor’s accounting period
    • Incremental deliveries may be authorized, but all the items must be in NLT the 16th business day and the incremental deliveries are negotiated. A potential example is IMS by third working day after close-of-month, the raw data by fifth working day, and format 5 narrative by the sixteenth working day.
  • Historical Contract Performance Data – The Government may request this “time-phased historical data from contract award” in place of the normally provided CPD (typically no more than annually).

Applicability

IPMDAR Applicability:

  • IPMDAR is intended to be applied completely (i.e., not tailored) for cost or incentive contracts ≥ $20M – unless tailoring is specified within the DID and coordinated with the Service/ Agency EVM Focal Point.
  • If EVM reporting is required on contracts less than $20M, tailoring is more flexible, BUT the Native Schedule and Performance Narrative Report are recommended.
  • IPMDAR typically not required on FFP.

Humphreys & Associates, Inc. can help you properly implement the new IPMDAR requirements, please contact us at (714) 685-1730

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Formal Reprogramming – What Happened?

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Graph of an Increasing Budget

A long time ago, in a galaxy far, far away….an Over Target Baseline (OTB) – by design – was a rare occurrence (and the OTS concept did not even exist as part of Formal Reprogramming). Formal Reprogramming was a very difficult and cumbersome process that most contractors (and the government) really did not like to consider. The government, in its 1969 Joint Implementation Guide, said:

“Reprogramming should not be done more frequently than annually and preferably no more frequently than once during the life of the contract.”

The Office of the Under Secretary of Defense (OUSD) Acquisition, Analytics and Policy (AAP) – formerly PARCA – , in their latest OTB/OTS guide, states that Formal Reprogramming now has expanded to include an Over Target Schedule (OTS).  However, in that guide, it is stated in Paragraph 1.3.8:

“Ideally, formal reprogramming should be done no more than one time during the life of a contract. However, there may be instances where another formal reprogramming is warranted… When formal reprogramming is accomplished in accordance with the procedures in this guide, with a realistic cost and schedule estimate established for the remaining work, it should not be necessary to undergo formal reprogramming again.”

Today, though, whenever contractors incur a significant cost or schedule variance, instead of resolving the variance cause, the first words seem to be: “Let’s do an OTB or OTS.”  The lure of “getting rid of cost and schedule variances” seems too good to pass up.  Unfortunately, an OTB/OTS implementation has never been an instantaneous process. With AAP’s 12 step OTB/OTS process, it is obvious that the contractor will not be able to start today and incorporate the OTB/OTS in the next Integrated Program Management Data and Analysis Report (IPMDAR) dataset. In fact, AAP’s OTB/ OTS guide states in paragraph 3.8:

“It may be difficult to ascertain the length of time it will take to implement a new baseline based on the scope of the effort. It is not uncommon for the entire process to take up to six months which would be too long of a period without basic cost reporting.”

The last line of the above cited paragraph was referencing the reporting requirements to the customer when an OTB/OTS is being implemented.

The IPMDAR Implementation and Tailoring Guide (5/21/2020) even recognizes the issues with timeliness of implementing an OTB/OTS:

2.3.2.5.5  Formal Reprogramming Timeliness. Formal reprogramming can require more than one month to implement. During formal reprogramming, reporting shall continue, at a minimum, to include ACWP, and the latest reported cumulative BCWS and BCWP will be maintained until the OTB/OTS is implemented. 

So why does it take so long to implement the OTB/OTS?  Can the contractor just adjust the bottom line variances and move on?  Actually no, nothing is really that simple.  This is one of the reasons that implementing an OTB and OTS should not be taken lightly.   The AAP OTB/OTS Guide addresses adjustments this way:

“3.5.6.2 Adjusting Variances: A key consideration in implementing an OTB is to determine what to do with the variances against the pre-OTB baseline. There are essentially five basic options. This is a far more detailed effort than these simple descriptions imply, as these adjustments have to be made at the detail level (control account or work package).”

When considering the number of control accounts and work packages involved in a major contract, a Formal Reprogramming can become a rather daunting task.  The contractor also has to report the effects of the Formal Reprogramming in the IPMDAR Reprogramming Adjustments columns. These adjustment columns appear on both Format 1 and Format 2 of the IPMDAR database, which means the contractor must undertake the assessment for both the contract’s WBS and the OBS – for each WBS element and for each OBS element reported.  This can be further complicated if the OTB/OTS exercise were flowed down to subcontractors for a given program.  The AAP OTB/ OTS Guide, paragraph 3.8 also states:

“The customer should be cognizant of the prime contractor’s coordination complexities and issues with its subcontractors. The time to implementation may be extended due to accounting calendar month overlaps, compressed reiterations of contractor ETC updates, internal reviews, subcontractor MR strategy negotiations, senior management approvals, etc., all while statusing the normal existing performance within a reporting cycle.”

In the early days, when implementing an OTB with variance adjustments, the company and the customer agreed on a month-end date to make the data adjustments.  Then the contractor ran two CPRs or IPMRs (now the IPMDAR): (1) the first report as though no OTB had been implemented [to determine the amount of adjustments to cost variance (CV) and schedule variance (SV) at all the reporting levels] and, (2) the second report [after the OTB implementation had been completed – no matter how long it took] showing the Column 12 adjustments plus whatever BAC changes were being implemented.

Under the current OTB/OTS Guide, it appears as though this process is being done all at once. As stated in the AAP OTB/ OTS Guide paragraph 3.8 above, this implementation could take up to 6 months to complete, so lagging the second report until the OTB/OTS implementation is completed seems logical. The last sentence in paragraph 3.8 also stipulates that regardless of how long implementation takes, the contractor and customer will agree on interim reporting that will be required, further stating that:

“In all cases, at least ACWP should continue to be reported.”

Perhaps this agreement with the customer should also specify the content of the first IPMDAR following OTB/OTS implementation.

All things taken into account, the process of requesting and getting approval for an OTB or OTS can be a long and difficult process, especially if, at the end of it all, the contractor’s request is denied.  Even if it were approved and the contractor implements and works to the newly recognized baseline, immediately doing another one is not a pleasant thought – and remember, it was not intended to be pleasant. Reprogramming was always supposed to be a last resort action, when reporting to the current baseline was totally unrealistic.

Now, what about those cases where a contract has one or two elements reporting against totally unrealistic budget (or schedule) baselines?  The AAP OTB/ OTS Guide does cover a partial OTB, but reiterates that this is still an OTB because the Total Allocated Budget (TAB) will exceed the Contract Budget Base (CBB).  In the early days, however, the government allowed what was called Internal Operating Budgets (IOBs) for lower level elements (control accounts, or specific WBS elements, etc.) that were having problems resulting in an unrealistic baseline for the work remaining. The 1987 Joint Implementation Guide, paragraph 3-3. I (5) described IOBs as follows:

“(5) Internal Operating Budgets. Nothing in the criteria prevents the contractor from establishing an internal operating budget which is less than or more than the total allocated budget. However, there must be controls and procedures to ensure that the performance measurement baseline is not distorted.

(a) Operating budgets are sometimes used to establish internal targets for rework or added in-scope effort which is not significant enough to warrant formal reprogramming. Such budgets do not become a substitute for the [control] account budgets in the performance measurement baseline, but should be visible to all levels of management as appropriate. Control account managers should be able to evaluate performance in terms of both operating budgets and [control] account budgets to meet the requirements of internal management and reporting to the Government.

(b) Establishment and use of operating budgets should be done with caution.  Working against one plan and reporting progress against another is undesirable and the operating budget should not differ significantly from the [control] account budget in the performance measurement baseline. Operating budgets are intended to provide targets for specific elements of work where otherwise the targets would be unrealistic. They are not intended to serve as a completely separate work measurement plan for the contract as a whole.”

Current literature no longer specifically addresses Internal Operating Budgets (IOBs), but with the recent trend of contractors jumping to the OTB/OTS conclusion, it might be a better alternative to have individual instances of unrealistic budgets (or schedules) that do not otherwise push the total program to the need for a complete OTB and/or OTS implementation.

These could be good discussion topics for future AAP and DCMA meetings with industry representatives, to determine if there are ways to streamline the process, or at least reduce the amount of requests to implement Formal Reprogramming.  Variances are, after all, performance measurement indicators that should not just be routinely and artificially eliminated.

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Management Reserve; Comparing Earned Value Management (EVM) and Financial Management Views of “Reserves”

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Management Reserve & Earned Value ManagementPerhaps you have witnessed the collision of earned value management’s views on “management reserve” with the Chief Financial Officer (CFO) and the finance department’s views on “balance sheet reserves.” Most companies tend to organize EVM, the function, reporting to either the programs’ organization or to the finance organization. Either will work but either can fail if the two organizations do not understand the interest of the other.

In this article we will outline three areas. The first will be EVM and Management Reserve (MR). The second will be finance and balance sheet “contingencies, loss provisions, or reserves.” The third will compare the two views and identify where they are similar and where they differ.

We will use two terms for both EVM and Financial Management; “in play” and “on the sideline.” “In play” for EVM means that it is in your Performance Measurement Baseline (PMB) and Budget at Completion (BAC). “On the sideline” for EVM means “not in scope” therefore in MR. “In play” for financial management means recorded on the balance sheet (e.g.: current liability; an accrued liability). “On the sideline” for financial management means not recorded on the balance sheet, because it is more likely than not that a liability has been incurred.   If material, however, it will likely be disclosed in the notes to the financial statements, even if it is not recorded on the balance sheet.

 

Earned Value Management and Management Reserve

A program manager and his or her team must deal with – mitigate – risk or be consumed by those risks as they become issues. There are two types of risks, known and unknown. The known risks are entered into a risk register, and their likelihood and consequence are determined. Mitigation for those known risks is done at the activity level in a program’s Integrated Master Schedule (IMS) (Planning and Scheduling Excellence Guide — PASEG page 141, ¶ 10.3.1). Mitigation of known risks is part of the PMB (in the BAC) and is therefore “in play.”

The second type of risk – unknown or unknowable risks – are covered by management reserve if within the Scope of Work (SOW) of the existing contract. If contractor and customer conclude that the realized risk is outside the existing contract, then an Engineering Change Proposal (ECP) would likely be created by the contractor; and a contract modification would be issued by the authorized customer contracting officer if they agreed.   The program manager should ask this question of his team: what work is “at risk” and what work is not “at risk?” Does labor or material present more risk? Management reserve “is an amount of the overall contract budget held for management control purposes and for unplanned events” (Integrated Program Management Report–IPMR DI-MGMT-81861 page 9, ¶ 3.2.4.6). Management reserve is “on the sidelines.” MR has no scope. MR is not earmarked. MR stands in waiting.

 

Earned Value Management Reserve (MR) Compared To Financial Management “Contingency”

Because the audience reading this blog is most likely from the EVM community, I’ll offer a Financial Management example of a company that faces many risks and must manage those risks or be consumed by them. Altria Group, Inc. and Subsidiaries (stock symbol: MO) are in the tobacco, e-Vapor and wine business. Altria’s history clearly shows that the company measures and successfully mitigates the risks they face. Altria faces a blizzard of litigation each year and must protect its shareholders from that risk. So how does Altria manage known risks (mostly from litigation) and how does Altria handle unknown risks?

Altria is a publicly traded company and its annual report (10K) is available on-line to the public. This data is from their 2014 annual report.

I am an MBA, not a CPA, so I’ll stick to Altria’s 2014 balance sheet. For those not familiar with financial statements, a balance sheet has on its left hand side all of a company’s assets – what the company owns and uses in its business (current assets = cash, accounts receivable, inventory; long term assets = property, plant and equipment). The right hand side of a company’s balance sheet shows current and non-current liabilities and shareholders’ equity. The top right hand side of the balance sheet includes current and non-current liabilities (accounts payable, customer advances, current and long-term debt, and accrued liabilities like income taxes, accrued payroll and employee benefits, accrued pension benefits and accrued litigation settlement costs) and the bottom of the right hand side of the balance sheet includes shareholders’ equity consisting of common and preferred stock, paid in capital and retained earnings.

Altria’s 2014 annual report shows under current liabilities; accrued liabilities; settlement charges (for pending litigation Contingency note # 18) a value of $3.5 billion dollars. The 2013 amount was $3.391 billion dollars.

So Altria has “in play” $3.5B for litigation for 2014. In financial terms, Altria has recorded $3.5 billion in expense related to the litigation, probably over several years as it became more likely than not that a liability had been incurred and was reasonably estimable. In EVM terms Altria has $3.5B in their baseline, or earmarked, or in scope for litigation (court cases).

What happens if Altria ultimately has more than $3.5B in litigation settlement costs? What does Altria have waiting on the “sidelines” to cover the unknown risks? Essentially Altria has on its balance sheet waiting “on the sidelines” $3.321 billion in cash and the ability to borrow additional funds or perhaps to sell additional shares of stock to fund the settlement costs. In EVM terms Altria has $3.5B in its baseline (on its balance sheet) to manage the risks associated with litigation. Altria’s market capitalization at the market close on May 17, 2015 was $52.82 billion and its 2014 net revenues were $24.522 billion. It is reasonable to understand that Altria has more than enough MR.

 

Differences Between EVM MR and Financial Management Balance Sheet Reserves

In EVM, MR is only released to cover unplanned or unknown events that are in scope to the contract but out-of-scope to any control account. A cost under-run is never reversed to MR, and a cost over-run is never erased with the release of MR into scope.

In industry in general, and Altria in particular, if the “in play” current liability for settlement charges of $3.5B are not needed (an under-run), then Altria will reverse a portion of the existing accrued liability into income, thereby improving profitability. If Altria’s balance sheet reserve of $3.5B is insufficient, then Altria’s future profits will be reduced as an additional provision will be expensed to increase the existing reserve (an over-run).

[Humphreys & Associates wishes to thank Robert “Too Tall” Kenney for authoring this article.]

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Earned Value Management | Integrated Program Management Report (IPMR) XML Electronic Submittals

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One of the major changes in the 2012 IPMR Data Item Description (DID) was the requirement to use the DoD-approved XML schemas and guidelines to electronically submit formats 1 through 4, 6, and 7. The DoD-approved XML schemas were developed under the auspices of the United Nations Centre for Trade Facilitation and Electronic Business (UN/CEFACT), a formal international organization for establishing electronic business standards.  The DoD-approved XML guidelines are the Data Exchange Instructions (DEIs) or business rules for using the UN/CEFACT XML schemas to support the data requirements in the IPMR DID.  This XML electronic submittal format replaces the ANSI X12 Electronic Data Interchange (EDI) transaction sets 839 and 806 found in the previous reporting DIDs, the 2005, DI-MGMT-81466A, Contract Performance Report (CPR) and the 2005, DI-MGMT-81650, Integrated Master Schedule (IMS).

The purpose of using a software vendor neutral international standard to submit data to the DoD was to eliminate the need for any specific toolset or proprietary database at either end.  Contractors can use their toolset of choice or internally developed applications to produce the XML instance files and electronically submit the data. For the various DoD end-users, they can use their toolset of choice or internally developed applications to read the XML data for their use and analyses.

The business owner for the DoD IPMR Data Exchange Instructions is the OSD Office of Performance Assessments and Root Cause Analyses (PARCA), Earned Value Management (EVM) Division (https://www.acq.osd.mil/evm). The electronic submittals are designed to support the OSD EVM Central Repository (https://dcarc.cape.osd.mil/EVM/EVMOverview.aspx), a joint effort between the Defense Cost and Resource Center (DCARC) and OUSD/AT&L, managed by PARCA.  The EVM Central Repository provides a secure centralized reporting, data collection and distribution of EVM data environment for the DoD acquisition community.

There are a number of UN/CEFACT XML related resources available to contractors, software vendors, and government users on the DCARC EVM Central Repository web site.

  • Select the UN/CEFACT XML navigation option to download the base UN/CEFACT XML schemas as well as the Data Exchange Instructions for the IPMR formats. There are three primary DEIs. One for Formats 1 through 4 (can include Format 5 data as an option), one for Format 6 (the IMS), and one for Format 7 (time phased historical data). Also on this web page is a link for a digital file signing tool; this works as an outer envelope that contractors can use to digitally sign and secure an XML instance file submission to the EVM Central Repository.
  • Select the EVM Tools navigation option to download the XML instance file IPMR Schema/DEI Checker or XML instance file viewers. The schema/DEI checker can be used to verify a given XML instance file conforms to the basic XML schema requirements as well as the business rules defined in the DEIs.  The XML instance files viewers can be used to read and display the XML data content in a more human friendly format.

A number of the commercial off the shelf (COTS) software vendors have submitted their IPMR outputs for testing to the EVM Central Repository to verify their XML outputs can pass the Central Repository data submission validation process. A number of contractors also tested outputs produced from their internal application systems (no COTS tool was used). This testing was part of the implementation verification process for completing the Data Exchange Instructions. To confirm a software vendor has successfully completed the process to verify their tool-set outputs can be successfully read and uploaded to the Central Repository, send an email to the EVM Contact for PARCA listed on the DCARC EVM Central Repository web site (Contact Us navigation link).

PARCA has also recently taken ownership of the XML schema and DEI Change Control Board (CCB) and related process. The intent is to use the PARCA Issue Resolution process (https://www.acq.osd.mil/evm/ir/index.shtml) for software vendors, contractors, or other end users to submit change requests for the base UN/CEFACT XML schemas or IPMR Data Exchange Instructions.

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DoD Earned Value Management System Interpretation Guide | EVMSIG

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The updated DoD Earned Value Management System Interpretation Guide (EVMSIG), dated February 18, 2015 was released in March, 2015.

This DoD update, per the GAO, focuses on “(1) problems facing the cost/schedule control system (CS2) process; (2) progress DOD has made with reforms; and (3) challenges DOD faces in fostering and managing potentially significant changes”.

The update commences with:

EVMSIG INTRODUCTION

1.1 Purpose of Guide

Earned Value Management (EVM) is a widely accepted industry best practice for program management that is used across the Department of Defense (DoD), the Federal government, and the commercial sector. Government and industry program managers use EVM as a program management tool to provide joint situational awareness of program status and to assess the cost, schedule, and technical performance of programs for proactive course correction. An EVM System (EVMS) is the management control system that integrates a program’s work scope, schedule, and cost parameters for optimum program planning and control. To be useful as a program management tool, program managers must incorporate EVM into their acquisition decision-making processes; the EVM performance data generated by the EVMS must be timely, accurate, reliable, and auditable; and the EVMS must be implemented in a disciplined manner consistent with the 32 EVMS Guidelines prescribed in Section 2 of the Electronic Industries Alliance Standard-748 EVMS (EIA-748) (Reference (a)), hereafter referred to as “the 32 Guidelines.”

The DoD EVMS Interpretation Guide (EVMSIG), hereafter referred to as “the Guide”, provides the overarching DoD interpretation of the 32 Guidelines where an EVMS requirement is applied. It serves as the authoritative source for EVMS interpretive guidance and is used as the basis for the DoD to assess EVMS compliance to the 32 Guidelines in accordance with Defense Federal Acquisition Regulation Supplement (DFARS) Subpart 234.2 and 234.201 (References (b) and (c)). The Guide provides the DoD Strategic Intent behind each guideline as well as the specific attributes required in a compliant EVMS. Those attributes are the general qualities of effective implementation that are tested in support of determining EVMS compliance as it relates to the 32 Guidelines. As applicable, the DoD Strategic Intent section may clarify where differences in guideline interpretation exist for development and production type work. DoD agencies and organizations charged with conducting initial and continuing EVMS compliance activities will establish amplifying agency procedures and/or guidance to clarify how they are implementing this Guide to include the development of evaluation methods for the attributes associated with each of the 32 Guidelines.

1.2 EVM Policy

The Office of Management and Budget Circular No. A-11 (Reference (d)), the Federal Acquisition Regulation (FAR) Subpart 34.2 and Part 52 (References (e) through (h)) require federal government agency contractors to establish, maintain, and use an EVMS that is compliant with the 32 Guidelines on all major capital asset acquisitions. Based on these federal regulations and the DoD Instruction 5000.02 (DoDI 5000.02) (Reference (i)), the DoD established the Defense Federal Acquisition Regulation Supplement (DFARS) 234.201 (Reference (c)), which prescribes application of an EVMS, via the DFARS 252.234-7002 EVMS clause (Reference (j)). When EVM reporting is contractually required, the contractor must submit to the government an Integrated Program Management Report (IPMR) (DI-MGMT-81861) (Reference (k)) to report program cost and schedule performance data. The IPMR is being phased in to replace the Contract Performance Report (CPR) (DI-MGMT-81466) and the Integrated Master Schedule (IMS) (DI-MGMT-81650). Hereafter, for simplicity purposes, the term “IPMR” is used to reference legacy or current CPR/IMS DIDs. There are times in this Guide when the IMS reference is to an output of the contractor’s internal management system, i.e., a work product, which may not be referred to in the same context as the IPMR. [The full EVMSIG update is found here.]

Furthermore, also in March, 2015 the GAO released its “Report to the Committee on Armed Services, House of Representatives: Defense Acquisition | Better Approach Needed to Account for Number, Cost, and Performance of Non-Major Programs”.

An overview:

The Department of Defense (DOD) could not provide sufficiently reliable data for GAO to determine the number, total cost, or performance of DOD’s current acquisition category (ACAT) II and III programs (GAO-15-188 “Better Approach Needed to Account for Number, Cost, and Performance of Non-Major Programs” overview). These non-major programs range from a multibillion dollar aircraft radar modernization program to soldier clothing and protective equipment programs in the tens of millions of dollars. GAO found that the accuracy, completeness, and consistency of DOD’s data on these programs were undermined by widespread data entry issues, missing data, and inconsistent identification of current ACAT II and III programs. See the figure below for selected data reliability issues GAO identified. [The full GAO-15-188 document is found here.]

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