EVMS Compliance Review Series #1 – Prep for the DCMA 8-Step Review Process

by Humphreys & Associates on April 24, 2012


Updated November 7, 2017

 

This is the first topic in a series discussing the DCMA Compliance Review (CR) process. It is an update to the original series #1 Blog that was based on the instruction book from the DCMA Website that identified the “DCMA 16 Step EVMS Compliance Review Process.” It has been replaced by the DCMA’s “Earned Value Management System Compliance Reviews Instruction 208 (DCMA-INST 208)” that has refined the process to Eight (8) Steps. 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), this new 8 Step EVMS Compliance Review Process applies to you. See DCMA-INST 208 for a complete discussion of all the steps in that process.

As noted in DCMA-INST 208, the Compliance Review (CR) “primary objective is to assess the compliance of the contractor’s EVMS processes and implementation with the EIA-748…EVMS GLs in order to ensure that contractors use effective internal cost and schedule management control systems and that the government can rely on accurate, valid, reliable, timely, and auditable data produced by those systems.” A “Compliance Review” is a common term used to denote any type of formal EVM System review performed for determining compliance of the contractor’s EVMS. This includes the:

  • Validation Review (VR),
  • Implementation Review (IR), and
  • Review for Cause (RFC).

The 8 Step CR process described herein does not address the ongoing surveillance efforts covered by DCMA-INST 210, “Earned Value Management System Standard Surveillance Instruction.”

The figures below compare the compliance review process approach of the old 16 Steps to the new 8 Steps:

Table 1. EVMS 16 Step CR Process

Earned Value Management System Review Process

 

Table 2. EVMS 8 Step CR Process

 

Process Step Description
1 Notification and Data Call
2 Planning and the Data Analysis (DA)
3 Opening Meeting
4 Fieldwork
5 Communication
6 Report Writing
8 Close-Out

 

If you were to look at the details behind the 8 Step CR Process you would see that very little has actually been eliminated from the detailed 16 Step process:

  • Steps 1 through 5 have been grouped into the new Step 1.
  • Steps 6 through 9 and 11 are part of the new Step 2. The formal RA and Go/No Go are not mentioned, but are inherent in the planning of the CR on-site review (Opening Meeting).
  • Step 10, parts of Step 12, and Step 15 are part of the new Step 5 (Communication).
  • Step 12 is split between new Steps 3 and 4.
  • Step 13 is in the new Step 6.
  • Step 14 is contained in the new Step 7.
  • Parts of Steps 14, 15, and 16 are included in the new Step 8.

One notable change, although not really a step, is that DCMA has removed all lower level activities that previously involved DCAA. This included two coordination actions, incorporation of DCAA findings, and CAP closure.

A frequent and common question that H&A consultants are asked is how long it takes to complete the DCMA Compliance Review process. In all the years H&A has been in business, it has varied based on:

  • The current contractual environment,
  • DCMA process requirements, and
  • The resources DCMA has available to do compliance reviews.

In the past, a contractor with an aggressive EVMS implementation plan could complete the process in coordination with the DCMA in about 18 months.

It is a different story today. DCMA is short on the resources they need to do compliance reviews and they have been updating their processes and requirements. The result: it can take up to three years to complete the process. This can have serious implications in those instances where a contractor is contractually required to have a DCMA EVMS Letter of Acceptance in place for a project. In some instances, the contract may be near completion or already completed by the time DCMA sends off a notification letter to the contractor.

Comparison of the 16 Steps against the 8 Steps actually shows that the details of the original process have been re-packaged into the 8 Step process. This is sort of like the story you may have heard about the man who ordered a medium pizza for himself, and the pizza proprietor asked if he would like that cut into 8 pieces or 16 pieces. The man replied “You had better do 8 slices, I don’t think I can eat 16!”

So, in the 2014 Compliance Review Instruction (CRI) – 208 (and its March 7, 2017 Change 1 update), DCMA launched their new 8 Step Compliance Review Process that, on the surface, seemed to reduce the process by 50%. Unfortunately, the CRI has simply cut that “pizza” into 8 slices instead of 16, meaning that virtually the same process is required, but the steps that make it up now have more lower level steps involved than the original 16 steps had per step. The problem was not the number of steps, but the length of the process (the pizza itself!).

What do you do if you find yourself in this situation? One suggestion is to have a discussion with the Director of the EVMS Center to request a waiver from the system acceptance contractual requirement because the compliance review process cannot be completed before the contract completion date.

One critical implication is the 8 Step process assumes successful accomplishment of each step. Any failure along the way will extend the time it will take a contractor to attain acceptance of their system and implementation. A contractor must be fully prepared to prevent a repeat of any of the steps in the process. It is essential to do things right the first time to prevent further delays. This is a discussion for the next topic in this series – preparing for a Contractor Self-Assessment. While a self-assessment is no longer a formal step in the CR Process, it is still contained as a lower level activity in the new Step 1, Notification and Data Call.

Contact Humphreys & Associates for questions about preparing for a DCMA compliance review. Go to our Contact page or email us.

 

Printer Friendly Version

Previous post:

Next post: