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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Variance Analysis, Corrective Action Plans, Root Cause Analysis

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Variance Analysis “provides EVMS contract management with early insight into the extent of problems and allows corrective actions to be implemented in time to affect the future course of the program.” [NDIA ANSI EIA 748 Intent Guide] Department of Defense Data Item Descriptions: DI-MGMT-81861, Integrated Program Management Report (IPMR) paragraphs 3.6.10xx; DI-MGMT-81466A, Contract Performance Report, paragraph 2.6.3; and DI-MGMT-81650, Integrated Master Schedule (IMS) — paragraph 2.5 — all require analysis for significant variances including cause, impact and corrective action plans.  By comparing the performance against the plan, it is possible to make mid-course corrections which assist completion of the project on time and within the approved budget. The Variance Analysis Report (VAR) is a “living, working document to communicate cause, impact and corrective action”. [See: Chapter 35 Variance Analysis and Corrective Action, Project Management Using Earned Value, Humphreys & Associates, page 707.] Well-written variance analyses should answer the basic questions of why, what and how.

Cause is also known as root cause, nature of the problem, problem statement, issue, or problem definition. Root cause is the fundamental reason for the problem. Root cause is required in order to take preventative corrective action. The explanation of the variance is broken down into each of its components: discuss schedule variances separately from cost variances; discuss labor separately from non-labor; discuss which portion of the variance was caused by efficiency (hours) and which portion was because of dollars (rates) or if the variance was driven by material discuss how much was because of price and how much was because of usage. For more information refer to Humphreys & Associates blog Variance Analysis-Getting Specific.

Once the root cause of the problem has been identified and described, the impact(s) on the project should be addressed. Identify impacts to customers, technical capability, cost, schedule (including when the schedule variance will become zero), other control accounts, program milestones, subcontractors, and the Estimate at Completion, including rationale.

A corrective action (CA) plan should be developed that describes the specific actions being taken, or to be taken, which includes the individual or organization responsible for the action(s). The corrective actions should be directly derived from root cause analysis and related to each identified root cause.   Results from previous corrective action plans should be included.  Occasionally, a successful plan will include interim modifications or fixes in the short term, with long term changes identified as well. When no corrective action for an overrun is possible, an explanation and EAC rationale should be included.  A corrective action log should be used that tracks the actions taken and the status of the corrective plan for each variance analysis cycle.  As was stated in the Humphreys & Associates article:  Corrective Action Response: Planning and Closure – Part 2 of 2  “It is critical that verification methods, objective measures, metrics, artifacts, and evidential products are identified that will verify that the corrective actions are effective.”  Corrective action plans based on clearly a defined root cause facilitates time management action and avoids the occurrence of repetitive problems.

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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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EVMS Variance Analysis — EVMS Analysis and Management Reports

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A Variance Analysis Report (VAR) that includes specific information about the cause, impact, and corrective action “provides management with early insight into the extent of problems and allows corrective actions to be implemented in time to affect the future course of the program” [reference: NDIA, IPMD EIA-748 (Revision D) EVMS Intent Guide]. Unfortunately, variance analysis is an easy target for criticism during EVMS reviews. There are many examples of inadequate variance analysis to choose from, but what they all have in common is the lack of specific information on the “why, what, how, when, and who” of any variance. The variance analysis reporting requirements are found in the EIA-748 (Revision D) Guidelines in Section IV., Analysis and Management Reports, Guidelines 22-27.

EIA-748 Guidelines
Section IV. Analysis and Management Reports
22 2-4a Control Account Monthly Summary, Identification of CV and SV
23* 2-4b Explain Significant Variances | Earned Value Management
24 2-4c Identify and Explain Indirect Cost Variances
25 2-4d Summarize Data Elements and Variances thru WBS/OBS for Management
26* 2-4e Implement Management Actions as Result of EVM Analysis
27* 2-4f Revise EAC Based on Performance Data; Calculate VAC


A VAR that includes specific information and data about a problem will allow management to make informed decisions and mitigate project risk. Getting specific about variance analysis reporting includes the following elements.

Overall:

  • Emphasis on the quantitative, not qualitative
  • Emphasis on the specific, not the general
  • Emphasis on significant problems, not all problems
  • Define abbreviations and acronyms at first use
  • The Control Account Manager (CAM) is the most knowledgeable person to write the variance analysis report but will need information from the business support team

Cause:

  • Isolate significant variances
  • Discuss cost and schedule variances separately
  • Clearly identify the reason (root cause) for the variance (ties to the corrective action plan)
  • Clear, concise explanation of the technical reason for the variance
  • Provide cost element analysis
    • Labor – hours, direct rates, skill mix, overtime (rate & volume)
    • Material – unplanned requirements, excess quantities, unfavorable prices (price & usage)
    • Subcontracts – changing requirements, additional in-scope work, schedule changes
    • Other Direct Costs – unanticipated usage, in-house vendor
    • Overhead (indirect) – direct base, rate changes
  • Identify what tasks are behind schedule and why

Impact:

  • Describe specific cost, schedule, and technical impact on the project
  • Project future control account performance (continuing problem)
  • Address effect on immediate tasks, intermediate schedules, critical path, driving paths, risk mitigation tasks
  • Describe erosion of schedule margin, impacts to contractual milestones or delivery dates, and when the schedule variance will become zero (this may only mean the work getting completed late (BCWPcum =BCWScum); and does not necessarily mean getting “back on schedule”
  • Describe any impact to other control accounts
  • Assess the need to revise and provide rationale for the Estimate at Completion (justify ETC realism – CPI to TCPI comparison, impacts of corrective action plan, risk mitigation, open commitments, staffing changes, etc.)
  • Note: If there is a root cause, there will be an impact. It could be related to cost, schedule, lessons learned to be applied to future activity, an update required to a process to support the corrective action or a re-prioritization of resources to meet a schedule.

Corrective Action Planning:

  • Describe specific actions being taken, or to be taken, to alleviate or minimize the impact of the problem
  • Include the individual or organization responsible for the required action
  • Include schedules for the actions and estimated completion dates (ECD)
  • If no corrective action is possible, explain why
  • Include results of corrective action plans in previous VARs.

Ask yourself, is the analyses presented in a manner that is understandable? Does the data support the narrative? Does the variance explanation provide specifics of:

why” the problem occurred,
what” is impacted now or in the future,
how” the corrective action is being taken,
when” the corrective actions will occur,
when” the schedule variance will become zero, and/ or the work gets “back on schedule”
who” is responsible for implementing the corrections?

Remember, a well-developed Variance Analysis Report can reduce the risk of a Corrective Action Request (CAR) during an EVMS review.

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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-15-188Better Approach Needed to Account for Number, Cost, and Performance of Non-Major Programsoverview). 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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EVMS compliance: Material Transfers and Loan/Paybacks

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Earned Value Management System (EVMS) compliance | Material Transfers and Loans/Paybacks

In a high rate production environment, it is not unusual for different Contract Lot Buys to have demands for the same required parts. Circumstances driven by delivery schedules, fee incentives, national priorities, or quality issues will prioritize the demand for these common parts. Companies will be challenged to respond to these dynamics while satisfying contractual requirements and continuing to remain Earned Value Management System (EVMS) compliant. A documented Material Transfer and Borrow and Payback (e.g., TBLP) policy/procedure describing a disciplined, auditable approach is a mandatory prerequisite for EVMS project managers.

Material Management and Accounting System (MMAS)

There are a number of applicable Government documents that come into play but none more important than the Material Management and Accounting System (MMAS). It is a DoD Policy (242.7202) that contractors have a MMAS that:

(1) Reasonably forecasts material requirements
(2) Ensures the cost of purchased and fabricated material charged or allocated to a contract are based on valid time-phased requirements
(3) Maintains a consistent, equitable, and unbiased logic for costing of material transactions.

MMAS Standards 6, 7 and 8 are especially apropos to material transfers and loan/paybacks:

• MMAS Standard 6 (Material Transfers) requires that the contractor’s policies and procedures provide detailed descriptions of circumstances which will result in manual or system generated transfers of parts.
• MMAS Standard 7 (Material Costing) requires that the contractor’s system transfer parts and associated costs within the same billing period or use an ACO approved “Loan/Payback” technique.
• MMAS Standard 8 (Inventory Allocations) requires that the contractor’s system handle allocations of common inventory in such a manner as to preclude improper allocation and costing of allocations.

Material Transfer versus Loan/Payback

For a number of reasons, a material transfer involves the most problematic issues for accommodating changing demands and priorities for common parts:
• Transfer costs are based on labor, material and applicable burdens when originally incurred and not based on the year when they are physically transferred (i.e. 2010 costs vs. 2014 costs). Related funding issues may also surface (requesting 2014 funding to ‘build’ a 2010 requirement in 2014).
Replacement costs will, in most cases, be at a higher value and there may be a potential schedule impact; both represent negative impacts to the customer.
• Previously reported Budgeted Cost for Work Performed (BCWP) and Actual Cost of Work Performed (ACWP) for work already accomplished will be impacted.
• Potential for inadvertently gaining a cost benefit when transfers are made between a Cost Plus and Fixed Price contract.
A transfer approach should only be considered when there is no replenishment currently in the procurement system. If there is a replenishment currently in the ‘pipeline’ then a loan/payback approach should be used as this will result in no cost transfer.
Under a loan/payback scenario, a part is moved temporarily from the contract but the cost of the part remains on the contract. As noted earlier, contractor procedures for the loan/pay-back technique must be approved by the Administrative Contracting Officer (ACO). Per Defense Contract Audit Agency (DCAA), when the technique is used, the contractor must have controls to ensure that:
• Parts are paid back expeditiously.
• Procedures and controls are in place to correct any over-billing that might occur.
• Monthly, at a minimum, identify the borrowing contract and the date the part was borrowed.
• The cost of the replacement part is charged to the borrowing contract.
Material Management and planning within an EVMS environment is quite challenging. Thankfully, there are a number of Earned Value Management Systems software programs available to assist contractors in meeting and managing this challenge.

Consider Humphreys & Associates to assist you in guiding your efforts in this complex endeavor, to ensure a firm foundation is established that meets or exceeds your material management needs.

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