Your company has just spent a year or more pursuing the EVM System Certification, going through the formal Compliance Review by the DCMA, and clearing the Corrective Action Requests identified during that review.  Finally, the company has received that coveted System Certification notification from the DCMA!  So, now the company is finally through with that process, right? 

Well… not exactly!

Now comes the really hard part – living up to that certification throughout the life of the contract(s). 

Can you lose DCMA System Certification?

All too often contractors, who have suffered through many months of trying to get their EVM Systems accepted by the government, have tended to let their guard down once certification is attained, letting their implementation of EVMS fall into disrepair.  Doing so can only end badly: poor or late data submittals, cost and/ or schedule surprises (overruns/ missed delivery dates, etc.), and generally unhappy customers.  When the customer is not happy, nobody is happy!  Failure to correct this situation on the company’s part could ultimately result in what is known as a Review For Cause conducted by the DCMA to determine if the company’s EVM Certification should be withdrawn.  Losing the EVMS Certification not only means the contractor can no longer claim in proposals that they have a certified EVMS, it can also cause a company several unwanted contractual, monetary, and reputation impacts – and the recertification process itself is no picnic either.

EVMS Business Practices

To help avoid the above unpleasant consequences, part of the DCMA’s EVMS review series includes ongoing Surveillance of a contractor’s EVM System, starting immediately after it has been certified.  The DCMA has a series of EVMS related Business Practices (BP) [updated May 2020]

• BP0 – Earned Value Management Systems-Overall guidance on DCMA EVMS assessments
  • BP1 – Pre-Award EVM System Plan Review -of contractor proposal for EVM compliance
  • BP2 – System Description Review –of contractors EVM System and related documents
  • BP3 – Program Support – DCMA’s general EVMS-related support (IBRs, data review, etc.)
  • BP4 – System Surveillance – post-EVMS ongoing review of continued EVMS compliance
  • BP5 – Review for Cause – to assess if an EVMS acceptance is to be withdrawn
  • BP6 – Compliance Review Execution – how a Compliance Review will be run

The focus of this article is BP4 – System Surveillance, but do note that there is also BP5 on conducting a Review For Cause (RFC) discussed briefly above.

The stated purpose of BP4 is that it: “Defines the process to evaluate contractor EVMS compliance through continuing surveillance.” 

Yes, this means it is a compliance review after a contractor has gone through their Compliance Review! The basic intent of this process is to keep some pressure on the contractor to make sure EVMS implementation remains high quality throughout the life of the contract.

Drive the Car

Using our building-a-car analogy from Part 1 of this series: we have designed and built our car and trained our people how to drive, so it is now time to DRIVE OUR CAR. If we do not maintain all the car’s systems properly we are likely to encounter a lot of warning indicator lights (poor performance). If we ignore those indicators, the car is likely to fail on us. If the car blows up, we may have to go through the whole car building process again.

The DCMA does not want a contractor’s EVM System to fall into disrepair either.  The Review For Cause (RFC) and overall recertification process is unpleasant for the DCMA, too. This is also why, unlike in the past, the EVMS Center team players for Surveillance reviews are pretty much the same ones who participated in the formal Compliance Review:

• Director, EVMS Center
• Group Lead, EVMS Center
• Team Lead, EVMS Center
• Team Member, EVMS Center

There will likely be fewer Team Members than were on the full Compliance Review team, but as you can see, the Leaders will be the same. The DCMA has been placed in charge of all surveillance activities, and Government Program if team members may be needed to augment the DCMA Team.

The Compliance Review (CR) process [BP6] consisted of 5 phases:

1. Plan
2. Execute Pre-Event activities
3. Execute – CR Onsite Activities
4. Report
5. Closing Actions

The Surveillance Review process [BP4], however, is comprised of only 3 phases:

1. Plan
2. Conduct
3. Report

The Surveillance Process is primarily conducted off-site, although some on-site interviews could be required if follow-up action is required because potential non-compliances exist as a result of the data analysis.  Typically, on-site actions would be interviews of CAMs or other contractor personnel.

Plan phase:

• Identify Requirements:  The EVMS Center Team Member works with the contractor’s EVMS point of contact to establish or update an Annual EVMS Surveillance Plan (SP).  They will jointly identify the contracts with EVMS requirements that may be subject to the surveillance activities, which may include existing contracts, new contracts, modifications to existing contracts, or even subcontracts with EVMS requirements.
• Risk Assessment: The EVMS Center Team Member will use a Risk Assessment Worksheet to “identify a population of representative contracts” against which the DCMA can test all aspects of the system.
• Create/ Update the Surveillance Plan (SP):  Before the start of each Fiscal Year, the EVMS Center Team Member will create or update the Surveillance Plan to document the surveillance activities using all the candidate contracts for the upcoming Fiscal Year.  The Plan is to ensure the complete evaluation of all 32 Guidelines for the site’s EVMS over a 3-year cycle to support the site re-certification.  This evaluation includes data analysis and the DCMA EVMS Compliance Metrics (DECM) for the particular Guidelines identified in the plan for each surveillance event.  This means that over the 3-year cycle 10 or 11 Guidelines must be evaluated each year in order to cover the 32 Guidelines.  This Surveillance Plan must be reviewed and approved by the EVMS Center Group Lead.

Conduct Phase:

• Data Call:  At least 45 days prior to each surveillance event, data will be required based on the specific Guidelines being covered in that particular event.  This will typically be a subset of the Data Call required for the Compliance Review.
• Execute Data Analysis:  Using data provided in the Data Call, the Team Member will use the tests identified in the DECM for the Guidelines being reviewed in each surveillance event.  The contractor should be running these metric checks as part of their own self-evaluation, and the EVMS Center Team Member can use those results in addition to running independent calculations on those metrics.  This is often done if Joint Surveillance is used by the DCMA, but the DCMA Team Member must still perform independent assessments and document results of those checks.
• Evaluate Results:  Identify potential compliance issues resulting from data analysis metric tests.
• Follow-up:  Discuss issue with the contractor, get more data samples to test further, conduct interviews of contractor personnel, as needed.  Convey data analysis concerns to the contractor before the surveillance event.
• Closeout:  To close out the action, one of these will take place:
• Accept as the correct execution of the contractor system
• Highlight as a risk for future surveillance
• Issue a Corrective Action Request (CARs)

The EVMS Center Team Member provides an out brief at the end of the surveillance event.

Report Phase:

• Document results:  summarize/ provide the following:
• A report with an Executive Summary
• Results from all metrics evaluated
• Follow-up actions taken on metric results
• Summary of CARs issued/ observations made
• Summary of contractor internal CARs/ findings
• Summary of reasons for a Risk Assessment/ Surveillance Plan update (if applicable)
• Identified risks for evaluation at future surveillance events
• CAR/ Corrective Action Plan (CAP) status for the site

The EVMS Center Team Member identifies any significant deficiencies to the Team Lead, and then (as necessary) to the Group Lead and the Director for concurrence and processing.  A letter will be issued to the Contracting Officer (CO) notifying them of the completion of the 3-year EVMS compliance assessment, current system status, and any outstanding Corrective Action Requests (CARs) or Corrective Action Plans (CAPs).  The EVMS Center Team Member enters the approved plans/ reports to the Integrated Workflow Management System (IWMS) and for subsequent distribution to appropriate offices and the contractor (as required).

Compliance Review Support

As you can see, this seems almost as involved as getting ready for a full-up Compliance Review.  This is probably by design, since the DCMA wants to emphasize the importance of maintaining the EVM System in a compliant state for the life of the contract.  As a contractor, it is equally important to you because if your system application falls apart and you lose your EVMS certification (via BP5), the recertification process (BP6) starts all over again.

Humphreys & Associates has people ready to help you wade through the government requirements for EVMS certification, whether you are new to EVMS, or you are an experienced contractor needing help getting ready for a Compliance Review, System Surveillance, or even a Review For Cause.  We also have a wide range of training courses for beginners in EVMS or advanced courses for experienced Earned Value professionals.  We can also prepare your company for Surveillance, an IBR, an RFC, or even a full blown Compliance Review. Contact us today at (714) 685-1730 or e-mail us.