Formal Reprogramming

Formal Reprogramming: OTB or OTS Best Practice Tips

By Humphreys & Associates / September 1, 2023 / Corrective Action, Corrective Action Request, Formal Reprogramming, Over Target Baseline (OTB), Over Target Schedule (OTS)

Corrective Action, Corrective Action Request, Formal Reprogramming, Over Target Baseline (OTB), Over Target Schedule (OTS)

Formal Reprogramming: OTB or OTS Best Practice Tips

As a result of an Earned Value Management System (EVMS) compliance or surveillance review, the Defense Contract Management Agency (DCMA) or DOE Office of Project Management (PM-30) may issue a corrective action request (CAR) to a contractor. H&A earned value consultants frequently assist clients with developing and implementing corrective action plans (CAPs) to quickly resolve EVMS issues with a government customer.

A recent trend our earned value management consultants have observed is an uptick in the number of CARs being issued related to over target baselines (OTB) and/or over target schedules (OTS). On further analysis, a common root cause for the CAR was the contractors lacked approval from the contracting officer to implement the OTB and/or OTS even though they had approval from the government program manager (PM).

So why was a CAR issued? It boils down to knowing the government agency’s contractual requirements and EVMS compliance requirements.

What is an OTB/OTS and when it is used?

During the life of a contract, significant performance or technical problems may develop that impact schedule and cost performance. The schedule to complete the remaining work may become unachievable. The available budget for the remaining work may become decidedly inadequate for effective control and insufficient to ensure valid performance measurement. When performance measurement against the baseline schedule and/or budgets becomes unrealistic, reprogramming for effective control may require a planned completion date beyond the contract completion date, an OTS condition, and/or a performance measurement baseline (PMB) that exceeds the recognized contract budget base (CBB), an OTB condition.

An OTB or OTS is a formal reprogramming process that requires customer notification and approval. The primary purpose of formal reprogramming is to establish an executable schedule and budget plan for the remaining work. It is limited to situations where it is needed to improve the quality of future schedule and cost performance measurement. Formal reprogramming may be isolated to a small set of WBS elements, or it may be required for a broad scope of work that impacts the majority of WBS elements.

Formal reprogramming should be a rare occurrence on a project and should be the last recourse – all other management corrective actions have already been taken. Typically, an OTB/OTS is only considered when:

The contract is at least 35% complete with percent complete defined as the budgeted cost for work performed (BCWP) divided by the budget at completion (BAC);
Has more than six months of substantial work to go;
Is less than 85 percent complete; and
The remaining management reserve (MR) is near or equal to zero.

A significant determining factor before considering to proceed with a formal reprogramming process is the result from conducting a comprehensive estimate at completion (CEAC) where there is an anticipated overrun of at least 15 percent for the remaining work.

When an OTB is approved, the total allocated budget (TAB) exceeds the CBB, this value referred to as the over target budget. Figure 1 illustrates this.

Before Over Target Baseline — *Figure 1 – Over Target Baseline Illustration*

When an OTS is approved, the same rationale and requirements for an OTB apply. The planned completion date for all remaining contract work is a date beyond the contract completion date. The purpose of the OTS is to continue to measure the schedule and cost performance against a realistic baseline. The process must include a PMB associated with the revised baseline schedule. Once implemented, the OTS facilitates continued performance measurement against a realistic timeline.

Contractual Obligations

An OTB does not change any contractual parameters or supersede contract values and schedules. An OTS does not relieve either party of any contractual obligations concerning schedule deliveries and attendant incentive loss or penalties. An OTB and/or OTS are implemented solely for planning, controlling, and measuring performance on already authorized work.

Should you encounter a situation where it appears your best option is to request an OTB and/or OTS, the DoD and DOE EVMS policy and compliance documents provide the necessary guidance for contractors. It is imperative that you follow agency specific guidance to prevent being issued a CAR or your OTB/OTS request being rejected.

DoD and DOE both clearly state prior customer notification and contracting officer approval is required to implement an OTB and/or OTS. These requirements are summarized the following table.

Reference	DoD/DCMA¹	DOE
Regulatory	DFARS 252.234-7002 Earned Value Management System “(h) When indicated by contract performance, the Contractor shall submit a request for approval to initiate an over-target baseline or over-target schedule to the Contracting Officer.”	Guide 413.3-10B Integrated Project Management Using the EV Management System 6.1.2 Contractual Requirements. “…if the contractor concludes the PB TPC and CD-4 date no longer represents a realistic plan, and an over-target baseline (OTB) and/or over-target schedule (OTS) action is necessary. Contracting officer approval is required before implementing such restructuring actions…” Attachment 1, Contractor Requirements Document “Submit a request for an Over-Target Baseline (OTB) or Over-Target Schedule (OTS) to the Contracting Officer, when indicated by performance.”
EVMS Compliance²	Earned Value Management System Interpretation Guide (EVMSIG)³ Guideline 31, Prevent Unauthorized Revisions, Intent of Guideline “A thorough analysis of program status is necessary before the consideration of the implementation of an OTB or OTS. Requests for establishing an OTB or an OTS must be initiated by the contractor and approved by the customer contracting authority.	EVMS Compliance Review Standard Operating Procedure (ECRSOP), Appendix A, Compliance Assessment Governance (CAG) Subprocess G. Change Control G.6 Over Target Baseline/Over Target Schedule Authorization “An OTB/OTS is performed with prior customer notification and approval.” See Section G.6 for a complete discussion on the process.
Contractor EVM SD⁴	DCMA Business Process 2 Attachment, EVMS Cross Reference Checklist (CRC), Guideline 31. “b. Are procedures established for authorization of budget in excess of the Contract Budget Base (CBB) controlled with requests for establishing an OTB or an OTS initiated by the contractor, and approved by the customer contracting authority?”	DOE ESCRSOP Compliance Review Crosswalk (CRC), Subprocess Area and Attribute G.6 “Requests for establishing an OTB or an OTS are initiated by the contractor and approved by the customer contracting authority.”

Notes:

When DoD is the Cognizant Federal Agency (CFA), DCMA is responsible for determining EVMS compliance and performing surveillance. DCMA also performs this function when requested for NASA.
Along with the related Cross Reference Checklist or Compliance Review Crosswalk, these are the governing documents the government agency will use to conduct compliance and surveillance reviews.
For additional guidance, also see the DoD EVM Implementation Guide (EVMIG) , Section 2.5 Other Post-Award Activities, 2.5.2.4 Over Target Baseline (OTB) and Over Target Schedule (OTS). The EVMIG provides more discussion on the process followed including the contractor, government PM, and the contracting authority responsibilities.
Your EVM System Description (SD) should include a discussion on the process used to request an OTB/OTS. The EVM SD content should be mapped to the detailed DCMA EVMS guideline checklist or the DOE Compliance Review Crosswalk (subprocess areas and attributes) line items.

Best Practice Tips

The best way to avoid getting a CAR from a government agency related to any OTB or OTS action is to ensure you have done your homework.

Verify your EVM SD, related procedures, and training clearly defines how to handle this situation. These artifacts should align with your government customer’s EVMS policy and regulations as well as compliance review guides, procedures, and checklists. Be sure your EVM SD or procedures include the requirement to notify and gain approval from the government PM and contracting officer, as well as what to do when the customer does not approve the OTB or OTS. Also discuss how to handle approving and managing subcontractor OTB/OTS situations; the prime contractor is responsible for these actions. Your EVMS training should also cover how to handle OTB/OTS situations. Project personnel should be aware of contractual requirements as well as your EVMS requirements and be able to demonstrate they are following them.
Maintain open communication with the customer. This includes the government PM as well as the contracting officer and any other parties involved such as subcontractors. Requesting an OTB or OTS should not be a surprise to them. Verify a common agreement has been reached with the government PM and contracting officer that implementing an OTB or OTS is the best option to provide visibility and control for the remaining work effort.
Verify you have written authorization from the government PM and the contracting officer before you proceed with implementing an OTB or OTS. You will need this documentation for any government customer EVMS compliance or surveillance review. Your baseline change requests (BCRs) and work authorization documents should provide full traceability for all schedule and budget changes required for the formal reprogramming action.

Does your EVM SD or training materials need a refresh to include sufficient direction for project personnel to determine whether requesting an OTB or OTS makes sense or how to handle OTB/OTS situations? H&A earned value consultants frequently help clients with EVM SD content enhancements as well as creating specific procedures or work instructions to handle unique EVMS situations. We also offer a workshop on how to implement an OTB or OTS . Call us today at (714) 685-1730 to get started.

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Formal Reprogramming – What Happened?

By Humphreys & Associates / October 20, 2017 / CPR/IPMR, DCMA, Formal Reprogramming, Internal Operating Budgets (IOBs), IPMR, OBS, OTB, OTS, Over Target Baseline (OTB), Over Target Schedule (OTS), parca, wbs

CPR/IPMR, DCMA, Formal Reprogramming, Internal Operating Budgets (IOBs), IPMR, OBS, OTB, OTS, Over Target Baseline (OTB), Over Target Schedule (OTS), parca, wbs

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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