In general, IPMDAR data reporting requirements are based on contract structure and the need to effectively communicate the execution performance between the contractor and the program. While it can be sufficient to structure the reporting for a single data delivery package to represent the entire contract (or the total of the cost-plus CLINs), it is common for data reporting to the EVM-CR to be stratified by specific CLINs or collections of CLINs. Within the EVM-CR, this level of reporting below the contract is known as a “contract effort”. It is typical for a single contract to have multiple contract reporting efforts within the EVM-CR.
A secondary aspect of contract reporting structure is the EVM-CR notion of a “component effort”. Within a single contract or contract effort, it is possible (and not uncommon) to report a data package that reflects the total for the contract (or effort) and also report multiple, separate data packages that reflect subsets of the effort. For example, a single effort might reflect multiple CLINS (0001, 0002, & 0003) that in total reflect the LRIP 1 activities on a contract. In this case, if there is a desire for detailed-level performance reporting, it is possible to deliver a data package representing the LRIP 1 total as well as 3 separate packages for the components LRIP 1 CLIN 0001, etc.
Finally, within a single submission package it is possible to report CLIN traceability to CA level or WP level data, but not through an explicitly defined structure. As per the CPD File Format Specification, the data submission package is expected to have definitions of the WBS and OBS structures as well as a definition of control accounts (and work packages if required). There is no allowance for an explicit definition of a CLIN table. However, within the control account (and work package) definition table, there is a facility to allow for custom tags which was intended to be used for program specific needs. In particular, these tags can be used to identify which CLIN is associated with each control account.
The new IPMDAR does not deviate from or eliminate any previous need for a level of reconciliation between a monthly performance report (e.g. IPMDAR) and a quarterly funding report (e.g. CFSR). As guidance only, the IPMDAR that is performed with the same reporting period end date for a CFSR should contain the same "estimated price."
The IPMDAR DID is available for use on solicitations and requests for proposals (RFPs) with an earned value reporting requirement after 12 March 2020. The DID can also be applied to modified or existing contracts through a bi-lateral agreement between the government program office and the contractor. Changing an existing contract to the new IPMDAR is dependent on each situation. Switching may disrupt the comparison of historical data, the program business rhythm, and other analysis that may prohibit the move to the new standard. In other cases, a major contract modification may present a reasonable opportunity to go from prior reporting formats (CPR or IPMR) to the IPMDAR. Programs should follow their Service or Agency direction while balancing the benefits of updating against the disruption of the change.
1. DID Reference 2.4.2.3: " Tasks/Activities. Provide elements of work with duration, cost, logical relationships/dependencies, and resource requirements. " and 2.4.3.2 "Resource loading may be required as part of the Schedule in either the Native Schedule File, or both the SPD and Native Schedule File."
This seems to indicate that resource loading the IMS is required by the DID. However, directly loading resources in the IMS is not required, however, it could be as part of the negotiated CDRL between the contractor and the customer (Tailoring). If not directly loaded into the IMS, there should be a way to reconcile the discrete tasks in the IMS with the method that the contractor will use to time-phase their resource allocation if done outside the IMS.
2. DID Reference 2.4.2.1: "If a Statement of Work (SOW) or Integrated Master Plan (IMP) are used for vertical schedule integration, those references shall be provided in both the SPD and native schedule."
If you are going to use the SOW or IMP to vertically integrate the IMS, then the SOW or IMP references must by clearly indicated in the IMS. This is normally done through a designated custom field in the native schedule file and designated for conversion to the SPD.
3. DID Reference 2.4.2.21: "Schedule Risk Assessment (SRA). SRAs are required prior to an IBR, implementation of an OTB or OTS, as specified in the contract. The inputs (e.g., three-point estimates) from the most recent SRA shall be provided in the Native Schedule File submission. Results of the SRA shall be discussed in the Performance Narrative Report."
SRAs are a required part of the DID. Part of the intended purpose of this revision was to focus on forecast accuracy, and a Schedule Risk Assessment helps provide insight on the impact of risk to the schedule forecast data. The latest 3 point duration estimates (Minimum, Most Likely, Maximum) durations need to be designated in the schedule file, and the output of the SRA, including assumptions, distribution curve, probability histograms that support dates, and actions take to address risks that impact dates must be included in the Performance Narrative Report.
According to the DID, Schedule Risk Assessments (SRA) are required prior to an Integrated Baseline Review (IBR), implementation of an Over Target Budget (OTB) or Over Target Schedule (OTS), or as specified in the contract.
Please refer to DI-MGMT-81861B section 2.4.2.21 and Table 2.1 for more information regarding SRAs. Table 2.1 states that the Detailed Analysis (reporting aspect) of the SRA has to be monthly, unless otherwise noted in the CDRL.
There should be no change in how Prime contractors integrate/view data from the subcontractors from the IPMDAR DID viewpoint. Each Prime must follow their documented System Description and their EVM/IPM toolset. A few paragraphs from the DID are shown below:
A few paragraphs from the Implementation Guide are shown below:
The default reporting is "cumulative-to-date." The need to report "time-phased non-cumulative" is made available in the event of a catastrophic data loss or crash, as well as visibility into retroactive changes. This would allow a recreation of the historical record but is NOT recommended for monthly reporting due to massive data files on a recurring basis. If one were to desire this on a monthly basis, a statement of that request could be placed in Block 16 of the CDRL and reference the DID paragraph being tailored.
Originally when the IPMR was rolled out, it was the first major revision to data exchange reporting in many years. For the contract performance data, the IPMR was a significant change from the original EDI 839 format. Further, the IPMR added all new reporting requirements for schedule data and a new time-phased cost requirement (Format 7). Because of the significant nature of the change and because it was rolled out before tool vendors were involved in the planning, ADA (previously PARCA) felt it was a value to the stakeholders to provide EVM-CR testing of vendor test files in order to facilitate stakeholder evaluations of commercial tools.
With the IPMDAR, tool vendors have been engaged from the outset and the marketplace appears to be handling the need to inform the stakeholder community. While ADA does not anticipate the need to maintain/distribute a list of tested tools, the EVM-CR team is available to provide testing support for tool vendors that want to get an evaluation of submitted test files.
Some vendor tools have the ability to support the file structures now. Contractors need to coordinate with tool vendors to determine integration and validation timelines for consistent report production of compliant reports.
As with the IPMR, the ADA EVM-CR team has basic reader, validator, and data display/conversion tools available.
The use of the IPMDAR may be used on IDIQ contract with or without the EVMS clause on contract. The policy for placing the EVMS clause on contract of IDIQ type efforts remains the same and should be done in accordance with the current DoDI 5000.02 and 5000.85.
The IPMDAR requirement for final delivery submission by the 16th business day, was to allow the prime contractor to have sufficient time to integrate subcontractor data, as well as generate the variance analysis. An earlier date for the final delivery is possible. This can be coordinated and contractually obligated between the Government and prime contractor through the CDRL requirements.
Another option for IPMDAR reporting is the ability to provide incremental delivery of data. This would provide reviewers with the data trends at a timelier manner, with the assumption that not much will change from the incremental delivery to the final delivery on the 16th business day.
Deliveries will be posted in the EVM-CR and clearly marked as interim or final by the submitter. The revision of the submission workflow process in the EVM-CR will help make the entire process more efficient and intuitive.
The IPMDAR is stand-alone reporting as described in DI-MGMT-81861B. Other reporting similar or "associated," "companion," or "supplemental" data may be requested to enhance data analytics.
An Executive Summary template would be of benefit to all programs with an IPMDAR requirement and ADA will work to have it published within the Implementation & Tailoring Guide, either at initial release or shortly afterward.
In IPMDAR reporting, variance write-ups are part of the Performance Narrative Report submission and are independently delivered.
If the DOD is the lead agency in a partnership with other federal agencies, then the IPMDAR DID (DI-MGMT-81861B) shall be used to report supplier data.
Agencies outside of DoD can obtain an account in the EVM-CR in order to view and download the data.
The delivery of the IPMDAR can be put on contract with or without the DFARs Clause 252.234.7002. The Data Item Description (DID) (DI-MGMT-81861B) was established, coordinated and developed for use within the Department of Defense. Other Federal agencies may adopt this DID (DI-MGMT-81861B) and place it on their contracts if it fits their program management needs.
Work Package level reporting, while allowable by the DID, was introduced into the reporting structure to accommodate the automated testing of EIA-748 Guideline 27. Generally speaking, that level of reporting may be too low in the system structure to derive meaningful data and more importantly the explanation of variance. Programs should work with their supplier to obtain an appropriate level of data reporting that provides meaningful insight into the execution without going so far as to be overly burden the supplier and introduce unnecessary costs for reporting.
Data specifications, listed in the IPMDAR data exchange instructions, should satisfy DECM requirements.
Tailoring of the IPMDAR is encouraged. IPMDAR submissions can be tailored on the CDRL Form DD1423-1, Block 16. Tailoring of the IPMDAR can include, but is not limited to the following:
The DID allows for tailoring down to the Work Package level, but not lower.
We have certainly considered this issue. The IPMDAR data exchange formats allow for appropriate classification markings on submissions files. Commercial tool vendors already have tools that they make available in various classified environments. It would be expected that when the IPMDAR support is provided within the commercial tools used in the classified space, the stakeholder organizations would go through normal procedures to obtain the latest tool updates. However, there may be one area of confusion. The ADA-provided test/validation tools for free download off the ADA IPM public site are intended for unclassified data testing. Specifically, since the EVM-CR is only for UNCLASSIFIED data, our test tools currently available for download "reject" items that are not marked as UNCLASSIFIED. If desired, it would be possible to provide equivalent test tools specifically targeted for documents marked with other classifications.
The costs should be the same as current IPMR experiences indicate and the overall management of the data and information and the compliance rigor is unchanged by the reporting format (e.g. Datasets versus Human Readable Formats. However, from an industry perspective we believe, as most studies point out, that the driving costs for performance reporting lies within the written narratives.
There are multiple guides providing information on Earned Value Management for programs with Agile methodologies. The IPMDAR does not specifically address agile, nor does it specifically address any development, production, or sustainment methodologies. The IPMDAR is compatible with all methodologies that are being managed with earned value.
Earned Value Management (EVM) is a widely accepted industry best practice for program management, 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.
Earned Value Management (EVM) is one of the DoD’s and industry's most powerful program management tools. Government and industry program managers utilize EVM to assess cost, schedule, and technical progress on programs to support joint situational awareness and informed decision-making. To be effective, EVM practices and competencies must integrate into the program manager’s acquisition decision-making process. The data provided by the EVM System (EVMS) must be timely, accurate, reliable, and auditable. Industry must implement the EVMS in a disciplined manner consistent with the 32 Guidelines contained in the Electronic Industries Alliance Standard-748 EVMS (EIA-748).
The NDIA Integrated Program Management Division (IPMD) is the recognized body for subject matter expertise on EIA-748. The IPMD website hosts several guides that represent best practices in EVM application and implementation. In addition, the College of Performance Management (CPM) website contains a set of articles and presentations regarding EVM.
EVM and EVMS requirements are listed below:
FAR clauses should not be put on DoD contracts. The FAR allows for federal departments and agencies to use clauses that are substantially the same as the FAR clauses. The EVMS DFARS clauses are written to provide the amplifying policy and guidance for DoD contracts. In fact, Section 234.203, DFARS specifically states that the DFARS will be used instead of the FAR. For EVM, it should be noted that the FAR contains a clause for pre-award IBRs but the DFARS do not. Therefore, if a program manager elects to conduct a pre-award IBR on a DoD contract, he or she should include that requirement in the statement of work.
The EVMS FAR clauses are in FAR:
The application of updated DFARS clauses is not retroactive on a contract. However, new solicitations released after the update of a given clause are expected to include the latest version of the DFARS. Program managers are not precluded from imposing new or different EVM requirements on existing contracts if the benefits outweigh the costs. Remaining contract duration and estimated costs, as well as other risk factors, should be taken into consideration when determining whether to modify the EVM requirements on existing contracts. In addition, the costs associated with the modifications will be borne by the government.
Data for ACAT I programs with an EVM (IPMR and CFSR) requirement must be submitted directly tot he EVM-CR by the reporting contractor. The EVM-CR should be the sole addressee on the Contract Data Requirements Lists (CDRLs) for these reports. The use of UN/CEFACT format is required for all reports. See the documents below for additional information:
No, the DoD EVM policy does not mandate pre-award IBRs. The policy requires that IBRs be initiated as early as practicable and that the timing of the IBRs take into consideration the contract period of performance. The IBR process should be conducted no later than 180 calendar days (6 months) after: (1) contract award, (2) the exercise of significant contract options, and (3) the incorporation of major modifications. However, the policy does not prohibit the use of pre-award IBRs in situations where they may be appropriate and beneficial. If a program manager elects to conduct a pre-award IBR on a DoD contract, he or she should include that requirement in the statement of work.
In situations where the entire work scope is not known, the IBR can be conducted in stages. A review of the known work scope should be conducted within the 180 day window with a follow-up IBR scheduled at a later time for the work not yet completed in the context of the entire performance measurement baseline. As a rule of thumb, the 180 day IBR should run through the first major milestone for the program. Any IBR event increment should not be driven by definitization, but should represent the best time to hold the IBR to assess the plan for the work. A contract letter from the PMO to the contractor will be needed to detail the requirements.
EVM requirements do not change based on replanning, rebaselining, or any other formal reprogramming. EVM requirements can only be changed via a contract modification. The OTB/OTS guide details the implementation and reasoning for rebaselining and single point adjustments (SPA).
When determining the contract value for the purpose of applying the EVM thresholds, the total contract value in then-year dollars, including planned options placed on contract at the time of award, should be used.
Then-year dollars are current dollars that reflect the impact of inflation over time, just like the dollars in your wallet. Base-year dollars are constant dollars that reflect the cost of the program as if inflation had not occurred (the cost to acquire a multi-year system if you paid for it in advance in one specific year). The EVM application thresholds were changed from base-year dollars to then-year dollars because then-year dollars represent a more accurate measure of the value of contracts. Contracts are awarded in then-year dollars, which represent what the government has to pay. Base-year dollars are used primarily for cost estimating purposes and are not good indicators of current contract value. The threshold dollar values will be reassessed periodically and revised as necessary to keep pace with future inflation.
As noted, when determining the contract value for EVM thresholds, the total contract value including known contract options at the time of award, should be used to determine EVM applicability. If the options/changes were not known, the program manager is strongly encouraged to add or change the EVM requirements when modifying an existing contract to proceed to a subsequent acquisition phase, or in cases where the duration of the contract exceeds 12 months, the value of the contract reaches $50 million or greater, and/or the nature of the work imposes risk to the government. Note that the costs associated with the modifications will be borne by the government and that performance data prior to the EVM requirement may be incomplete or estimated.
The EVM policy applies to all cost or incentive type contracts, subcontracts, intra-government work agreements, and other agreements valued at or greater than $20 million.
Since a fixed price incentive contract is by definition an incentive contract, it requires the implementation of EVM if it is valued at or greater than $20 million.
Current DFARS Clauses:
Any program not under the requirements of the DFARS or DoDI 5000.02 is not subject to various requirements, including EVM/EVMS. However, in accordance with the direction in Office of Management and Budget (OMB) Circular A–11, Part 7, and the corresponding Capital Programming Guide, all major acquisitions with development effort, regardless of whether they have been designated as DoD acquisition programs, are subject to the overarching FAR EVM policy.
FFP contracts are not subject to EVM and EVMS requirements. If the risk warrants the need for EVM to manage the work scope, FFP may not be the appropriate contract type. Therefore, the use of EVM on FFP contracts continues to be limited to cases where the program manager believes there is significant schedule risk and/or concern about the impact of cost pressures on product or service quality. In these cases, the program manager should ask for a deviation from the program decision authority to implement EVM on individual FFP contracts.
No, the DoD EVM policy only appears to differ from the OMB policy. If the DoD policies on selecting contract type and applying EVM are followed, the instances of noncompliance with the OMB policy will be the exception not the rule. While the OMB policy does not exempt FFP contracts from the EVM requirements, OMB's focus is on development efforts in both the planning and acquisition phases. DoD does not as a matter of course use FFP contracts for development and integration efforts, which are inherently more risky to the government. (OMB also discourages the use of FFP contracts for development efforts.)
Therefore, in DoD the use of FFP contracts is typically limited to mature, lower risk production work, which uses means other than earned value to manage contract performance. Higher risk development work is usually accomplished with cost type contracts, which require EVM. Low rate initial production and early production contracts tend to be of the fixed price incentive type, which also require EVM. In order to preclude any disconnects with regard to the applicability of EVM based on contract type, DoD program managers need to adhere to the Department's policies on selecting contract type and applying EVM. Additionally, when a FFP contract is chosen for development work, the program manager needs to apply EVM to the contract and should request a waiver from the program decision authority to do so.
The contractor should not be prohibited from employing its EVMS if the use of EVM is an ingrained corporate process. DoD, however, would not typically require formal EVM requirements on contracts to which EVM is not being applied, such as FFP contracts. When the contractors EVMS is an ingrained corporate process and no reporting to DoD is required, DoD should incur little or no implementation costs associated with use of the contractors EVMS. In cases where there may be some minor costs, they should be negotiated up front with the contractor. Also, there are cases when the IPMR can be used to receive tailored cost and or schedule information without the formalized full EVM. In those scenarios, the tailored CDRL for the IPMR would be included in the contract package.
If a contract type is mixed, the EVM policy should be applied separately to the different parts (contract types). In other words, the use of EVM on any cost or incentive parts that are valued at $20 million or greater would be required but EVM would not be required on any FFP parts, unless the work involves development or integration effort.
As a rule, EVM is required on cost or incentive contracts valued at or greater than $20 million. However, the nature of the work associated with the contract is the main factor when determining EVM applicability. This means, efforts that are service oriented, sustainment, unplanned maintenance, or other “level of effort (LOE)” work generally should not have EVM applied. In the cases where the work scope doesn’t warrant EVM but the DFARS thresholds are met, a deviation is required per the guidance in the applicable Service’s DFARS supplements.
There may be times where a contract that would normally require EVM (based on contract size, type, etc) may wish to be exempt from the requirement due to unique circumstances. EVM deviations and waivers are a means for modification or removal of EVM requirements and/or reporting from a contract that otherwise would be required to apply them per the DFARS or DoD 5000. EVM deviations are the modification or removal of EVM/EVMS DFARS clauses from a contract, while waivers remove requirements levied by the DoDI 5000.85 for program management purposes, usually in the form of modifying EVM reporting beyond what the IPMDAR DID normally allows. If attempting to remove EVM from a contract entirely, a deviation and a waiver may both be required to ensure both DFARS and DoD 5000 requirements are covered. A deviation and/or waiver should be a high bar, requiring clear reasoning and substantiation, and a description of how the contract will be managed should the alteration be approved. If approved, the requirement removal or alteration is incorporated into the contract itself; most often this process occurs prior to contract award.
While EVM as a discipline is owned by ADA within OSD, ADA is not empowered to make waiver or deviation determinations itself. In most cases that authority has been delegated to the component acquisition executives (CAE), where each component has their own internal process for handling these cases managed by their project controls and contracting community. Requests for EVM deviations or waivers should be initiated and routed per component-specific processes:
In the limited cases where the authority rests with OSD, ADA manages this process. However, ADA has also been charged with performing reviews of waivers and deviations upon request and providing a formal recommendation as to whether a waiver or deviation might be appropriate in support of component processes. To request a recommendation, please submit the ADA EVM Deviation and Waiver Recommendation Request Form and supporting documentation including a statement of work, to the ADA IPM Division email.
If you have any further questions, including if you’re unsure who to reach out to within your agency, please don’t hesitate to contact us.
Yes, the EVM requirements flow down to the subcontractor if the subcontract is valued at or greater than $20 million. Subcontractors with contracts valued at or greater than $50 million are subject to the EVMS validation requirement. In accordance with the DFARS clauses, the prime contractor identifies the major subcontractors in its proposal. The government then determines, and specifies by name in the prime contract, which of those major subcontracts must comply with the EVM requirements.
No, the contract will be awarded in accordance with the rules of the organization receiving the transferred funds, and in accordance with the FAR as applicable.
Yes. The EVM thresholds and requirements apply to both domestic and foreign contractors and subcontractors. In fact, many foreign suppliers operate in countries that have EVM policies very similar to those of the United States, such as Canada, Australia, and the United Kingdom.
Yes, shaded areas on the Formats indicate no data should be placed in those cells. For management reserve (MR), data should be included in Section 6 (a), (b), and (c) Estimated Cost at Completion under the Management Estimate at Completion (1). As per the DID, the estimate at completion in column (15) would only be for work included in the Performance Measurement Baseline (PMB). Any impacts due to additional risk, management reserve, or higher level management knowledge would be included in Section 6 (1).
The requirement for an IMP has not changed. Both the IMP and the IMS continue to be important tools that provide significant assistance in the planning and scheduling of work efforts. The IMP is a contractual event-based plan consisting of a hierarchy of program events, with each event being supported by specific accomplishments and completion criteria. The IMS is a time-based schedule that flows directly from the IMP and provides the level of detail necessary for day-to-day program/contract execution. The IMS is typically requested through a CDRL based on Format 6 of the IPMR. A formal IMP requirement is not found in the IPMR but is recommended as good business practice by DoDI 5000.02.
The decision to impose any EVM requirement, including the IPMR Format 6 IMS requirement, on an existing contract must be made by formal contract modification. The modification should be made based on negotiations between the government and contractor and should be based on all relevant factors to include the dollar value and duration of the contract, the degree of risk, and the nature of the work. If a decision is made to modify the contract, keep in mind that the IMS can be tailored as appropriate within the bounds of the policy. Detailed guidance on tailoring the IMS can be found in the IPMR Implementation Guide.
No, the Format 6 of the IPMR does not prescribe a resource-loaded schedule, nor does it prohibit resource loading in those situations where it is appropriate and beneficial to do so. The XML requirement included with the IPMR DID does support the information if it is included in the XML submission of the Format 6.
The program manager is ultimately responsible for determining how EVM reporting will be tailored, but the degree of tailoring must be appropriate and allowable within the bounds of the EVM policy. The IPMR is highly tailorable and the IPMR Implementation Guide has information on tailoring aspects. For example, reporting frequency, submission dates, and level of detail can be negotiated. All relevant risk factors should be considered when determining the degree of tailoring that is appropriate.
The policy aims to link the cost and schedule reporting by requiring the submission of both reports any time EVM is required and mandating that a common work breakdown structure be used for both reports. The policy does not prescribe specific software applications.
