Hello. It’s been a while, hasn’t it? If you are one of the people who keep coming back to this site, to see if I’ve blogged anything new—or maybe to check out one of the far-too-many articles in the News Archive—then thank you. I’m writing this for you, because I have something to say.

I haven’t blogged about the problematic CAS cost impact guidance issued in late 2023 by DCAA and publicly endorsed by DCMA. If you’re dealing with that, you have my sympathies. And my apologies, because I was one of those who pointed out to DCAA that their then-current audit guidance didn’t comport with the 2015 Raytheon decision at the ASBCA. Well, I got what I wanted—and then some. DCAA updated their audit guidance and took that opportunity to take a little extra along the way. But I didn’t write about that because what can one do except hope that some contractor wronged by inapt audit guidance takes the DOD to court.

I haven’t blogged about recent CAS Board activity, because why get all hot and bothered about things that may never come to pass or things that may be overtaken by events (clears throat **Executive Order**). CAS 404, 408, 409 and 411 are in play at the CAS Board but, as most everyone knows, the Board is currently adrift, waiting for direction and, dare I say, leadership that is currently lacking. The many Staff Discussion Papers, Advance Notices of Proposed Rulemaking and Notices of Proposed Rulemaking may someday result in regulatory action. Maybe. But until then, it’s business as usual. So, I didn’t write about all that CAS stuff.

I haven’t blogged about the recently announced DCAA reorganization, which seems to affect only the very largest of DOD contractors, the ones that my friend John used to call “the Five Families.” And the auditors, of course. They are impacted. But the rest of us? Not so much. So what could I have said?

I haven’t blogged about cyber-security and the recent updates in requirements, nor have I blogged about CMMC and are you ready to be assessed? because, at this point, if you don’t know you have already lost the race. I mean, it’s not like I have ignored the topic. For more than a decade I have been beating the drums of cyber-security and secure supply chains. I’m tired now; my arms hurt from all that drumming and I don’t have the energy to keep telling people what they should already know.

Today’s blog article is about FAR 2.0 and regulatory reform. Many people are anxious about what FAR 2.0 will look like and how it might affect them. What does government contract compliance look like in an environment where all the regulations—which have been growing and evolving and changing since 1984—are eviscerated into something that looks nothing like what we thought we knew? What will that be like? So, there is anxiety and nervousness.

I want to suggest that we all calm down. Relax. Wait and see. Not knowing makes us nervous—true. I get that. The uncertainty can be hard on one’s nerves. But consider: don’t worry about the unknown future because we have quite enough on our plates right now. Deal with today and let tomorrow take care of itself.

Here are some absolute truths that you may wish to consider as you contemplate what may transpire:

1. You have existing contracts. They have clauses in them and those clauses impose requirements. They will exist until the work is physically complete and delivered and accepted. They will exist until the final billing rates are calculated and submitted and audited and negotiated. They will exist until the final invoices are submitted and paid. In other words, they will exist for a long time and, at least for those contracts, nothing is going to change. Nothing. All the risks are still the same: compliant timekeeping, compliant accounting, compliant billing, compliant purchasing. Et cetera. The False Claims Act and The Truthful Cost or Pricing Data Act still apply.

2. You have proposals in the pipeline. Some of those competitions may be cancelled, especially if you are at one of those contractors that perform touchy-feely work not aligned with current Washington, DC, priorities. True. But many others will not be cancelled, especially for those DOD contractors that provide critical weapon systems. Those contractors actually may experience a bit of an uptick. (Historical analog: the defense buildup under Reagan.) Those RFPs still have their provisions in place; the evaluation factors are still the evaluation factors. For current proposals, nothing is going to change. Nothing.

3. Future contracts and future proposals may look different—true. But how different? What will they look like? We don’t know … so try not to worry about it. There are bills being discussed in Congress that may change things, but those bills still have to go through Committee votes and reconciliations and all the other things that make the actual lawmaking impenetrable to most humans. There may be legal challenges to whatever final laws emerge from the morass of Congressional lawmaking. We don’t know what the end-product will look like or what parts will be voided by the courts … so let’s wait and see what emerges, if anything.

4. I listen to some smart and experienced people, such as Vern Edwards and Jim Nagle. They’re not worried. They’ve been through this before. (Implementation of FASA in the mid-nineties comes to mind.) Most people do not think much is going to come of the current FAR 2.0 efforts. They are, let’s say, dubious. Vern said (in a podcast which is available at WIFCON 2.0) that he doesn’t think anything significant is going to happen “but it’s going to be fun watching.” That’s a good attitude to have, if you can get there.

So … those are four truths that I hope will help calm you and your work teams.

Let’s be honest here. There have already been significant changes at the government workforce and funding levels. Those changes are starting to have ripple effects at the contractors. Those impacts will definitely continue. I’m not blind to them and, for many (especially those in civil service) it’s going to be tough. But you can get through this, especially if you are flexible and willing to take some risks.

There are jobs aplenty, especially in the manufacturers of weapon systems. But the jobs might not be available near you, especially if you had a nice remote work gig. You may have to move in order to find employment. So what? I’m not trying to trivialize the pain of moving one’s family, because it is a pain. I know. (I’ve moved my family three times and that doesn’t count my move from LA to Fairfax, VA when I was single.) But you can do it—especially if you need to.

Almost everyone who reads this blog has skills that are important to government contractors. Get out there: polish your resume; update your LinkedIn profile. And start applying. Will you have mixed results? Probably. But don’t give up because I know—I know—that contractors are looking for good people with skills and experience. I work at one of them and we are desperate for the right people to apply to our career site.

Think about the priorities in DC right now, which is where the funding will be. Where do your skills fit into those priorities? More FMS cases, more international contracts. Border security; “Golden Dome” (which sounds to me like “Star Wars,” which we called “Peace Shield,” which was among the first projects I worked on when I started in this crazy business.) There is work to be found, so go find it.

All right. Stop rolling your eyes. I don’t know how this article morphed into a rah-rah session. Sorry. But I hope I’m communicated something here: sure, all is chaos. Okay. But if you stay calm and deal with what’s in front of you, you’ll be fine.

Hi there! It’s been a minute. Thanks for coming back here.

I have so much to write about—prominently the recent CAS Board activities. Not to mention, DCAA’s CAS cost impact audit guidance that was clearly written by lawyers instead of, you know, accountants or auditors. I’m going to get to all that stuff when time permits. But today I want to talk about people.

It’s crystal clear (in my mind, at least) that when we are discussing the triumvirate “people, process and technology,” people are the most important component. I know not everyone agrees. In June, at the Deltek/ProPricer Government Contract Pricing Summit (where I spoke on the topic of evaluating and negotiating profit), I heard a very well-known speaker assert that technology was the most important component. He said (paraphrasing) “technology is always moving forward; people and process both struggle to catch up.” Okay. He was a former Assistant Secretary of the Air Force and now CEO of an innovative start-up that has a very cool Lord of the Rings-related name, and I’m just me. Who am I to argue with him?

But he’s wrong.

People are the most important thing. Always and forever.

Corporations look to reduce costs wherever possible. All things being the same, reduced costs leads to greater margins. Investors like increasing margins and the increasing profits that result from cost-cutting. We know that’s not always true in the government contracting market space—especially in developmental efforts—where cost-type contracts mean that (generally speaking and with many exceptions), more costs equal more revenue. All things being equal, more revenue leads to a higher bottom-line profit. But most government contractor executives don’t have a clue about government contract accounting rules so they base decisions on what they’ve been taught in business school, which is that cost-cutting is a good thing.

As a result of that logic, they locate their engineering centers and factories in low-cost states, where employee compensation will be lower than in other states. That’s not the only reason—obviously. Political realities ensure that locating facilities in the states of certain politicians gives contractors a boost during budget time. There’s also the matter of locating facilities in states that are not friendly to unions, or that offer lower corporate taxes, or even full-on tax breaks for the right companies. But we don’t talk about that in the 10-K management discussions. Instead, we talk about cost-cutting.

Employee compensation (among other factors discuss noted) is why Lockheed Martin has so much work in Texas, Florida, and Georgia. (LockMart is in many other states, including California and Colorado, but that’s not the point.) Where does Lockheed Martin make the most money? In its Aeronautics Division. Where is that Aeronautics Division headquartered? Fort Worth, Texas.

Employee compensation is why Boeing builds its 787 Dreamliner in Charleston, South Carolina. From Wikipedia—

Boeing announced in October 2009 that it would build a new 787 Dreamliner final assembly and delivery line in North Charleston. Boeing said that the second production line was necessary to ‘meet the market demand for the airplane,’ but it came amid tense negotiations between the company and the International Association of Machinists and Aerospace Workers (IAM) union representing workers in Everett who had recently gone on strike. South Carolina's unionisation rates, the lowest in the country at 2.7%, were stated by Boeing management as a reason to transfer production to there. IAM said the decision was retaliatory and National Labor Relations Board agreed, filing a lawsuit against the company in April 2011. The lawsuit was dropped in December after IAM withdrew its complaint as part of a new contract with Boeing, clearing the way for production to begin in South Carolina. Since then, Boeing has continued to challenge the rights of unions to organize at the plant, and is alleged to have fired workers for their attempts to unionize.

(Footnotes omitted.)

Companies—particularly those who manufacture MILSPEC products—that have an unhealthy, misplaced focus on people tend to have long-term consequences from that manifest years later, long after the executives who made critical blunders in workforce management have left the companies, taking with them millions of dollars of incentive compensation.

Recently, the NASA Inspector General released report number IG-24-015, discussing the management of the Space Launch System (SLS) Block 1B development. The IG had many criticisms of NASA and its lead contractor, Boeing. The one we are going to focus on is NASA’s blunder to locate SLS core stage manufacturing at the 85-year-old plant in Michaud, Louisiana—located in New Orleans.

The SLS program is under cost pressure. In 2011, Congressional testimony estimated that SLS development costs through 2017 would be roughly $18 billion. As of 2017, $11.9 billion has been spent, of which 40% was spent developing the core stage. As of 2021, development of the core stage was expected to have cost $8.9 billion, twice the initially planned amount. (Source: Wikipedia.) The program is behind schedule and faults have been found in the welding of the core stage.

Let’s talk about the welding. The SLS core stage uses a brand-new welding method: friction stir welding. We don’t know that FSW is. All we know is what Wikipedia tells us; we are told that the new process can create unique risks, which can be mitigated by the quality of the tool design.

Okay. NASA decided to build a new core stage for a new rocket at an 85-year-old plant, and to do it with a new welding technology where attention to detail and tooling design is critical for success. What could go wrong?

The NASA IG answered the question in its report.

According to Safety and Mission Assurance officials at NASA and DCMA officials at Michaud, Boeing’s quality control issues are largely caused by its workforce having insufficient aerospace production experience. Michaud officials stated that it has been difficult to attract and retain a contractor workforce with aerospace manufacturing experience in part due to Michoud’s geographical location in New Orleans, Louisiana, and lower employee compensation relative to other aerospace competitors. Safety and Mission Assurance officials advised that Boeing provides training and work orders to its employees in an attempt to mitigate the challenges associated with an inexperienced workforce and help ensure that its workers comply with quality control standards. However, given the significant quality control deficiencies discussed above and our observations during a site visit to Michoud, we found both these efforts to be inadequate.

The NASA IG report added a footnote to the above. The footnote referenced AS9100D, Section 7.2, Competence. The inference is clear: Boeing’s Michoud assembly workforce management does not comply with the requirements of AS9100D. Our research indicates that Boeing has never been certified to be compliant with the requirements of AS9100—even though it requires its suppliers to hold that certification. Only in the past two months has the aerospace giant indicated that obtaining AS9100 certification is something its leadership wants to pursue. Ya think? (Source: Sean Broderick’s article in Aviation Week, 28 June 2024.)

So … you get what you pay for. If you want low-cost employees then don’t ask them to participate in innovative things. If you want to attract and retain a skilled workforce, then be prepared to pay for it. Don’t cheap-out on the hired help. It you want the best, then pay for the best. Learn to accept and to work with a unionized workforce. Your employees are not your enemy.

This issue is not confined to US aerospace/defense contractors. It is global.

Last week, I received an email from Kevin Craven, Chief Executive of ADS, the industry group that represents aerospace and defense companies in the United Kingdom. (Why am I part of a UK industry group? Long story but it’s also why my picture is on file at the MoD.) Mr. Craven had a simple topic he wanted to discuss, “everyone’s favourite subject: skills.”

We are all acutely aware of the difficulties we have as businesses to recruit the right talent, at the right time. Our industries employ - at last calculation - some 427,500 people throughout the country into well-paid, highly skilled, manufacturing, engineering and digital services jobs. Our success in recruiting, however, is mixed.

We know that there are 10,000 vacancies in our industries, as a minimum. We hear from our larger members that they can be oversubscribed in some roles - a fantastic achievement - while our smaller businesses, no less pivotal to our economy, can struggle. To address this imbalance, we’re actively seeking practical solutions to increase engagement across the board - to get those roles filled, capability delivered, and to secure the UK’s advanced manufacturing advantage.

… at ADS we are actively seeking partnerships - whether that’s through STEM events, widening participation schemes, mentoring programmes, policy agendas, practical job finding support, or partnerships with organisations who are leading the way in this area.

Back in the States, Huntington Ingalls Industries announced July 6 that it plans to add 2,000 heads to its current Pascagoula, Mississippi, workforce of 11,300. That’s about a 20 percent increase. On May 24, the VP of Human Resources (Xavier Biele) at HII’s Newport News Shipbuilding site in Hampton Roads, Virgina, announced that the shipbuilder needs to find more employees. Magan Eckstein’s article at Defense News reported:

The yard plans to hire 3,000 skilled tradespeople this year, but it needs to bring in 19,000 over the next decade, Beale said, adding that the existing training pipelines in the Hampton Roads region is unable to funnel enough new employees toward Newport News.

Beale said volume is only one issue when it comes to recruiting. When the COVID-19 pandemic struck the United States in 2020, a wave of highly experienced workers retired. Replacing those master tradespeople with recent high school graduates has affected productivity.

While it’s difficult to find talent with decades of shipbuilding experience, the next best thing might be finding talent with years of experience as welders or electricians outside of the shipbuilding-industrial base, Beale said.

Where I live in San Diego, we have trouble recruiting employees because of the insanely high cost of living. Everybody knows about California housing prices. And utility prices. And high state taxes. What fewer people know is that salaries tend to be commensurate with the cost of living, and the property taxes are relatively low in comparison to other states. (Hello, Texas: I’m looking at you.)

Aerospace and defense companies need to get over the notion that employee compensation cuts lead to lower prices. Maybe they do; but they also lead to production inefficiencies and delays, and potentially to serious quality issues. The US government can help by removing the “ceiling” on allowable employee compensation (FAR 31.205-6(p))—though almost no direct-charging employee is ever going to come close to that limit; it impacts executives, which may not be a bad thing if they keep on blundering around trying to increase shareholder value by attacking their own employees.

We need to get serious about attracting and retaining good people. If that means paying the rank-and-file more, then so be it. You can cover the costs of wage increases by cutting multi-million-dollar executive bonuses. (Ha! Like that’s ever going to happen.)

In addition, we need to reevaluate certain employee labor classes based on the true value they add in the 21^st century. As noted above, skilled tradespeople are in high demand. It is absolutely viable to skip college (and student debt) in order to join an apprenticeship program that leads to a career in the trades. Touch labor is critical.

And what about our supply chain specialists, our buyers and source inspectors? Given the importance of the supply chain to program success, wouldn’t you think you would want to hire the best, train them, and keep them around for a long time? Sure. But if that’s true, why do you keep hiring former buyers from Sears, thinking they will make already trained supply chain specialists with deep FAR expertise. Let’s not be silly.

Think of a workforce as an inverted pyramid, with the direct-charging touch labor folks on the top and the executives on the bottom. There’s your true value-added illustration.

Why don’t we start managing that way?