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Apogee Consulting Inc

Just How Important is Supply Chain Management to Operational Success?

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We have tooted horns and bloviated ‘til the bovines come home, but we’re afraid the message is not getting out. Listen, folks: Whether you call it Supply Chain Management, supplier management, or subcontractor management, it is the key to success. Period.

Your preoccupation with internal matters, your management metrics that focus only on internal issues (such as headcount), your application of Lean and Six Sigma solely to your own production line, your attempts to control cost growth by forcing suppliers into firm fixed-price development contracts or into making huge program “investments”—these actions betray a management naïveté, an erroneous impression that the management approach that worked to put a man on the Moon is the same approach that will lead to successful program execution in the 21st century.

Newsflash: it will not.

Program management in the 21st century looks completely different from how it looked 40 years ago. And nowadays it’s all about managing a large team to a successful outcome. It’s all about supplier management.

But don’t take our word for it. Look at the evidence and draw your own conclusion. Here are two recent news stories that show the pros and cons of revamping one’s approach to managing subcontractors.

In the first story, the Pentagon’s Missile Defense Agency has decided to “withhold” a $400 million Terminal High-Altitude Area Defense (THAAD) production contract from Lockheed Martin until it can prove it has solved quality and reliability problems associated with the “optical block switch” designed and manufactured by one of its subcontractors. According to this Wall Street Journal article—

Production of the missile, Gen. O'Reilly said, is ‘badly needed’ so the Army's first THAAD unit, stationed at Fort Bliss, Texas, can fully train on its equipment. But he said he would not approve a $400 million-plus production contract unless the company fixed the flaws and the safety device passed new qualification tests within the next 30 days.


I am holding their [the contractor's] feet to the fire,’ Gen. O'Reilly said. ‘I will not move forward until they satisfy all the quality requirements and all the production start-up requirements.’


According to Gen. O'Reilly, Lockheed offered a warranty over the part, called an optical block switch. If production is approved and new problems are discovered, the company will be liable for any extra costs stemming from production delays, he said.

This GlobalSecurityNewswire article reported LMCO’s reaction as follows—

The company suggested it could assume additional financial responsibility to secure the contract, Reuters reported. The firm proposed underwriting potential expenses that could result from halting and resuming the manufacturing process as the faulty switch is addressed. Approval of the component is expected next February.


We have taken responsibility for delivering the successful optical block switch solution as promised,’ [LMCO Spokesperson] Amerine stated by e-mail.

This article at SpaceNews fills in some of the gaps—

Dallas-based Lockheed Martin Missiles and Fire Control is the prime contractor for the MDA’s Terminal High Altitude Area Defense (THAAD) system, designed to destroy ballistic missiles in and above the Earth’s atmosphere.

Lockheed is under contract to deliver 50 THAAD interceptors and was expected to receive a production order for 48 more. However, an optical safety switch built by one of Lockheed’s subcontractors, Moog Inc., has repeatedly failed in testing, resulting in a production delay of at least six months, U.S. Army Lt. Gen. Patrick O’Reilly, the MDA’s director, told reporters at the Space and Missile Defense Conference here.

It’s very frustrating. After 10 years of development of this version of THAAD we’re down to one small component,’ O’Reilly said. ‘I’m sure half of the Lockheed workforce would like to personally rebuild it themselves.’ …

A redesigned safety switch has been built and is undergoing qualification testing, O’Reilly said. Though testing of the redesigned safety switch will not be fully complete until next February, the MDA and Lockheed have come to an unconventional arrangement in order to minimize the delay. If the first three new safety switches pass preliminary testing in September, MDA will allow Lockheed Martin to enter production in exchange for a warranty on all of the interceptors built under this contract, O’Reilly said.

To wrap this story up, we want to quote an August 19, 2010 story from the Aerospace Daily & Defense Report entitled, “MDA Contractor Woes Continue with Faulty Thaad Part.” It reported—

O’Reilly said he notified Lockheed Martin of the problem a year ago; the company offered other solutions that also failed to quality. Now the focus is on a redesign … As prime contractor, Lockheed is responsible for the quality of parts used in its systems, even if they come from a supplier such as Moog. Lockheed also offered to pay for any ‘financial setbacks’ that the program could encounter in the future as a result of problems with the optical block switch.

Let’s reprint one phrase from the foregoing for emphasis: “As prime contractor, Lockheed is responsible ….”

Yes, indeed.

Program quality and execution risk cannot be transferred to suppliers. The prime contractor is responsible to the customer for the program. Period. If your attorney counsels otherwise, you should hire another attorney. If your subcontract manager or buyer or procurement specialist tells you that cost or schedule or quality or performance risk has been controlled by pushing it downwards in the supply chain, you should put a better support team in place.

Because you cannot build a wall between team members on a program; you cannot say, “This is your responsibility and this is my responsibility.” You cannot transfer risk; the most you can do is to share it. The more that design information and risk information is shared, and communicated, and managed as a team, the better the outcome. When you treat your suppliers as individual entities that succeed, or fail, on their own, then you will always suboptimize your outcome. That is axiomatic. It is a nearly inviolate law of 21st century program management.

As Lockheed Martin learned to its chagrin.

On a more positive note, Raytheon may be getting the message. We recently reported that Raytheon won the Small Diameter Bomb Increment II (GBU-53/B) competition against the odds-on favorite team of industry giants, Boeing and Lockheed Martin. After receiving its debriefing, the losing team declined not to protest the award—which is a rarity these days. Clearly, Raytheon’s technical approach and pricing gave them such a competitive advantage that the award decision was unimpeachable. Raytheon’s winning approach is worth studying.

Several articles indicated that Raytheon’s decision to use an uncooled infrared seeker was a key technical and cost differentiator. As DefenseIndustryDaily reported—

Uncooled infrared involves a performance hit over cooled infrared designs, in exchange for snap-attack capability, better reliability, and lower production and maintenance costs. Raytheon could work to adapt the IIR seeker in their AGM-154 JSOW as a starting point, and they did eventually produce a version that fit SDB-II, was cheaper to manufacture, and more than met government requirements.

But perhaps more importantly, DID reported that “Raytheon executives said that they also took a somewhat different supply-chain approach to the SDB-II.” According to the article—

[Raytheon picked] suppliers early and then work[ed] directly with them to improve productivity at every step. While Raytheon prototyped their final assembly line, and began using lean production techniques to reduce the amount of ‘touch labor’ and improve productivity, they brought in suppliers to do the same thing. For instance, Celestica engineers were embedded with the team, in order to run their own producibility tools on circuit card designs and refine them to improve yield and costs. Rockwell Collins, who makes the datalink, did the same thing. This is not uncommon in general manufacturing, but defense manufacturing has traditionally been more stovepiped.

Raytheon’s initial team during development will be about 300, but this is expected to drop below 50 for production phase – in part because Raytheon has already used lean techniques, and focused from the beginning on creating a design that was simpler to manufacture.

Raytheon’s suppliers included General Dynamics OTS, Klune Industries, Rockwell Collins, Raytheon Dene, Goodrich, and Cobham. As the article above notes, Raytheon invested in its supply chain and worked with its suppliers in a partnership to develop common processes and align approaches.

This is how it is done, folks. This is how you build a program team that shares risks and responsibilities, as opposed to an adversarial team where the overall program objectives are subliminated to the needs of the individual business entity.

(Boeing 787 team, are you listening?)


 

 

What is Going-On with the Army’s NextGen Ground Combat Vehicle?

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On August 25, 2010, the U.S. Army cancelled the competition for its multi-billion dollar next-generation Ground Combat Vehicle (GCV). According to this Reuters article, the Army intends to issue a new RFP within 60 days, “delaying a contract award for up to six months.” The GCV program was intended to replace the ground vehicle portion of the troubled Future Combat System (FCS) program, which was terminated in the early days of the Obama Administration.

The GCV program has been a beset by delay after delay, as this Wikipedia article documents. This latest delay is another blow to the hopes of the competing teams. As Reuters reported—

The unexpected change to the Ground Combat Vehicle … program threatens jobs as well as revenue for the competing teams of companies and marks another setback for the Army's effort to develop new infantry vehicles. The prime contractors bidding for the program are: Science Applications International, Britain's BAE Systems, and General Dynamics Corp, and their subcontractors include many of the largest U.S. defense contractors, such as Lockheed Martin Corp, Boeing Co, and Raytheon Co. The Army is studying the impact on its fiscal 2011 budget request, which called for $934 million to start development of prototype new vehicles.

The Army’s rationale for cancelling the competition was (and remains) vague. The Reuters article noted that “a review done with Pentagon acquisition officials showed risks in proceeding as planned.” This article at the Army Times explored what went wrong. It concluded that the Army “overreached” and was overly ambitious in its plans to integrate developing technology into the program. As the article reported—

The new RFP will reflect changes to the program’s efforts to minimize technology integration risk and to ensure that we have a viable acquisition strategy to deliver the vehicle within seven years of the contract award,’ GCV program spokesman Paul Mehney said.

The article continued---

According to industry sources familiar with the first RFP, the requirements placed on industry were stringent and demanded an enormous level of armor to protect soldiers, the vehicle and its sensors. This led to heavy and costly solutions.


A disconnect emerged between what the Army required in its RFP and what the service expected to get, an industry source said. A light went on after industry responded to the Army’s questions about the June bids. The Army got a ‘resounding’ response from industry of ‘you asked for it, you got it,’ the source said.

Apparently, the Army realized that it was headed down the wrong path. A more cynical view wondered whether it ever intended to execute the program of record at all. The Army Times article reported—

One source who attended an Army industry day last fall said he wondered whether GCV was a ‘conceptual Kabuki dance’ meant to placate Gates until he retires, and then allow the Army to take a ‘deep and informed breath’ and figure out what it really needed.

But while the Army replans its GCV program to address technology readiness and armor requirements, the Defense Advanced Research Projects Agency (DARPA) is planning quantum leaps in the technology it will apply to GCV vehicle production. In mid-August, DARPA issued several draft “Broad Agency Announcements” (BAAs) looking for massive innovation in the design and production of various “complex cyber-electro-mechanical systems such as defense and aerospace vehicles.” One aspect of DARPA’s vision is vehicleforge.mil, which it described as “an open source hosting site for the collaborative development” of such systems.

Another aspect of the vision is iFAB. What is iFAB? In the words of the draft BAA—

The principal objective of iFAB … is to enable substantial compression of the time required to go from idea to product through a shift in the product value chain for defense systems from ‘little m’ manufacturing (i.e., fabrication) to the other elements of ‘big M’ Manufacturing (i.e., design, customization, after-market support, etc.). Such a shift requires significant de-coupling of production from the other phases and facets of ‘big M’ Manufacturing so as to enable its commoditization. One might term this the ‘foundry-style’ model of manufacturing. This model is an anathema to the current defense industry trend of tightly coupling design and prototyping through multiple design-build-test-redesign iterations. In fact, the iFAB vision is to move away from wrapping a capital-intensive manufacturing facility around a single defense product, and toward the creation of a flexible, programmable, potentially distributed production capability capable of accommodating a wide range of systems and system variants with extremely rapid reconfiguration timescales.

iFAB will be based on “a foundry-style manufacturing capability … capable of rapid reconfiguration to accommodate a wide range of design variability and specifically targeted at the fabrication of military ground vehicles.” Note the emphasis on fabrication of military ground vehicles—i.e., the GCV program. .

To emphasize the connection, we note DARPA’s Fast Adaptive Next-Generation Ground Combat Vehicle (FANG) program. Details are sketchy, but we found several links between FANG and iFAB. This article states—

The specific goals of the iFAB program are to rapidly design and configure manufacturing capabilities to support the fabrication of a wide array of infantry fighting vehicle models and variants. Parallel efforts titled vehicleforge.mil and Fast Adaptable Next-Generation Ground Combat Vehicle (FANG) seek to develop the infrastructure for and conduct a series of design challenges (termed Adaptive Make Challenges) intended to precipitate open source design for a prototype of the Army's Ground Combat Vehicle (GCV).

The iFAB end vision--to be developed in the second phase of the program which will be solicited under a separate BAA at the conclusion of the present effort--is that of a facility which can fabricate and assemble the winning FANG designs, verified and supplied in a comprehensive metalanguage representation with META/META-II tools.

In other words, DARPA is looking to apply wildly advanced technology to the program that is being delayed because of concerns related to (among other things) technological maturity.

We dig the irony.



 

Memories of the Big 4

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The large cadre of consultants here at Apogee Consulting, Inc.—you know, the hundreds of consultants who are waiting by the phone for you to call—come from the “Big 4” world of professional service firms. As this Wikipedia article explains, “The Big Four are the four largest international accountancy and professional services firms, which handle the vast majority of audits for publicly traded companies as well as many private companies, creating an oligopoly in auditing large companies.” And they provide consulting services to government contractors, of all sizes, in all industries, as well—which is where we cut our teeth.


PricewaterhouseCoopers LLP, Ernst & Young LLP, KPMG LLP, Deloitte LLP. These are the Big 4. And we spent many years working for the audit partnerships.


If you’ve never worked in such an environment, it’s a unique one—trust us. Here are three videos that we found on YouTube, that brought back lots of memories. We thought we’d post them for others to enjoy.


A couple of introductory words first.


Number one, these videos contain lots of Not-Safe-For-Work language. Lots of bad words. No bad images, but lots of bad words. You have been warned.


Second, if you’ve never worked in the firms, you might think these videos are exaggerated and do not depict the reality of the work environment. Trust us, they are spot-on 100% accurate. There are lots of positive aspects of working for the Big 4. But these videos accurately depict some of the less-than-savory aspects.


Enjoy.


Video No. 1 – A Moment in the Life of the Auditor




Video No. 2 – Annual Performance Reviews




Video No. 3 – Project Plans





Perhaps these videos offend you. If so, please accept our apologies. But most folks think they’re funny. We hope you enjoyed them as much as we did.

 

 

 

 

 

 

 

 

 


 

New DCAA Audit Guidance Clarifies Audits of Indirect Rates Used in Cost Estimates

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We previously shared our thoughts regarding DCAA’s June 4, 2010 audit guidance found in Memorandum for Regional Directors (MRD) 10-PSP-018(R). In that MRD, auditors were directed to disclaim any opinion on any indirect rates found in a contractor’s cost proposal (which DCAA calls “forward pricing rates”) where those rates had not yet been audited by the agency.

Where those rates were based on a negotiated Forward Pricing Rate Agreement (FPRA) with the DCMA. DCAA should not accept the FPRA rates until auditors had completed “detailed testing” and other “analytical procedures” in order to be able to opine on them. Where FPRA rates had been audited, but the DCMA Administrative Contracting Officer negotiated differing indirect cost rates with the contractor, then the DCAA auditor may accept them. However, where the auditor “believes the ACO did not fully consider the DCAA audit results and there are significant differences between the DCAA recommended rates and the FPRA or FPRR,” then the auditor should elevate the disagreement pursuant to the DCAA/DCMA dispute resolution process.”

And “If the pricing proposal audit report must be issued prior to resolving this disagreement, the audit opinion should reflect the DCAA recommended rates.” In other words, the audit guidance directed the DCAA auditor to substitute his/her judgment for that of the DOD representative who has the authority to bind the government.

** Insert eye roll here**

Suffice it to say that we were less than enamored of that piece of audit guidance.

But we are a bit happier with the DCAA’s latest MRD, 10-PSP-021(R), issued on August 24, 2010, which “clarifies” the previous “guidance on the expectations regarding the contractors’ use and extent of budgetary data in support of forward pricing rates.” We’ll provide some quoted bits from that MRD—

  • Contractors must indicate how they computed and applied their indirect rates while also showing trends and budgetary data with explanations to support the reasonableness of the rates per the requirements of FAR Part 15. The extent of detail will vary depending on the specific data supporting each Fiscal Year and based on the size and complexity of the contractor.

  • When auditing proposed indirect rates, auditors should perform substantive procedures to evaluate the reasonableness of the contractor’s basis of estimate (e.g., budgetary data and historical costs/trends). When historical contractor data is used to support the basis of estimate, the auditor must document the substantive audit procedures performed (previously or currently) to ensure the historical data is in reasonable compliance with FAR Part 31.

Well, that doesn’t seem too bad, does it? But that’s not all. The MRD contained some—shall we say aggressive?—bits as well.

The audit guidance opined that the “overarching principal of FAR Part 15” [sic] is that “the contracting officer must purchase supplies and services at fair and reasonable prices.” That’s more or less correct, but then the audit guidance states, “Contractors are generally required to follow the Table 15-2 instructions for submitting proposals as contained within FAR 15.408.” Well, that’s not true at all. Contractors are only required to follow the proposal format instructions found in FAR Table 15-2 when they are submitting cost or pricing data. (Or, if you will, “certified” cost or pricing data, based on the recently revised FAR definition(s).) If the contractor is not submitting cost or pricing data, it is not required to follow the format of Table 15-2.

(Now there may be some room for controversy here. If you follow the link above to the article, you would see that the phrase “information other than [certified] cost or pricing data” has been redefined to encompass “the identical types of data as certified cost or pricing data, consistent with Table 15–2 of 15.408, but without the certification.” That phrase strikes us as patently ambiguous, but we bet DCAA will seize on it as requiring that all cost information be submitted in the format of Table 15-2—which we would argue would be an incorrect reading of the requirements.)

Anyway, back to the MRD.

After declaring that contractors are “generally required” to follow the format and instructions of Table 15-2, the DCAA audit guidance then stated that Table 15-2 requires contractors to “indicate how they computed and applied indirect rates while also showing trends and budgetary data with appropriate explanations to support the reasonableness of the proposed rates.” The MRD used this as a foundation to state—

Therefore, in accordance with FAR Part 15, a contractor’s indirect rates should be based on a well-supported basis of estimate for each Fiscal Year of the proposed period of contract performance. To demonstrate reasonableness, contractors must show how they computed and applied the indirect rates while also providing supporting trend and budgetary data with appropriate explanations commensurate with the size and complexity of the contractor’s organization. The contractor’s proposal should be prepared in accordance with the contract cost principles and procedures in FAR Part 31 and, when applicable, the requirements and procedures in 48 CFR Chapter 99, Cost Accounting Standards (see requirements of FAR 15.404-1(c)(2)(iv)).

There’s more. The audit guidance stated—

At larger contractors it would be expected that the proposed indirect rates for the first year be based on a detailed management-approved operating budget, and each subsequent period be based on adjustments to the operating budget based on strategic or long-range forecasts (e.g., plant expansions, expected business volume, etc.). At a large contractor, with a board of directors, one would expect detailed budgets and forecasts to be in place to provide the directors with knowledge of future planned capital expenditures and other strategic and long range objectives. The contractor’s proposed rates should be consistent with this budgetary data.

Now, we all know that there is almost no chance that any contractor, large or small, has detailed operating plans that project out for any great length of time. Although some of the language above seems to expect a “well-supported estimate for each Fiscal Year of the proposed period of contract performance,” other parts seem to be more forgiving, stating that only the first year needs to be supported with a “detailed management-approved operating budget” and that subsequent periods can be based on “adjustments” to that first year budget “based on strategic or long-range forecasts.”

That seems fairly reasonable, assuming somebody has made those “strategic or long-range forecasts” and has shared them with those people calculating the forward pricing rates used in cost proposals. As the MRD stated, “Generally, the level of forecasted detail will decrease as the period being estimated moves further into the future and the uncertainty of conditions and potential events grows. Therefore, it is not expected that even larger contractors prepare detailed operating budgets for each Fiscal Year of contract performance….” Seems okay, right?

But wait a second. Let’s look a bit deeper at the MRD. It stated—

The FAR requires an explanation of how the rates were derived for each of the out-years to allow the contracting officer to ascertain the reasonableness of the rates. For example, flat-lining out-year rates with no explanation to support that the rates will not change in future periods is not adequate. Adjustments to out-year pools and bases should be made based on reasonable sales forecasts and the contractor’s assumptions for changes to major groupings of costs (e.g., variable, semi-variable, and fixed). In addition, for multi-segment contractor organizations the budgets and forecasts should reconcile for all significant cost allocations and interdivisional effort supporting the proposed rates.

We would be shocked if the large multi-segment contractors ensured that their out-years’ rates were based on budgetary data that reconciled for “all significant cost allocations and interdivisional effort.” That’s simply a huge amount of effort—nearly impossible within any reasonable timeline.

Although the audit guidance told DCAA auditors that “the extent of data supporting a contractor’s proposed indirect rates will vary,” the standards it applied to the largest contractors would be extremely difficult to meet. What happens if a contractor can’t satisfy the auditor that its forward pricing rates are well-supported and based on budgetary data?

In such cases, the MRD stated—

As outlined in CAM 9-205(d), if the contractor’s indirect rate forecasts are not adequately supported throughout the entire period of performance and are so deficient that an examination of the unsupported years cannot be performed, the auditor should recommend that the contracting officer return the proposal to the contractor.

We opined in our previous article that DCAA’s recent audit guidance was tantamount to throwing a monkey wrench into the gears of the DOD acquisition machinery. While there are a few nuggets of goodness in this latest MRD, our opinion is that there also much in it that we believe supports our previous opinion. We understand the audit agency’s need for independence—but if this is the price we have to pay for independence, then we urge the Pentagon to figure out another way of getting contractor proposals evaluated so that the parties can negotiate a reasonable price.






 

Final Inflation Adjustments to Acquisition Thresholds

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We previously reported on significant revisions to the implementation of TINA in the Federal Acquisition Regulation, as implemented by Federal Acquisition Circular (FAC) 2005-45 on August 30, 2010. FAC 2005-45 also implemented changes to key acquisition-related thresholds, based on inflation adjustments calculated from changes to the Consumer Price Index. Every five years, the FAR Councils review the CPI changes and adjust certain “heavily used” thresholds.


These thresholds matter, because they determine when various FAR contract compliance requirements kick-in. Put another way, in order to ascertain the compliance risk associated with a solicitation or contract, one looks at which FAR requirements are invoked—and those requirements vary based on which acquisition threshold has been invoked.


We reported on the proposed rule changes here. As the FAR Councils stated, between the proposed rule and the final rule, “some of the thresholds changed due to lower inflation than was projected at the time of publication of the proposed rule.”


The final rule establishes the following acquisition-related thresholds—


  • The micro-purchase base threshold of $3,000 (FAR 2.101) is not changed.

  • The simplified acquisition threshold (FAR 2.101) is raised from $100,000 to $150,000.

  • Commercial items test program ceiling (FAR 13.500) is raised from $5,500,000 to $6,500,000.

  • The cost or pricing data threshold (FAR 15.403-4) is raised from $650,000 to $700,000.

  • The prime contractor subcontracting plan (FAR 19.702) floor is raised from $550,000 to $650,000, and the construction threshold of $1,000,000 increases to $1,500,000.



 


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Newsflash

Effective January 1, 2019, Nick Sanders has been named as Editor of two reference books published by LexisNexis. The first book is Matthew Bender’s Accounting for Government Contracts: The Federal Acquisition Regulation. The second book is Matthew Bender’s Accounting for Government Contracts: The Cost Accounting Standards. Nick replaces Darrell Oyer, who has edited those books for many years.