Budget Issues and Workforce Impacts
 If you’ve been reading blog articles on this site for any length of time, you know we’ve been interested in the health of the defense industrial base, and have written several articles discussing how defense contractors are reacting to budgetary pressures stemming from Congress’ inability to pass a budget (as well as from several other factors, including but not limited to Dr. Carter’s “Better Buying Power Initiative” and Shay Assad’s attack on contractors’ indirect expenses and profits). We could post several links to those blog articles, but the site has a search feature, so you can do your own homework on that, if you’re so inclined.
The Aerospace Industry Associations (AIA) has published many upon many articles of its own, issuing dire warnings of the impact of “sequestration” Defense Department funding cuts on the defense industrial base workforce. In fact, the AIA has estimated job losses in the potential aerospace/defense sector at one million heads.
And while the devasting impact of “sequestration” is undeniable, what is less obvious is the immediate impact on the defense contractor workforce from the current budgetary uncertainty and current DOD cost reduction measures (as noted above). We want to discuss one particular story that came to our attention.
In 2005, UK-based BAE Systems acquired United Defense Industries for $4 Billion and created BAE Systems Land & Armaments, which is reportedly the largest land systems defense contractor in the world (or at least it was, until its recent losses of the M-ATV and FMTV bids). As part of its acquisition of United Defense, BAE Systems acquired the legacy manufacturing operations of Bowen McLaughlin York (BMY), which later became the BMY Combat Systems Division of the Harsco Corporation, based in Pennsylvania.
Today, as it has for nearly 75 years, BAE Systems’ York, Pennsylvania, plant manufactures a number of mature ground combat and land defense systems products—including various types of Bradley Fighting Vehicles. Nearly 1,300 employees work on defense products, as perhaps their fathers and grand-fathers did before them. (And women, too! We didn’t forget.) Reportedly, 80 percent of the Army’s fleet of Bradley FVs has passed through the York plant at one time or another.
But times have been tough recently. As noted, a couple of very large “must-win” bids were lost, and (as we’ve reported) the Army seems to have fumbled its Next Generation Ground Combat Vehicle program. With large-scale ground combat operations winding-down in Southwest Asia, and the US Army planning to halt Bradley FV production (perhaps for several years) starting in 2014, management is looking at a backlog burn-down without much in the way of new orders to replace it.
Which inevitably means workforce reductions.
In early May, 2012, BAE Systems announced that 210 workers at the York, Pennsylvania, plant would be furloughed for about 30 days this summer. That’s about 20 percent of the plant’s workforce. Although management commented that the furlough (which applies to both salaried management and hourly union workers) stemmed from “the normal ebbs and flows of the business,” it was clear that the move was made in response to more than the general business climate.
According to the Reuters article (link above), BAE Systems stated that the root cause of the furlough was “a delay in a Fiscal 2012 contract award for upgrades to the Army’s M2 Bradley Fighting Vehicles.” The delays in awarding the contract led to slips in delivery schedules of long-lead materials from suppliers. No materials, no upgrades. Thus: temporary lay-offs.
But as usual, the story behind the story is more interesting.
According to Inside Defense and Inside the Army (subscription required), the Army put the blame for the contract award delay on BAE Systems itself. Reportedly, the Army has asserted that the delay occurred because “BAE did not submit a compliant bid proposal.” Ms. Heidi Shyu (acting Army Acquisition Executive) wrote in an email to Congress that (reportedly), “BAE omitted the fact that they submitted an inadequate cost proposal … which significantly contributed to the delay in contract award.”
To be very clear, we do not have any insight into BAE Systems’ proposal. We don’t know whether or not it was “adequate.” But we do know this much: The Bradley FV program has been around for thirty years, entering service in 1981. We know that the contract in question is for an award of Fiscal Year funding. Putting all that together, we have to ask how much data the Army actually needed to see in order to determine the BAE Systems’ price was fair and reasonable. They had years and years of actual cost data; what was going to be new information?
Sure, it was a single-source award and likely subject to TINA. But so what? The purpose of TINA is to place the negotiating parties on an equal footing, not to burden the contractor with providing unnecessary and costly information that confirms with the DCMA Contracting Officer and the Buying Command already knew.
What is more likely, we think, is that DCAA used its infamous Cost Proposal Adequacy Checklist, and kicked-back the proposal because it didn’t meet all the check-boxes. Again: so what? If our guess is correct, then the real question is why did the CO think s/he needed field pricing assistance to perform cost analysis on one of the Army’s most mature production programs?
And so, contract award was delayed (for whatever reason) and now more than two hundred people are facing a month without a paycheck.
But that’s not the end of the story. Demonstrating an almost unbelievable naïveté, the Army complained to Congress that (a) BAE Systems did not tell them about the consequences of the delay, and (b) BAE Systems could avoid the furlough if it only “accelerated” material deliveries from suppliers. Yes, that’s what the Inside Defense and Inside the Army stories reported.
BAE told the Army that program supply chains don’t just accelerate themselves—at least, not without a cost impact or two. The story reported that the Army told Congress that BAE Systems told them that—
BAE stated that production schedules are already locked in accounting for the furlough and even if material deliveries could be accelerated, it may be too late to make this change as the program is already in progress. Multiple program activities would require acceleration at this time, not just material lead times and those accelerations are not possible.
Next the Army tied a different approach (according to the article’s reporting of the Army letter). The Army asked BAE Systems to slow down production rates and stretch out the program to avoid the furlough. (“Such a strategy would not require a material delivery acceleration.”) BAE nixed that suggestion as well. BAE told the Army that if it cut its production rate in half (as the Army had requested) then it would still have to furlough half of the 210 employees. BAE Systems told the Army that slowing production would lead to a “more significant impact than [having] all BAE Bradley Production Union employees being furloughed for 30 days.”
We don’t know. The Army comes out of this looking pretty clueless, in our opinion. One would think that the contractor’s workforce management would be left to the contractor, especially if (as the Army asserted) all the problems stemmed from the contractor’s inadequate proposal. The Army’s (over)reaction seems to us to have a bit of guilt associated with it.
We return to our initial question. How does the Army justify requiring a full-up, fully expensive, TINA-compliant proposal for an annual funding request? If you want to pile-on, then let’s ask why this program isn’t being funding with mult-year money, which would permit more robust long-term planning?
Who’s running this show? We aren’t really sure, but one thing is certain. It’s the local workforce that’s paying the price for this apparent mismanagement.
DCAA Implements New Accounting System Review Program and Says Goodbye to Flash Reports
 On April 24, 2012, DCAA issued audit guidance via MRD 12-PAS-012(R), concerning performing reviews of contractors’ accounting systems pursuant to the new DFARS adequacy criteria and business system administration rules. You know, the stuff that we’ve incessantly blogged about here? Yeah, that stuff.
And yet, here we are, blogging about that stuff once again.
We suspected that the easiest way forward for DCAA was to mash several of its previous ICAPS audit programs into one, and call it the “accounting system” audit program. And that’s indeed what happened. It’s the logical move, since that’s essentially with the DAR Council did in establishing the 18 system adequacy criteria in its new DFARS contract clause regarding contractors’ accounting systems.
So the formerly separate ICAPS audits of Billing and Control Environment are now considered to be subsidiary assignments under the “controlling assignment” given Activity Code 11070. Other former ICAPS audits such as Labor Accounting and ODC Accounting are being completely incorporated into the Accounting System Audit procedures. In addition, some other formerly separate ICAPS-type audits (e.g., Timekeeping, purchase existence/consumption) will now be performed separately but “referenced and incorporated” into the controlling Accounting System Audit assignment, as will CAS compliance reviews.
Importantly, the new DCAA accounting system audit program asserted that, in order to comply with GAGAS, auditors cannot use the definition of “significant deficiency” found in the new DFARS rules. Instead of the definition mandated by regulation, DCAA auditors will use the following—
A deficiency, or combination of deficiencies, in internal control over compliance such that there is a reasonable possibility that a material noncompliance with a compliance requirement (e.g., applicable Government contract laws and regulations) will not be prevented, or detected and corrected on a timely basis.
Given that much of the controversy surrounding adoption of the business system administration rules concerned DCAA’s approach to the term “significant deficiency,” and the lack of clarity regarding application of the concept of materiality to the word “significant,” we think that contractors should be concerned with DCAA’s definitional flexibility. Very concerned.
The audit guidance devoted substantial verbiage to addressing materiality, perhaps in a proactive attempt to head-off contractors’ criticism of the audit procedures. Here is a snippet of that verbiage (emphasis in original)—
In evaluating whether a noncompliance is severe enough to be considered a material noncompliance and a significant deficiency/material weakness, the auditor should consider the likelihood that the identified noncompliance with the DFARS criteria will result in noncompliance with other applicable Government contract laws and regulations (e.g., with FAR Subpart 31.2, CAS, or applicable requirements in FAR Part 15) and the magnitude of those potential other noncompliances. If there is a reasonable possibility that the identified noncompliance with the DFARS criteria will result in a material noncompliance with other applicable Government contract laws and regulations, either individually or in combination, it is a significant deficiency/material weakness. Some of the specific factors that auditors should consider include:
- The nature and frequency of the noncompliance with the DFARS criteria identified with appropriate consideration of sampling risk (i.e., the risk that the conclusion based on the sample is different than it would be had the entire population been tested).
- Whether the noncompliance with the DFARS criteria is material considering the nature of the compliance requirements.
- The root cause of the noncompliance. (Understanding why the noncompliance occurred will help to determine if it is systemic and significant.)
- The effect of compensating controls.
- The possible future consequences of the noncompliance with the DFARS criteria.
- Qualitative considerations, including the needs and expectations of the report’s users. For Government contract cost issues, qualitative considerations also include serving the public interest and honoring the public trust.
Astute readers will notice that DCAA’s “specific factors that auditors should consider” are not especially helpful. We like the bit about taking into account the effect of compensating controls; however, we don’t care at all for the bit about taking into account “qualitative considerations.” We don’t think all the verbiage in the guidance regarding materiality really reduced industry’s concerns. We predict problems lie ahead in that area.
We also predict future challenges associated with this piece of audit guidance—
In addition, it is not necessary to demonstrate an actual monetary impact to the Government (e.g., unallowable or unallocable costs, or that the price the Government negotiated for a contract was unreasonable) to report a significant deficiency/material weakness. There only needs to be a reasonable possibility that the noncompliance with the DFARS criteria will result in a material noncompliance with other applicable Government contract laws and regulations, thus materially affecting the reliability of the data produced by the system. … If the audit team determines that a noncompliance is not a significant deficiency/material weakness, the team should consider whether prudent officials, having knowledge of the same facts and circumstances, would likely reach the same conclusion (i.e., that the official would conclude that he/she can rely on the information produced by the contractor’s system in the conduct of his/her duties and responsibilities).
(Emphasis in original.)
So, yeah. Based on the foregoing, you might be thinking that DCAA HQ is telling its auditors that they don’t actually need to find any significant deficiencies in order to report them. Instead, all they need is to demonstrate a “reasonable possibility” that the contractor’s practices might not comply with governmental laws and regulations. And if by chance the auditors conclude that there is no reasonable possibility of that actually happening, then they need to reconsider and think about whether “prudent officials” (e.g., senior policy-makers at Fort Belvoir) would agree with their conclusion.
Could the bar have been set any lower? Could the subtext have been made any clearer? We don’t think so.
Okay, moving on. In case you were wondering about this article’s title and have been waiting impatiently for us to get to the part about the end of the issuance of Flash Reports, well here you go.
The same MRD announced the demise of the poorly thought-out and poorly implemented Flash Reports. Those reports were intended to flag detected/suspected internal control failures, but (in our view) the whole concept was a failure. The problem, as many of us know all too well, was that DCAA never had the bandwidth to follow-up as its audit procedures required. And DCMA never cared about the Flash Reports in the first place; typically, the DCMA ACO wanted a full-scope audit report before taking action. So the Flash Reports themselves, which at first seemed so ominous and scary, lost all urgency after about the tenth one received. It became kind of a joke, really. So we will all be glad to see them disappear.
But The King is Dead/Long Live The King.
DCAA introduced a new type of audit report to replace the Flash Report—the Deficiency Report. Here how DCAA described the new report (emphasis in original)—
GAGAS … require auditors to include in the report deficiencies, or a combination of deficiencies, in internal control that are less severe than material weaknesses (and, hence, also less severe than a significant deficiency as defined by the DFARS), yet important enough to merit the attention of those charged with governance (i.e., responsible contractor management officials). …
Upon completion of the separate Billing Audit and Control Environment Audit sub-assignments, the results will be summarized in a memorandum for record (MFR) to be reported as a part of the … Accounting System Audit. If a significant deficiency/material weakness is identified as a result of those audits, auditors should generally not wait for the completion of the Accounting System Audit to report the deficiency…. Instead, a deficiency report should be issued under the Billing Audit and Control Environment Audit sub-assignment number …
Because of the importance of timely communication of deficiencies, it also may be appropriate in some cases to issue an audit report on a significant deficiency/material weakness identified in an in-process business system audit (e.g., prior to completion of the Billing Audit or Control Environment Audit sub-assignment). In those cases, the auditor will … set up a separate assignment using the new 11070 Deficiency Report subactivity. The new subactivity code also is used to report deficiencies identified in other than business systems audits ... The Deficiency Report Assignment should not be established until there is sufficient evidence that a significant deficiency/material weakness exists and the elements of a finding for the deficiency are fully developed in the originating in-process business system audit….
The Deficiency Report Assignment is an integral part of the originating GAGAS examination engagement (e.g., incurred cost audit), not a separate examination. As a result, it is not necessary to document in the deficiency report assignment many of the procedures generally required to comply with GAGAS for an examination, since the GAGAS procedures would be documented in the originating GAGAS examination engagement. The deficiency report assignment working papers will reference the originating assignment and include the working papers from that assignment that contain support for the noncompliance with the DFARS criteria. …
If the evaluation of the identified noncompliance with the DFARS criteria and the elements of a finding were not fully developed in the originating assignment … the auditor should perform procedures to accomplish that as part of the Deficiency Report Assignment so as not to delay issuance of the report on the originating examination. However, such effort should generally not be extensive since the objective is not to evaluate the contractor’s compliance with all aspects of the applicable DFARS criterion or criteria but only to establish whether the noncompliance identified in the originating audit is a material noncompliance; and, therefore, represents a significant deficiency/material weakness or is less severe than a significant deficiency/material weakness, yet important enough to warrant the attention of responsible contractor officials. In either case, the noncompliance will be reported in the deficiency report.
Whew. Sorry about that, readers. But we felt it best for you to see, first-hand, what DCAA intends for its new Deficiency Reports. As you can tell, there are only subtle differences between the old Flash Reports and the new Deficiency Reports.
So the bottom line is that DCAA is moving forward in implementing the new DFARS Business System administration rules in the manner that many of us feared and warned the DAR Council about. The audit agency is redefining “significant deficiency” in a manner that is contrary to the plain, explicit, definition promulgated by the DAR Council—in essence, revising Federal regulations illegally and without soliciting any public comment.
DCAA has published audit guidance that warns auditors to think—and then think again—before giving contractors’ accounting systems a clean bill of health. Yeah, so much for independence and objectivity.
Finally, DCAA has put a stake in the heart of its ill-advised Flash Report methodology; but, like a Frankenstein monster, the audit agency has resurrected and reconstituted its reporting into new Deficiency Reports.
We are disappointed and disheartened that, once again, DCAA has chosen an adversarial position that actually inhibits timely and accurate audit reports. Disappointed and disheartened, yes. Surprised? No.
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The Allowability of IR&D for Defense Contractors
 Defense contractors spend considerable amounts on “independent” research and development (IR&D or IRAD) efforts. They need to, if they are going to compete for next generation-type defense programs. As our readers likely know, defense contractors’ IR&D expenditures are largely (if not entirely) reimbursed by the U.S. Federal government through payment of indirect costs allocated to direct contract costs—generally in the General & Administrative (G&A) expense rate.
Accounting for IR&D costs can be tricky, as we discussed in this article that covered the Appellate decision in the matter of ATK Thiokol, which so far is the leading precedent regarding how to account (and allocate) IR&D expenses. As we commented in the ATK article—
The Court had to interpret the FAR 31.205-18 cost principle, CAS 402, and CAS 420 in arriving at its decision. The parties’ contentions turned on the meaning of the phrase ‘required in the performance of a contract.’ Allowable IR&D costs are those that are not required in the performance of a contract, but the issue was whether the words meant ‘specifically’ or ‘expressly’ required, or whether they meant ‘implicitly’ required.
As you can see, properly accounting for IR&D costs involves inter-leaving the FAR Cost Principles and at least one (and likely more than one) Cost Accounting Standard. It’s not easy, especially for defense contractors, who also need to look the supplemental Cost Principles in the DFARS.
Another emerging challenge for defense contractors has been the Pentagon’s heightened sensitivity to its reimbursement of contractors’ IR&D expenditures. Like most everything involving Federal funds these days, DOD has been looking at how it can maximize the bang it receives for contractors’ IR&D bucks. We first mentioned the issue in July, 2010, right here, where we wrote that two of Dr. Carter’s “Better Buying Power Initiative” objectives were:
A few months later, Dr. Carter clarified what he meant by the phrase, “encourage effective use of IRAD.” He wrote that the goal was to increase the Pentagon’s focus on contractor IR&D expenditures, so as “to improve the return on IRAD investments for industry and government.”
Dr. Carter’s goal was to be implemented through revisions to the DFARS (the Defense Federal Acquisition Regulation Supplement). We wrote about the proposed revisions, and commented on the additional conditions they would create for many defense contractors. The rule was finalized recently so that, for the large defense contractors (i.e., those that have more than $11 million in reimbursed IR&D costs), in order to have their IR&D costs be allowable, they must submit annual reports to the Defense Technical Information Center (DTIC). And the project information (and associated costs) will be reviewed by DOD oversight officials to ensure that they are “of potential interest to DoD.”
And, unsurprisingly, those reviews are creating some challenges for defense contractors.
Reports are beginning to emerge from several large contractors that the reviews are not going as smoothly as one might have hoped.
The first issue is that DOD reviewers seem to be taking a narrow view of what types of IR&D projects might be “of potential interest” to the Pentagon. Contractors have been provided with an April, 2011, letter from then-Secretary of Defense Robert Gates that lists seven “Science and Technology Priorities” for the Defense Department. The worry is that these seven “strategic investment priorities” define and limit the types of R&D projects that the Pentagon wants to pay for, such that any project that cannot be shoehorned into one of the seven priorities will have its costs disallowed by DCAA and/or DCMA.
Issues that have received negative comments from reviewers include—
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Projects that were started but were subsequently abandoned, especially those that were of a higher dollar value or a large percentage of total IR&D expenditures
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“Shoestring” projects that were started but given insufficient budgets, given the project objectives
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Projects clearly outside the current capability and/or expertise of the contractor (i.e., attempts to enter new technology markets)
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Projects that have incomplete, unclear, or insufficient cost data
In addition, contractors being reviewed are expressing concerns (privately and without attribution) regarding the qualifications of the reviewers. They wonder whether the DOD reviewers have sufficient technical expertise to understand the projects they are reviewing, which are—by definition—state of the art or even just beyond state of the art efforts.
As a practical matter, large defense contractors who qualify for IR&D reviews might want to assess where they are against DOD’s expectations. They should be prepared to defend why their efforts (a) fit into the Technology Roadmap, and (b) why the Technology Roadmap ties to the Pentagon’s strategic science and technology priorities.
Looking at the bigger picture, we wonder if naysayers weren’t correct in worrying that the Defense Department’s renewed focus on contractor IR&D expenses wouldn’t tend to stifle innovation and technology development. If the Pentagon’s vision is an implementation of centralized planning and control that will act to channel contractors’ technology development efforts into only approved channels, then we don’t think that’s going to work out in the long run.
Just ask the former Soviet Union how that centralized planning and control thingee worked out for them.
Navy’s OASIS Program All Wet Because of Mismanagement, According to DOD IG
 The U.S. Navy’s “Organic Airborne and Surface Influence Sweep” (OASIS) Program is an ambitious ACAT II program, established in 2002, with the objective of developing a new towed minesweeping system. When operational, OASIS will conduct “influence minesweeping”—which is (as we understand it) the use of a helicopter to tow an object that mimics a ship’s magnetic or acoustic signature and, when the object passes near to a mine that detects such signatures, the decoy will cause the mine will explode. In the past 10 years, the Navy has spent about $112 Million in RDT&E funds pursuing development of OASIS.
The DOD IG reviewed the OASIS Program “to determine whether the Navy was effectively preparing the program for the low-rate initial production phase of the acquisition process.” The DOD IG will be issuing two audit reports. The first audit report, DoDIG-2012-081, was released April 27, 2012. Its focus was to determine “whether the Defense Contract Management Agency (DCMA) was providing effective support to the Program.
The audit report discussed DCMA’s various oversight and support roles, and provided a decent summary of the regulatory requirements imposed on DOD. We were interested to read the following paragraph—
The DCMA Major Program Support Instruction, November 2010, (the DCMA Support Instruction) provides policy and guidance for performing the contract management functions listed in the FAR. Specifically, the Instruction provides the DCMA staff with direction when supporting the program, product and project offices regarding program reviews, program status, program performance and actual or anticipated program problems, including direction to establish:
- a MOA with the program manager that focuses on desired program outcomes,
- a program support plan that details the tasks needed to meet the provisions of the MOA, and
- a program integrator to manage the program support team and perform the tasks documented in the program support plan.
In addition, the Instruction provides policy and guidance on the program integrator and program support team responsibilities for monthly program assessment reports, cost, schedule, and technical analysis; EVM assessments; and integrated baseline reviews of major programs.
The foregoing (along with other items) established the baseline against which the DOD IG reviewed the relationship between DCMA and the OASIS Program.
There was a fair amount of churn within DCMA. The DOD IG audit report stated that, over the past decade, three separate DCMA offices have had oversight responsibility over the OASIS program. According to the audit report, the three DCMA offices were—
- DCMA Garden City, in Garden City, New York (April 2002 to February 2008);
- DCMA Huntsville, in Huntsville, Alabama (February 2008 to June 2010); and
- DCMA Orlando, in Orlando, Florida (June 2010 to present).
Given the churn and hand-offs between DMCA Contract Management Offices (CMOs), it probably was unsurprising that the DOD IG found some issues of concern. Specifically, the DOD IG “identified internal control weaknesses in the Navy’s management of the OASIS contract.” Specifically, the DOD IG—
… determined DCMA officials and the Program Manager, Mine Warfare (Program Manager), did not effectively transition the program integrator and a program support team for the OASIS contract in February 2008. Additionally, the Program Manager did not request DCMA program management support after the MOA with DCMA expired. We also determined that the Program Manager relied on a support contractor to provide data analysis that DCMA could have provided at no cost to the program.
The DOD IG audit report found several instances of communication failures between the various DCMA CMOs. The audit report stated—
On February 26, 2008, DCMA Garden City transferred the OASIS contract administration responsibilities to DCMA Huntsville after the prime contractor moved from Amityville, New York, to Panama City, Florida. The administrative contracting officer at DCMA Huntsville stated that she thought that the OASIS contract was sent to her for close out because there were minimal unliquidated obligation funds on the contract. Subsequently, DCMA Huntsville transferred OASIS contract administration responsibilities to DCMA Orlando on June 5, 2010, due to an organizational realignment. When asked, DCMA could not provide documentation showing communication between the two DCMA offices.
The DOD IG found that the Director of DCMA (Orlando) admitted that he did not even know he was responsible for the OASIS Program until April, 2011, nearly a year after the Program was transferred to his office for contract administration. (April 2011, was when DOD IG performed its audit. Had the IG not performed an audit, the DCMA (Orlando) Director well might still be blissfully unaware of the contract under his cognizance.)
Once the oversight was brought to his attention, the DCMA (Orlando) Director took immediate action. According to the audit report—
As a result of our audit, on April 22, 2011, the Director, DCMA Orlando, assigned a program integrator and a six-person program support team that included an engineer, an EVM System specialist, two quality assurance specialists, and two administrative contacting officers to the OASIS Program. Since being assigned to the OASIS Program, the program integrator and the program support team have regularly attended meetings, visited the prime contractor facility in Panama City, Florida, and issued five Program Assessment Reports to the Program Manager. Program Assessment Reports are independent DCMA assessments of contractor performance with details including actual costs versus budgeted costs, performance schedule, and the way forward. …
On September 13, 2011, the Director DCMA Orlando, stated that the DCMA Chief Operating Officer approved an additional personnel resource to support the OASIS contract. DCMA also changed its policy as a result of our audit that will ensure that all Acquisition Category I and II programs receive continuous DCMA support.
So here’s the thing. Remember when we told you about the organizational and people challenges that DCMA had imposed on itself through mismanagement? Remember when we reported that DCMA was reorganizing to better manage its mission?
Yeah, we don’t think those changes would really prevent the missed hand-offs experienced by the OASIS Program. The churn was the problem. That, and a lack of follow-through. Those problems stem from a lack of ownership, and not from an organizational alignment issue.
We need DCMA Contracting Officers and other functional specialists to own their roles on the programs they support—own them and take pride in the important jobs they do, helping the taxpayers get value for obligated funds and helping the warfighters get the systems they need to defend our nation.
In our view, what we need is a change in mindset, or a change in culture. We don’t need more rearrangements of the deck chairs.
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