FAR (Federal Acquisition Regulations) 34.2 requires contractors that receive awards for major acquisitions for development to have an EVMS (Earned Value Management System) that complies with ANSI/EIA (American National Standards Institute/Electronic Industries Alliance) Standard 748. The idea here is that if implemented properly, the EVMS will provide an early warning of cost overruns and schedule delays.
Contractors required to implement ANSI/EIA compliant EVMS however know full well that the cost of compliance is significant. By OFPP's (Office of Federal Procurement Policy) own estimate, the cost of certification can exceed $1 million. In addition, some contractors are finding that once they achieve certification of its system from one agency, find that other agencies will not recognize that certification and will insist on performing their own certification at additional cost to the contractor (and to the Government program).
Contractors have observed that the certification processes used by some agencies are very similar. They should be because they all work off of essentially the same "audit" program. Last year's Open Dialogue on Improving Federal Procurement raised many concerns over eliminating or reducing duplicative processes as one avenue for improving the Federal procurement process. Chief among those concerns was the repetitive and expensive EVMS certification processes borne by contractors.
To reduce such repetitive and expensive certifications, the OMB's Office of Federal Procurement Policy, is encouraging agencies to share the details and results of their EVMS certifications and enter into reciprocal agreements with other agencies and to post their EVM processes and procedures on their public websites. Sharing such information should help identify redundancy in the certification processes. If an agency determines that its certification process is substantially similar to the certification process of another agency, the agency should consider whether it is feasible to enter into an agreement with the other agency for the mutual recognition of the EVMS certification.
There is a role for contractors in this new procedure. The procedure does not establish a central repository for EVMS certifications and agencies are not likely to poke around in other agencies websites to determine whether any certifications have been completed. Therefore, contractors need to alert pending EVMS certification teams if a previous certification has been completed and ask that they consider relying on the results of that certification.
OMB's guidance on this matter can be found here.
. , These observations have reached the attention of the OMB's Office of Federal Procurement
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