CSA QUESTIONS EVMS RULE

In commenting on the proposed rule to implement earned value management systems (EVMS), the Contract Services Association (CSA) noted:

Without question, EVMS raises the bar in terms of providing visibility into whether a program is on target with respect to cost, schedule, and technical performance. CSA believes that, appropriately used, EVMS can be an effective project management tool. EVMS can serve as an early warning system to alert the parties – both the Government and the contractor – to potential or actual problems in a program. However, the proposed rule is devoid of any acknowledgment that EVMS imposes a significant additional obligation upon as well as potential risk to contractors, or that such obligation and risk carry a price.

There needs to be some recognition in the rule that EVMS – like other complex disciplines – is not an exact science, and that even despite a contractor’s best efforts, a program may encounter problems. Indeed, cost, schedule, and technical problems have been encountered in major defense and space programs that currently employ EVMS. Mere awareness of a potential/actual variance in cost/performance/technical parameters does not by itself point to a cause, let alone a solution. Particularly on large and complex programs, it is impossible to predict at the outset precisely how the work will progress.

If EVMS is to succeed, there needs to be a concomitant obligation on the Government’s part to communicate with the contractor promptly and in writing what, if any, action should be taken to rectify a problem. A contractor should not be put in the position of having to guess where it stands, only to be informed retroactively that it is noncompliant. It would be counterproductive to use EVMS in a “gotcha” mentality.

In short, EVMS is not a panacea. It does not prevent problems from arising, nor does it present a means for correcting them. It is merely an indicator, not a solution. It will take time, effort, and patience on the part of both the Government and industry to make EVMS work. Unrealistic expectations about what EVMS can do will lead to mistrust, a breakdown in communication, and, ultimately, litigation – resulting in delay and disruption in contract performance – the very problems EVMS is designed to avoid.

There is no such thing as a “one-size-fits-all” approach to implementing EVMS.  Therefore, because of the complexity and far-reaching implications of EVMS, CSA recommends that the Federal Acquisition Regulations (FAR) Council either consider holding a public meeting to provide an opportunity for interested parties to engage in a dialogue prior to publication of a final rule, and/or issuing a second proposed rule following receipt and analysis of public comments.

A copy of the CSA comments can be found on the CSA website at www.csa-dc.org.

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CSA is the nation’s oldest and largest association of service contractors representing over 200 companies that provide a wide array of services to Federal, state, and local governments.  CSA members perform over $40 billion in Government contracts and employ nearly 500,000 workers, with two-thirds of CSA companies using private sector union labor.  CSA members represent the diversity of the government services industry and include small businesses, 8(a)-certified companies, small disadvantaged businesses, women-owned, HubZone, Native American owned firms and global multi-billion dollar corporations.  CSA promotes Excellence in Contracting by offering significant professional development opportunities for government contractors and government employees, including the only program manager certification program for service contractors.  For more information on CSA, go to:  www.csa-dc.org.