3Financial Management Scope Commitment Reprogramming Planning, ProgrammingBudgeting & ExecutionLife CycleCostEstimateAnnualFundingICECostAnalysisFundingPoliciesFYDP DPG PDM PBDFullFunding (Exceptions)MFP POM BESCAIVCCAIncrementalFundingMBIsFiscalEnvironmentPOECongressionalEnactmentPresident’sBudgetHAC HASC HBCBudgetResolutionAuthorization&AppropriationLawsSAC SASC SBCIntroduce student to subject of Funds Management.Why study it? -- Money is lifeblood of program. Learn how to get it and keep it.Walk through “Cloud Chart” - the funds management portions of acquisitionStress that process is not as straightforward as it appears due to having to deal with multiple years’ of money -- several of these processes may be operating on your program simultaneously.APBOperationalConceptForce StructureModernizationOperational CapabilityReadinessSustainabilityCommitment ReprogrammingFeedbackICDBudget Authority Obligation OutlayBudgetExecution
5AffordabilityPrograms must be consistent with overall DoD planning and funding prioritiesApplies to all programsFoster greater program stability:Fully Funded in the FYDPAssess affordability at each milestoneCAIG and CPIPT shall address affordabilityBasic concept is that components must put their money where their mouths are.Components must decide early on which programs are affordable and then provide sufficient resources for them in the FYDP (“fully fund”) -- reduces funding uncertainty and therefore makes program more stable.The DAB is now requiring programs to be funded at the CAIG estimate (usually more conservative – higher).
6Cost As An Independent Variable (CAIV) Essential to balance three significant parameters or variables in acquisition programs:CostSchedulePerformanceTwo of those variables are dependent on the third.Under CAIV philosophy, performance and schedule are dependent on costApplies to all programs by end of FY 02CAIV is an extension of all other acquisition reform efforts.CAIV requires that at Program Initiation, the PM set cost objectives and thresholds for the four major cost categories previously discussed: R&D, Investment, O&S, and Disposal. Thus CAIV looks at Life Cycle Cost.Cost/Performance IPT is empowered to recommend performance or engineering / design changes which lower cost but still permit performance and schedule thresholds to be achieved.Changes which negatively impact threshold values must be approved by ORD/APB approval authorities to ensure mission needs can still be met.“CAIV flagship” programs:- Army: ATACMS/BAT (P3I), Crusader- Navy: AIM-9X, MIDS- Air Force: SBIRS, JASSM, EELV- JSFCAIV success stories:- Joint Direct Attack Munition (JDAM) -- claims 66% production cost savings- MIDS redesign for 100% performance, 50% cost
7Nunn-McCurdy Breach Implications Law requires cancellation of acquisition program with 25% or greater unit cost overrun unless DAE provides specific “certifications”Certifications required to continue program:Program is “vital” to national security;There are no alternatives that provide equal or greater capability at less cost;Latest cost estimates for program are reasonable; andThe current acquisition strategy is adequate to manage and control cost.
8Nunn-McCurdy Breach Implications (cont.) Program cancelled under provisions of Nunn-McCurdy unit cost breach:Area Missile Defense Program (Navy; 65% cost growth)Programs currently “on – watch” for cancellation:CH-47 Chinook Helicopter Upgrade (Army; 117%)Guided Multiple Launch Rocket System (Army; 153%)Chemical Demilitarization (Army; 80%)Space Based Infrared System High (Air Force; 66%)LPD-17 Amphibious Ship (Navy; 75%)UH-1 Huey Helicopter Upgrade (Marine Corps; 68%)
9Major Appropriation Categories APPN CATFUNDING POLICYOBLIGATION PERIODSCOPE OF WORK EFFORTRDT & ERDT&E Activities & Exp, Minor Const & AIS R&D FacIncremental2 YearsPROC(SCN)Production Labor/HW, Initial Spares, HW & AIS E/SW>$250KFull3 Years5 Years - SCNO&MReplenishment Spares, Civilian Salaries, Travel, Fuel, Supplies, Minor Const<$750K, H/W & AIS E/SW <=$250KAnnual1 YearDollar thresholds for O&M just were raised from $100K to $250K in Joint Appropriation Resolution in 2003.MILCON thresholds changed in Authorization Act for FY 2002MILPERSMilitary Pay & Allowances, PCS Moves, Retired Pay AccrualAnnual1 YearMILCONMajor Construction Projects >$750KFull5 Years* Minor Construction threshold changed by FY2002 Authorization Act, O&M threshold changed by Joint Appropriation Res. FY 2003
10Severable ServicesMay enter into a contract for severable services that begins in one fiscal year and ends in the next fiscal year if the contract period does not exceed one yearFunds made available for a fiscal year may be obligated for the total amount of the contract
11Multi-Year Service Contracts Operations & MaintenanceContinuing requirement for servicesFurnishing of services will require substantial initial investment in plant/equipment, or incur substantial contingent liabilities for the assembly, training, or transportation of a specialized work forceThe use of such a contract will promote the best interest of the U.S. by encouragingcompetition and promotingeconomies of operation.
12Multi-Year Service Contracts (cont.) O & M - Covered ServicesOperation, maintenance and support of facilities and installationsMaintenance or modification of aircraft, ships, vehicles, and other highly complex military equipmentSpecialized training necessitating high quality instructor skills (eg. Pilot and aircrew members; foreign language training)Base services (eg. Ground maintenance; plane refueling; bus transportation; refuse collection and disposal.)Chapter 137 of title 10, United States Code, Sec 2306C, Multiyear ServicesContracts. (Originated in 2000 Authorization language).
13RDT&E - 18 Month Exception There are requirements in which there is no logical way to divide the work, it is clearly unfeasible to limit the contract to a shorter period; or the planned technical effort is such that no responsible contractor can be found who will accept a contract for a less than completion increment. For these type of efforts that take longer than 12 months, but less than 18 months, the Service or Defense Agency Comptroller may approve financing the total requirement in one fiscal year.
14Funding Rules for Communications & Information Systems Procurement - Investment- New Equipment / SW > $250K- Upgrades / Replacement Equipment > $250KO&M - Expenses- New Equipment / SW < $250K- Upgrades/Replacement Equipment < $250K- Routine maintenance, LeaseRDT&E- Development, test and evaluation costs- Development of major upgrades- HW / SW for RDT&E Facilities < $250KADPE usually follows the general rules pertaining to funding of Investment and Expense items. The rules on this slide apply to both General Purpose and Special Purpose ADPE.Although equipment is usually purchased with Procurement, hardware for RDT&E-funded facilities is to be purchased with RDT&E funds.General Purpose and Special Purpose ADPE funding rules diverge when it comes to development and/or purchase of software. Differences are addressed on the following slides.
15LRIP According to FMR - Designed to be flexible Article Use AppropriationDT or OT RDT&EOperational Use ProcurementTesting subsequent toacceptance ProcurementModification of Test Articles Procurement
16108th Congress The “Sitting Congress” for 2003 – 2004 (1st Session) HOUSESENATE435 MEMBERS100 MEMBERS-51 REPUBLICANS-229 REPUBLICANS-48 DEMOCRATS-205 DEMOCRATS-1 INDEPENDENT-1 INDEPENDENTHouse Independent is Bernie Sanders, VT.Senate Independent is James Jeffords, VT.Few with military experience
17SASC / HASC Subcommittees Different Subcommittee Titles in House and Senate Senate Armed Services SubcommitteesReadiness and Management SupportEmerging Threats and CapabilitiesPersonnelSeapowerStrategicAir-LandHouse Armed Services SubcommitteesTactical Air and Land ForcesReadinessTerrorism, Unconventional Threats and CapabilitiesTotal ForceStrategic ForcesProjection ForcesHASC has renamed subcommittees
18SAC / HAC Subcommittees Same Titles in House and Senate Agriculture and Rural DevelopmentCommerce, Justice, State and JudiciaryDefenseDistrict of ColumbiaEnergy and Water DevelopmentForeign OperationsHomeland SecurityInteriorLabor, Health and Human Services and EducationLegislative BranchMilitary ConstructionTransportation/Treasury and Postal ServiceVA, HUD and Independent AgenciesThese are the thirteen subcommittees of the appropriations committees. They are broken down along the lines of each appropriations bill.The Homeland Security Subcommittee was created with the 108th Congress in 2003, while at the same time combining Transportation and the Treasury and Postal Service subcommittees.Note that the VA, HUD, Independent Agencies bill includes funding for NASA, FEMA, IG offices, EPA, National Science Foundation, and the American Battle Monuments commission, to name a few.
19DoD Appropriation Structure Level of Control for “Below Threshold” Reprogramming PurposesRDT&EProcurementO&MMILPERSMILCONBudgetActivityBudgetActivityBudgetActivityBudgetActivityBudgetActivityThis slide shows level of control for three major appropriations. May be useful to show this prior to Below Threshold reprogramming slideProgramElementsLine ItemActivityGroupActivityGroupActivityGroupProjectsSub ActivitySub ActivityProject
20Below-Threshold Reprogramming ObligationAppropriationsMax InMax OutLevel ofControlPeriodRDT&EProcurementO&MMILPERSMILCONProgramElement$10MGreater of$10M or 20%2 YrsLine Item$20MGreater of$20M or 20%3 YrsBudget Activity$15MNone, unlessotherwise spec1 YrNoRestrictionBudgetActivity$10M1 YrLesser of$2M or 25%NoRestrictionProject5 Yrs* Over Threshold Reprogramming requires notification of Congress
21New Starts What is it? How do you determine a new start? Any new program, project, sub-project, task that you haven’t told Congress aboutHow do you determine a new start?Budget submission R-Forms and P-FormsWhy should you care?Congress mad at Air Force about thisCongress now watching other servicesAppropriation Law says you won’t get paid, if you don’t follow the rules
22New Starts (cont.)Any New Starts over $10M RDT&E or $20M Procurement in first three years requires written Congressional approval in the Authorization ActIf your program has not been approved in the Authorization Act, you must get written approval of the Congressional Authorization committees.Programs under this dollar threshold must do a letter notification to Congress and wait 30 days
23Congressional Interest HAC-D issued strong language in FY 00 House report criticizing DoD for initiating new programs without proper notificationIdentified specific programsCited lax managementFY 01 Appropriation Bill Sec 8091“None of the funds in this Act may be used to compensate an employee of the Department of Defense who initiates a new start program without notification to the Office of the Secretary of Defense, the Office of Management and Budget, and the congressional defense committees, as required by Department of Defense financial management regulations.”
24OSD Goals – End of 1st Year RDT&EObligations 80%Expenditures 55%ProcurementAdvance ProcurementObligations 100%Services are more stringent: i.e. Navy end of first year, 94% obligations, 58% expenditures
25Contract Funds Status Report (DD Form 1586)Required to obtain funding data on contracts over six months in durationNo dollar threshold specified but generally applicable to non- firm fixed priced contracts in excess of $1.2 million (in FY 96 constant dollars)Purpose of CFSR is to assist Components in:Updating and forecasting contract fund requirementsPlanning and decision making on funding changesDeveloping fund requirements and budget estimates in support of approved programsDetermining funds in excess of contract needs and available for deobligationObtaining rough estimates of termination costs
27Termination Liability No laws or regulations governing how to cover/budget for termination liabilityTermination liability over $100M requires written notification to the Congressional Defense Committees at least 30 days prior to contract award.MYP contracts cannot be terminated without notifying Congress 10 days prior
28Execution Laws Misappropriation Act (Title 31, U.S. Code, Sec 1301) Requires funds to be used only for the purposes and programs for which the appropriation was made.AKA “The Purpose Statute”Anti-Deficiency Act (Title 31, U.S. Code, Sec 1341 & 1517)Prohibits making or authorizing an obligation in excess of the amount available.Forbids obligation to pay money from the US Treasury in advance of an appropriation.Requires agency to fix responsibility for violations of the Act.The Misappropriation Act requires that funds be used only for the programs and purposes for which the appropriation is made.Examples: Multiple sidewalks to build an airfield because no MILCON appropriatedProduct Improvement interpretation of improving system performanceThe Anti-Deficiency Act prohibits authorizing an appropriation in excess of the amount available in an appropriation, or in advance of an appropriation.Examples: Any action resulting in overobligation or overexpenditure (including clerical errors), signing contract in advance of appropriationDo an exercise here - Good & Plenty, Jack & the Beanstalk (?)TRANSITION:Sometimes, programs require more funds than they asked for or were appropriated. This can happen for many reasons, including changed requirements, revised cost estimates, etc. If the Misappropriation Act prevents us from using funds for other than their named purposes and programs, how do we deal with the program’s funding problem? Reprogramming authority provided by Congress is the answer.Bona Fide Need RuleRequires funds to be used only for needs or services in the year of the appropriations obligation availability period.
29OSD Budget Review Balance Requirements to Available Resources Topline Readiness vs ModernizationAddress Administration / DoD PrioritiesNational ProgramsDefense Planning Guidance (DPG)Programming Decisions (PDM)QDRDuring an OSD Budget Review, these are things that get looked at:Assuring that you meet Priorities of Administration & DoD- Bottoms-Up Review- Concern with National ProgramsApplication of Acquisition Initiatives:- Defense Reinvestment- Support of Industrial Base- CAIV
30OSD Budget Review (cont.) Address Departmental InitiativesReadiness Levels/OPTEMPO RatesQuality of LifeDefense Reform InitiativeInfrastructure SavingsModernization TargetAffordabilityScience & TechnologyDuring an OSD Budget Review, these are things that get looked at:Assuring that you meet Priorities of Administration & DoD- Bottoms-Up Review- Concern with National ProgramsApplication of Acquisition Initiatives:- Defense Reinvestment- Support of Industrial Base- CAIV
31OSD Budget Review (cont.) Acquisition InitiativesProgram StabilityAcquisition ReformTotal Ownership CostADM/Baseline ConformityAssure Joint Programs Are ConsistentDuring an OSD Budget Review, these are things that get looked at:Assuring that you meet Priorities of Administration & DoD- Bottoms-Up Review- Concern with National ProgramsApplication of Acquisition Initiatives:- Defense Reinvestment- Support of Industrial Base- CAIV
32OSD Budget Review (cont.) Balanced / Coherent / Consistent BudgetBudget ScrubPrograms Are Properly PricedDevelopment / Production TransitionDuplicative ProgramsFollow-on SystemsSupport CostsBudget Execution RatesConform With Budget PoliciesDepartmental Outlay ProjectionsAccomodate Topline Resource Changes:- Subject to reprioritization of projects- Examine program growth- Update Economitc AssumptionsBalanced, Understandable and Consistent Budgets- Budget Scrub- Ensure proper pricing of programs- Ensure transition between phases supports program- Look at similar systems- Follow-on systems- O&S Costs- Check on execution rates of current program- Check conformity with budgeting policies- Check outlay projections
33OSD Balanced/Coherent/ Consistent Budget Program PhasingDevelopment / Production ConcurrencyAcquisition Schedule: Milestone Approvals, TestingFirst Quarter/Fourth Quarter new starts at riskProduction Lead-time/Non-recurring CostsFunded Delivery PeriodShould not exceed 12 monthsProgram PricingBasis of estimates for programs and cost exhibitsAnalysis of: Learning curves and Production ratesOSD Escalation IndicesContract data/Configuration changesBudget to most likely cost (Target / Ceiling)
34OSD Balanced/Coherent/ Consistent Budget Budget PolicyIncremental Funding - RDT&EFull Funding - Procurement, MILCONAnnual Funding - MILPERS, O&MExplanation of Funding AnomaliesAppropriation Cognizance (“Color” of Money)Budget ExecutionAnalysis of Accounting ReportsHistorical (3-5 years) track recordLikelihood budget request can be executedObligation Rates, Expenditure RatesAvailability of prior yr funds for budget yr efforts
35How to Survive Prepare for hearing Focus on Advance Questions Acquaint yourself with key OSD staffPrepare for hearingFocus on Advance QuestionsConduct an internal budget reviewEnsure your submission answers all their questionsUnderstand Issues:Budget policy, programmaticHearingLimit attendance at HearingFollow-up Hearing QuestionsAppeals - Address Specific PBD RationaleRecognize that outside “macro” issues will impactacquisition programsHow to survive:Get to know OSD staffBe PreparedAnswer questions completely, but do not give them more than they ask for or try to BS them.At Hearings, focus on questions. Limit attendance to those who need to be there, with one spokesman.Follow-up on hearing questionsDuring appeals - address the rationale in the PBDRecognize that outside issues with impact your program
36Impact Statements Tips for Effective Impact Statements: - Operational ImpactCapabilities to Warfighter/UserImpact to ProgramBelievable- Business CaseGreater Cost to the Government- Non-compliance with Policy
38Expired Funds Years 1 2 3 4 5 6 7 8 9 10 O&M RDT&E Ships MILCON ProcurementShipsMILCONMILPERSAvailable for ObligationAvailable for Outlay
39Expired Funds National Defense Authorization Act of FY 1991 Effective 1993Remains available for obligation adjustments and payments for 5 years after the obligation periodKeeps fiscal identity (appropriation, fiscal year, line item, etc.After 5 year period, all obligated and unobligated balances are cancelledAny additional payments funded out of current appropriation - Limited to lesser of:- 1% of current appropriation- Unexpended balance of cancelled appropriation
40Types of Reprogramming Congressional Prior Approval ReprogrammingInternal ReprogrammingBelow Threshold ReprogrammingReprogramming is the use of funds for purposes other than those contemplated by Congress at the time originally appropriated. These actions do not represesnt requests for additional funds from Congress, rather they involve the reapplication of resources within a particular appropriation.Guidance contained in the DoD Budget Guidance Manual (DoD M)Four types of Reprogramming Actions
41Congressional Prior Approval Applies to Actions Involving:- General Transfer Authority- Major System Procurement Quantity Increases- Congressional Special Interest Items- Amounts exceeding those specified for belowthreshold- Initiating a new start above $2M in the first year or $10M over a 3 year periodRequires:- Approval by Comptroller, DoD- Approval by HAC / SAC and HASC / SASC- Approval by House and Senate Committees onIntelligenceCongressional Prior Approval:Requires:- Approval by the Comptroller, Department of Defense- Approval by the HAC/SAC, HNSC/SASC and House and Senate Committees on Intelligence.Applies to actions involving:- General transfer authority - Provision in the Appropriation and Authorization Acts where transfers may be made between appropriations or appropriation subdivisions in the Acts. Made upon determination of SECDEF that such action is necessary in the national interest, and higher priority items, based on military requirements, than the items for which funds were originally appropriated, and in no case where the item for which funds are requested has been denied by Congress. Must also be approved by OMB.- Major system procurement quantity increases- Items that are designated as Special Interest.
42Omnibus Reprogramming DoD sends Congress one annual integrated package ofreprogramming requests containing all “Bills” and “Bill-payers”DoD/Congress will not revisit any rejected “Bills” or“Bill-payers”DoD prioritized Congressionally approved “Bills” andpays to the extent funds are available fromCongressionally approved “Billpayers”Major acquisition reprogramming requests sent toCongress on “exception” basis“Bills and Bill-payers”Approvals or Rejections
43Internal Reprogramming Applies to:- Reprogramming actions that do not involvechanges from the purpose and amounts justifiedin budget presentations to CongressRequires:- Approval by the DoD ComptrollerInternal ReprogrammingRequires:- Approval by the DoD ComptrollerApplies to:- Reprogramming actions that do not involve changes from the purpose and amounts justified in budget presentations to Congress
45Total Ownership Cost (TOC) Reduction of Total Ownership Cost (TOC) is an initiative of the Defense Systems Affordability Council (DSAC).“DoD TOC is comprised of costs to research, develop, acquire, own, operate and dispose of weapon and support systems, other equipment and real property; the costs to recruit, train, retain, separate and otherwise support military and civilian personnel; and all other costs of business operations of the DoD.”One of the many dimensions of DoD TOC is “Defense Systems TOC”; this is defined specifically as the “Life Cycle Cost (LCC) of that system” (further defined in DoD M). The PM should focus primarily on this dimension of DoD TOC and support reduction on DoD TOC through a continuous reduction of the system’s LCC.Reference: USD (A&T) Letter, Subject: Definition of Total Ownership Cost (TOC), Life Cycle Cost (LCC), and the Responsibilities of Program Managers, 13 Nov 98
46Total Ownership Cost (TOC)- Representative “Type” Costs Direct Costs of Acquisition System: Research, Development and Testing (Prime and Support Items); Production (Prime and Support Items); Initial Spares; Construction of Unique Facilities; Manpower Costs; Disposal CostsPM Primary Focus: The “Life Cycle Cost” of the specific acquisition systemIndirect Costs Attributable to System: Program Management/System Program Office (PMO/SPO) operations; Other Infrastructure that plans, manages and executes the acquisition program; Training of Personnel; POL; Ammunition; Replenishment spares; Maintenance$ $ $ $ $ $ $ $ $ $ $Indirect Costs of Command Infrastructure not directly involved with System : Operational Command HQ; Service HQ; OSD; Recruitment, training, retaining and separation of military and civilian personnelPM Interest (Beyond PM Influence and Control) : Generally, based on an incremental “fair share” that might be assigned to or associated with an Acquisition SystemIndirect Costs of Installations where Deployed: “Routine” BASEOPS (e.g., Maintenance of Grounds and Buildings; Snow Removal; Chapel; etc.); Personnel and Support - Related Costs at Post, Base or Ship
47FY99 C-5 Budget Justification BUDGET ITEM JUSTIFICATION(EXHIBIT P-40)DateFebruary 1998APPROPRIATION/BUDGET ACTIVITYAIRCRAFT PROCUREMENT-AIR FORCE/Aircraft ModificationsP-1 ITEM NOMENCLATURE: C-5This line item funds modifications to the C-5 aircraft. The four engine C-5 carries outsized and heavy cargo (tanks, helicopters, etc.) between main operating bases. The primary modificaiton budgeted in FY99 is the TF-39 High pressure Turbine (HPT). Other modifications enhance operational capability while improving flight safety, reliability and maintainability. The specific modifications budgeted and programmed are below.MOD MODIFICATION COST TOTALNR TITLE FY-97 FY-98 FY-99 FY-00 FY-01 FY-02 FY-03 TO GO PROG.3150 NAVSTAR GLOBAL POSITIONING4252 AIRLIFT DEFENSIVE SYSTEMS6032 COMPARTMENT FLOOR CORROS6037 TF39 ENGINE HIGH PRESSURE6038 AVIONICS MODERN PROGRAM96001 STATION KEEPING EQUIPMENT96004 SINCGARS99999X LOW COST MODIFICATIZ88888 REPROGRAMMINGSTOTAL FOR CP-1 SHOPP LISTITEM NO. 035PAGE NO.214
48Case Study - C-5 AMP Requirement Budget Justification FY 98 DEPSECDEF direction - passenger safety high priorityAir Force decides to start Traffic and Collision Avoidance System (TCAS) effort on the C-5 in FY 99 instead of FY 00Budget JustificationFY9 9 President’s Budget (PB) showed C-5 AMP (Avionics Modernization Program) totaling $600M beginning in FY 00TCAS effort included as part of overall C-5 AMP programAnswer to Congressional Inquiry (Aug 98) states AF intent to accelerate TCAS portion of C-5 AMPDuring Staffer Days (Feb 99) briefed House Appropriations Committee (HAC) staffer - intent to accelerate TCAS portion of AMP from FY 00 to FY 99Decision - New Start Notification Not RequiredAF believed Congress notified and agreed with approach
49FY00 C-5 Budget Justification BUDGET ITEM JUSTIFICATION(EXHIBIT P-40)DateFebruary 1999APPROPRIATION/BUDGET ACTIVITYAIRCRAFT PROCUREMENT-AIR FORCE/Aircraft ModificationsP-1 ITEM NOMENCLATURE: C-5This line item funds modifications to the C-5 aircraft. The four engine C-5 carries outsized and heavy cargo (tanks, helicopters, etc.) between main operating bases. The primary modificaiton budgeted in FY00 is the TF-39 High pressure Turbine (HPT). Other modifications enhance operational capability while improving flight safety, reliability and maintainability. The specific modifications budgeted and programmed are below.MOD MODIFICATION COST TOTALNR TITLE FY-98 FY-99 FY-00 FY-01 FY-02 FY-03 FY-04 FY-05 TO GO PROG.3150 NAVSTAR GLOBAL POSI4252 AIRLIFT DEFENSIVE SYS6032 COMPARTMENT FLOOR6037 TF39 ENGINE HIGH PRE6038 AVIONICS MODERNIZATI96001 STATION KEEPING EQUIRADIO99999X LOW COST MODIFICATIZ88888 REPROGRAMMINGSTOTAL FOR CP-1 SHOPP LISTITEM NO. 33PAGE NO.1
50Case Study C-5 AMP - Lessons Learned Discussion$9.7M spent in FY 99 for TCAS, using funds from other C-5 modification effortsFY 00 PB sent to Congress with FY 99 updatesBudget depicted $9.7M for C-5 AMP (which was not supposed to start until FY 00)HAC criticism published in NY TimesAppearance that Air Force diverted funds from Congressional special interest item to fund the new startConclusion - Formal Congressional Notification RequiredStaffer Day briefing does not constitute notificationKEY POINT: Formal Notification