1. CPM WDC – Panel on EVM Waiver
27 Aug 2019
Bill McMahon
Lead EVM SME
HHS/ASPR
Integrity Management Consulting, Inc.

2. EVM and the Pushback
DoD is more mature in terms of Acquisition and Project Management capabilities
EVM is by extension more mature in DoD area
Policy and requirements are more robust
Civilian Agencies have different degrees of PM and EVM capabilities
Policies, thresholds, and requirements vary

3. Policy FAR OMB A-11 Agency Specific EPA - CIO 2120.P
DFARs (DoD FAR supplement) 234,
DoD 5000
HHSAR 334.2
NASA FAR Supplement 1834 & 1852
DOE O 413.3B
DOT/FAA Order
EPA - CIO 2120.P
Most agencies follow DoD lead, NDIA guide

4. DoD $20M-$100M requires EVM compliance (EIA 748)
>$100M requires an EVM System validation (used to be $50M)
PoP > or = 18 months (used to be 12)
PARCA responsible for EVM performance, oversight and governance
ICAT 1D and IAM can get waivers if conditions met and DAE/CAE approve
For ACAT ID and IAM programs, OSD USD (AT&L) PARCA, in consultation with the CAE or designee, will review proposed contract work scope for EVM applicability and provide a recommendation to the DAE/MDA for a determination of EVM applicability. For all other ACAT levels, the CAE, or designee, will review and determine EVM applicability. If EVM is determined to apply, then threshold application in this table is utilized or a waiver from the CAE is required. If, based on the nature of the work, EVM is determined not to apply, then EVM is not placed on contract.

5. HHS >/= $20M requires EVM compliance (EIA 748)
>/= $50M requires an EVM System validation by a cognizant federal authority (CFA)
PoP >/= 12 months
ASPR/BARDA
TRL less than 7 “Advanced R&D”
7 Principles
No validation/surveillance mechanisms (compliance evaluation only)
OCIO and CMS generally follow HHSAR ($20M/$50M above)
Have their own EVM “best practices”

6. Class Deviations (CD) Procurement Class Deviations
NASA PCD-1505 deviates from FAR;
Raise of the compliance review threshold from $50M to $100M (similar to DoD/DFARS)
Adds provision for ‘Class D’ projects <$150M
DoD DFARS
Compliance Review (via DCMA) increase fro $50M to $100M
E.g. – Army CD for FPIF FRP contracts exempt from DFARS 234.2

7. Class Deviations (CD) – Cont.
ASPR/BARDA – Deviates from FAR
Not a ‘Major System’ as defined in FAR 34
Unique nature of projects (Medical Countermeasures/MCMs, Life Sciences)
Contracts requiring EVM are evaluated for compliance with 7 Principles
BARDA Program PCT (similar to IPT, or loosely, PMO) makes recommendation to BARDA contracts whether or not to require an EVMS