10 U.S.C. Chapter 144A – Major Automated Information System (MAIS) Programs February 27, 2012...
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Transcript of 10 U.S.C. Chapter 144A – Major Automated Information System (MAIS) Programs February 27, 2012...
10 U.S.C. Chapter 144A – Major Automated Information System
(MAIS) Programs
February 27, 2012
December 11, 2013Under Secretary of Defense for Acquisition, Technology and Logistics
DASD(C3&Cyber)Bob Ramsey
2UNCLASSIFIED
Outline
• 10 U.S.C. Chapter 144A establishes reporting regime– Enacted FY07 NDAA §816; amended FY09 NDAA §812, WSARA 2009
§101, FY10 NDAA §817 and §841, FY11 NDAA §805, FY12 NDAA §811
• §2445a – definitions
• §2445b – requires annual and quarterly reports
• §2445c – Significant & Critical variance reporting
• §2445d – if MAIS program is MDAP magnitude SecDef decides
• 5-year development clock
• Critical Change process
• Resources
3UNCLASSIFIED
Key Requirements10 U.S.C. Chapter 144A
• Defines Major Automated Information System (MAIS) in statute• Designates USD(AT&L) and Service Acquisition Executives as
Senior Officials responsible for reporting regime • Requires a MAIS Annual Report (MAR) to congressional defense
committees (analogous to MDAP Selected Acquisition Report)– MAR establishes the Original Estimate (baseline)
• Requires Program Managers to submit MAIS Quarterly Report (MQR) to the Senior Official – any variance from the baseline
• Establishes Significant and Critical Change thresholds• Imposes a reporting penalty if program exceeds 5 years from
Milestone A (or selection of preferred alternative) to FDD• Requires communication to Congress
– Significant Change → Notification letter– Critical Change → Report w/ certifications based on program
evaluation (almost identical to Nunn-McCurdy)
4UNCLASSIFIED
Definitions
5UNCLASSIFIED
MAIS Definition10 U.S.C. 2445a
• Chapter 144A defines MAIS as a Department of Defense program for the acquisition of an automated information system (either as a product or a service) if—
“(1) the program is designated by the Secretary of Defense, or a designee of the Secretary, as a major automated information system program; or
“(2) the dollar value of the program is estimated to exceed—
(A) $40,000,000 in fiscal year 2014 constant dollars for all program costs in a single fiscal year;
(B) $165,000,000 in fiscal year 2014 constant dollars for all program acquisition costs for the entire program; or
(C) $520,000,000 in fiscal year 2014 constant dollars for the total life-cycle costs of the program (including operation and maintenance costs).”
*italicized numbers are published in the Interim DoDI 5000.02 dated 26 Nov 2013
6UNCLASSIFIED
Amendment to MAIS Definition FY09 NDAA §812
• Adds “Other Major Information Technology Investment Program” to MAIS definition– (1) An investment that is designated by the Secretary of
Defense, or a designee of the Secretary, as a ‘pre-MAIS’ program
we try to avoid designating a program as “pre-MAIS” and rely instead on definition based on cost estimate
– (2) Any other investment in automated information system products or services that is expected to exceed a MAIS threshold, but is not considered to be a MAIS program because a formal acquisition decision has not yet been made
“formal acquisition decision” = Milestone B
This means “unbaselined MAIS”
7UNCLASSIFIED
MAIS of MDAP Magnitude 10 U.S.C. 2445d
• FY10 NDAA §817 amendment makes MAIS programs and MDAP mutually exclusive
• If a MAIS program reportable under Chapter 144A is also an MDAP reportable under Chapter 144, SecDef may designate that program as either a MAIS or MDAP– If program produces custom hardware → MDAP → Ch 144
– If a program is software intensive → MAIS → Ch 144A
• MDAP definition thresholds– Estimated RDT&E more than $480M (FY14 constant dollars)– Estimated Proc more than $2.79B (FY14 constant dollars)
8UNCLASSIFIED
MAIS Program Increments
• An “acquisition program” is used by the acquisition community to refer to the basic unit of management for an acquisition effort– A MAIS “program” is usually composed of a number of increments– A MAIS “program” is not baselined, only its increments have APBs
• Increment—the Increment is “a militarily useful and supportable operational capability that can be developed, produced, deployed, and sustained. Each Increment will have its own set of threshold and objective values set by the user.” (DODI 5000.02, Encl.2, 2.c.)
• MAIS program = ∑ Inc 1 + Inc 2 + Inc n– Regardless of cost, each increment of a MAIS program is
managed and reported as if it is a MAIS program
9UNCLASSIFIED
MAIS ProgramAnnual and Quarterly
Reports
10UNCLASSIFIED
MAIS Annual Report (MAR)10 U.S.C. 2445b
• MAR submissions must start when funds are requested in the President’s Budget
• Due annually to Congress 45 days after submission of the President’s Budget (PB)
• The annual report must include the following– Schedule including estimates of milestone dates, full deployment
decision, and full deployment– Estimates of total acquisition and total life-cycle costs– Summary of key performance parameters
• The initial MAR constitutes the Original Estimate for determining Significant & Critical Changes in the program; – Based on approved Acquisition Program Baseline (APB) by policy
• Original Estimate can only be changed if a Critical Change Report is sent to Congress– An updated APB is not sufficient to change an Original Estimate
11UNCLASSIFIED
2014 MAR Preparation Events and Target Dates
Event Means Responsible Agency Target Date
Train-the-Component Trainer Attend meeting
OUSD(AT&L) & Components
18 Nov 13
Distribute updated MAR procedures Email OUSD(AT&L) 11 Dec 13
Release Draft MARs to OSD Lead DAMIR Components 10 Jan 14
Review Draft MARs; provide comments DAMIR OSD staff 13-31 Jan 14
MAR issue resolution teleconferences; assign drafts back to PMO
Telecon/DCO OSD & Components 3-7 Feb 14
Release Final MARs to OSD DAMIR Components 28 Feb 14
Hold Final Release reviews DAMIR OUSD(AT&L) 3 Mar 14
Coordinate MAR package within OSD SACCP OUSD(AT&L) 4-12 Mar 14
Staff MAR package to AT&L for signature
Paper OUSD(AT&L) 13-15 Mar 14
Sign MAR Transmittal letters Paper USD(AT&L) 19 Mar 14
Deliver MAR Transmittal letters to Congress; release DAMIR MARs
Paper/DAMIR OUSD(AT&L) 24 Mar 14
12UNCLASSIFIED
MAIS Quarterly Report (MQR) 10 U.S.C. 2445c
• Baselined MAIS programs submit a quarterly report (MQR) to the Senior Official– MQR required even if no variance has occurred
• Also required for unbaselined MAIS programs ≥ 5 years past MS A / preferred alternative decision– Unbaselined MAIS do not have Original Estimates; no c/s/p
variances are possible– If unbaselined, only Ch 144A breach possible is 5-year
development clock– needs no status reporting via MQR; can track status via ad hoc
DAMIR report
13UNCLASSIFIED
MAIS Quarterly Report (MQR) 10 U.S.C. 2445c
• MQR provides the PM’s Current Estimate– For schedule, PM’s best estimate of dates– For performance, PM’s best estimate of values– For cost, PB ± fact of life changes
• Submitted on same (A, B, C) cycle as Defense Acquisition Executive Summary (DAES)
• MQR is not sent to Congress
14UNCLASSIFIED
Chapter 144A MAIS ReportingAutomation
• The APB, MAR, MAR Original Estimate, MQR, and DAES have been automated in DAMIR
Working to combine MQR into DAES—Summer 2014
APB
MAR OE
MAR
MQR DAES
data data
DAMIR
data
data
15UNCLASSIFIED
Reporting Variances
16UNCLASSIFIED
Senior Official10 U.S.C. 2445c(b)
• SAE: An AIS to be acquired for a military department• USD(AT&L): AIS acquired by a Component other than
military department– USD(AT&L) delegated all his Senior Official responsibilities to:
• ASD(HA)• DCMO• CAEs (DISA, DLA, NSA)
Note: the MDA is often NOT the Senior Official
17UNCLASSIFIED
Determinations 10 U.S.C. 2445c(c) and (d)
• The Senior Official must review the Program Manager’s MQR and determine whether a Significant or Critical Change has occurred– Significant Changes: notify congressional defense committees of
the change within 45 days after the PM’s report is due– Critical Changes: within 60 days after the PM’s report is due, the
Senior Official must -• Conduct an evaluation of the program, then• Submit a report with certifications to the congressional defense
committees • Through the Secretary of Defense (USD(AT&L) transmittal ltr)
• The clock starts the date the MAIS Quarterly Report was due in the office of the Senior Official – Last business day of every third month aligning with DAES Group
18UNCLASSIFIED
Significant and Critical Change Summary
Significant Critical
Cost - total acquisition cost - total life-cycle cost
15 to 25% increase ≥ 25% increase
Schedule
> 6 months to <1 year delay
≥ 1 year delay
Failed to achieve FDD within 5 yrs after MS A, or if no MS A, the date the preferred alternative was approved by the MDA
Performance“Significant adverse change in expected performance”
“Undermine the ability of the system to perform mission as originally intended” (i.e., did not meet a KPP threshold)
Report to congressional defense committees
Notification due 45 Days after MQR was due in the office of Senior Official
Program Evaluation and Report due 60 days after MQR was due in the office of Senior Official
19UNCLASSIFIED
Significant Change Defined10 U.S.C. 2445c(c)
• Schedule: estimate a delay of more than six months but less than a year in any program schedule milestone or significant event from the Original Estimate
• Cost: estimate of total acquisition cost or total life-cycle cost for the program has increased by at least 15 percent, but less than 25 percent, over the Original Estimate
• Performance: a significant, adverse change in the expected performance of the major automated information system to be acquired
20UNCLASSIFIED
MAIS Significant Changes(as of December 11, 2013)
Program(in order
received)
Reason for variance Days to Prepare
Notification
SC Report Date
DIMHRS (Navy) MS C and IOC slips due to requirements definition, Army interface delays, and data conversion complexity
81 20-Oct-08
GCCS-J (DISA) FDD schedule slip due to technical challenges and need for infrastructure upgrades
56 24-Apr-09
GFEBS (Army) Delayed FDD due to Army evaluation of OT report
43 13-Apr-10
KMI Inc 2 (NSA) Technical issues led to slip in OT&E 45 14-Jun-11
Navy ERP (Navy)
Delayed FDD and IOT&E due to technical problems
35 5-Aug-11
GCSS-MC (Navy) FDD schedule slip to mature software 43 13-Feb-12
CANES (Navy) MS C schedule slip 36 6-Aug-12
GCSS-A (Army) FDD schedule slip 34 2-Nov-12
PKI Inc 2 (NSA) FDD schedule slip (later became Critical Change) 44 13-Sep-13
IPPS-A Inc 1 (Army)
MS C schedule slip pending
21UNCLASSIFIED
Critical Change Defined10 U.S.C. 2445c(d)
• Schedule: estimate a delay of one year or more in any program schedule milestone or significant event from the Original Estimate
• Cost: estimate of total acquisition cost or total life-cycle cost for the program has increased by 25 percent or more over the Original Estimate
• Performance: a change in expected performance that will undermine the ability of the system to perform the functions anticipated in the Original Estimate– DoD has defined a failure to achieve a Threshold Key
Performance Parameter as a Critical Change • Five-year to full deployment decision threshold: failed to
achieve a full deployment decision within five years of MS A or if no MS A selection of preferred alternative– Excluding any delay as a result of bid protest– Only variance based on actual delay instead of PM’s estimate
22UNCLASSIFIED
MAIS Critical Changes(as of December 11, 2013)
Program(in order of date MQR received) Reason for Variance
Days to Deliver
CCRReport Date
CAC2S (Marine Corps) Schedule slip due to architecture issues 237 24-Apr-09
GCSS-MC (Marine Corps) Cost & schedule slips caused by grand design
118 16-Jan-09
TMIP-J Inc 2 (TMA) Cost & schedule slips due to Wounded Warrior rqmts
175 24-Apr-09
DIMHRS (Navy) Schedule slips caused by requirements complexity 65 7-Apr-09
ISPAN Inc 1 (Air Force) Cost increase due Original Estimate cost admin error
69 10-Apr-09
TELEPORT Gen 1&2 (DISA) Schedule slip caused by delay in satellite launch 57 27-Mar-09
Navy ERP (Navy) Performance slip caused by deletion of KPP 89 28-Sep-09
MPS Inc IV (Air Force) Development issues delayed Milestone C 448 23-Dec-10
DEAMS Inc 1 (Air Force) Failure to meet 5-year development clock 122 29-Sep-10
GFEBS (Army) Failure to meet 5-year development clock 58 28-Oct-10
ECSS (Air Force) Failure to meet 5-year development clock 111 18-Feb-11
MPS Inc IV (Air Force) Failure to meet 5-year development clock 61 1-Sep-11
KMI Inc 2 (NSA) Cost, schedule & performance slips due to new rqmts 111 22-May-12
ECSS Inc 1 (Air Force) Failure to meet CCR schedule date terminated 7-Dec-12
VIPS (DLA) Failure to meet 5-year development clock terminated 13-Mar-13
AOC WS Inc 10.2 (Air Force) Failure to meet 5-year development clock 285 12 Oct-13
GCSS-MC (Navy) Schedule slip due to technical challenges mtg reqmts 249 6-Sep-13
Teleport Gen 3 (DISA) Schedule slip due to dependency on delayed MUOS pending
PKI Inc 2 (NSA) Failure to meet 5-year development clock pending
23UNCLASSIFIED
Starting the 5-Year Development Clock
10 U.S.C. 2445c(d)(2)(A)
• Clock starts at “… the Milestone A decision for the program or, if there was no Milestone A decision, the date when the preferred alternative is selected for the program (excluding any time during which program activity is delayed as a result of a bid protest).”– Calculate delay in months and round-up to whole month
• Previously, clock started on a “funds first obligated” date FFO is an obsolete event, but we grandfather use of the date to
start the clock
• And before that, clock started at Milestone A
24UNCLASSIFIED
• “ … failed to achieve a full deployment decision within five years after ….”– Statutory definition of ‘full deployment decision’ – “the final
decision made by the Milestone Decision Authority authorizing an increment of the program to deploy software for operational use”
– The date the FDD ADM is signed by the MDA
• Interpretation of this definition and the FDD event is often complicated and depends on specific circumstances
Stopping the 5-Year Clock10 U.S.C. 2445c(d)(2)(A)
25UNCLASSIFIED
Prohibition on Obligation of Funds10 U.S.C. 2445c(g)
• If the Senior Official does not submit the required report on Critical Changes within 60 days of MQR due date, appropriated funds may not be obligated for any major contract under the program– For Chapter 144A purposes, the term "major contract" means
any contract under the program that:• Is not a firm-fixed price contract and,• Has target cost exceeding $17M (FY00 constant dollars), or• If no target cost exceeds $17M, is the largest contract under
the program. recommend programs not obligate funds during Critical Change
Report (CCR) preparation (would look bad as news headline)
• The prohibition ceases to apply on the date on which Congress receives a report in compliance with the law
26UNCLASSIFIED
Critical Change Process
27UNCLASSIFIED
Critical Change Program Evaluation10 U.S.C. 2445c(e)
• An assessment of— (1) the projected cost and schedule for completing the program if
current requirements are not modified;
(2) the projected cost and schedule for completing the program based on reasonable modification of such requirements; and
(3) the rough order of magnitude of the cost and schedule for any reasonable alternative system or capability
28UNCLASSIFIED
Critical Change Report 10 U.S.C. 2445c(f)
• Must include Senior Official’s written certification (with supporting explanation) that— (1) the automated information system to be acquired is essential to
the national security or to the efficient management of the Department of Defense
(2) there is no alternative to the system which will provide equal or greater capability at less cost
(3) the new estimates of the costs, schedule, and performance parameters with respect to the program and system or information technology investment, as applicable, have been determined, with the concurrence of the Director of Cost Assessment and Program Evaluation, to be reasonable; and
(4) the management structure for the program is adequate to manage and control program costs
29UNCLASSIFIED
D,CAPE Involvement10 U.S.C. 2445c(f)(3)
• Weapon Systems Acquisition Reform Act (WSARA) 2009 changed Chapter 144A certification requirement #3 to read:
“(3) the new estimates of the costs, schedule, and performance parameters with respect to the program and system or information technology investment, as applicable, have been determined, with the concurrence of the Director of Cost Assessment and Program Evaluation, to be reasonable;”
Summary of D,CAPE Involvement with Chapter 144A Critical Change Reports
MDA ICE Required? Cost/Sch/Performance #3 Concurrence?
USD(AT&L) Yes YesAnyone else No Yes
30UNCLASSIFIED
Critical Change Team (CCT) Organization and Reporting Path
Critical Change Team
E3 “Reasonable Alternative”
E2 “Reasonable Modification”
E1“Not Modified”
IPT Principals
Team Leader
IPT C1“Essential”
IPT C2“No Alternative”
IPT C3“New Estimate”
IPT C4“Management”
Senior Official
IPT Principals Lead
USD(AT&L) or designeeif needed for transmittal
* Lead organization for ACAT IAM programs; Services have an equivalent Lead organization
JS/J8* CAPE* CAPE* AT&L*
31UNCLASSIFIED
Model Critical Change Process Timeline
Info
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tifi
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t
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enio
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ffic
ial
Ca
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ot
Ob
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e F
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on
Ma
jor
Co
ntr
acts
60 Days
Senior Official (SO) Identifies CCT Lead and IPT Principals Lead
Triage Meeting; draft Determination and Tasking
Kickoff Meeting of CCT Leadership; specify detailed timeline
CCT Conducts Evaluation
IPT Meetings
Heading check w/ IPT Principals
Compile Final Report
Pre-Brief IPT Principals Lead
Brief IPT Principals
SO signs Report; sends to OSD
OSD transmits Report to Congress
Official MQR submittal; SO issues Determination &Tasking
32UNCLASSIFIED
Chapter 144A Source and Reference documents are available at:
https://acc.dau.mil/CommunityBrowser.aspx?id=227820&lang=en-US
OUSD(AT&L), DASD(C3 & Cyber)Bob Ramsey, 571-372-4415, [email protected]
Everything you wanted to know about Ch 144ADAG 10.11 MAIS Statutory Reportinghttps://dag.dau.mil/Pages/Default.aspx
For Additional Chapter 144A Guidance
10 U.S.C. Ch 144A (as amended) MAR Preparation InstructionsCh 144A Overview Briefing DAMIR-MAR User’s GuideTerms of Reference and Definitions DAMIR-MQR User’s GuideSection 811, FY07 NDAA on DBS POC ListingDAG 10.11 (MSWord)