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Acquisition of Services (AoS)
Title 10 Changes Summary Table
Software Acquisition Pathway (SWP)
Defense Business Systems (DBS)
Software Acquisition Pathway (SWP)

Defense Business Systems (DBS)

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Defense Business Systems (DBS)

INFORMATION REQUIREMENT

EXECUTION PHASE

DECISION POINT

SOURCE

TYPE

Business Enterprise Architecture

Capability Need Identification

Solution Analysis ATP

10 USC 2222(g)(B)

Statutory

​Capability Requirements

Capability Need Identification

Solution Analysis ATP

10 USC 2222(d)(2)

Statutory

​Business Process Reengineering

Solution Analysis

Functional Requirements ATP

10 USC 2222(g)(A)

Statutory

​CMO Certification1,2

Functional Requirements & Acquisition Planning

Acquisition ATP

10 USC 2222

Statutory

​Solution Approach (fulfills market research, analysis of alternatives, economic analysis)

Functional Requirements & Acquisition Planning

Acquisition ATP

10 USC 2222(g)(C) for market research

Statutory

Cybersecurity Strategy (for mission essestial and mission critical IT)

Functional Requirements & Acquisition Planning

Acquisition ATP

Federal Information Security Modernization Act

Statutory

​Acquisition Strategy

Functional Requirements & Acquisition Planning

Acquisition ATP

10 USC 2222(g)(1)(D)

Statutory

​Clinger-Cohen Act Compliance - Information Technology Management

Functional Requirements & Acquisition Planning

Acquisition ATP

Title 40, Subtitle III (Division D, E)

Statutory

Auditability Compliance

Functional Requirements & Acquisition Planning

Acquisition ATP

 
10 USC 2222(g)(1)(E)
10 USC Chapter 9A
Federal Financial Management Improvement Act (FFMIA)
Federal Managers Financial Integrity Act (FMFIA)

Statutory

Clinger-Cohen Act Compliance

Functional Requirements & Acquisition Planning

Contract Award

Title 40, Subtitle III (Division D, E)

Statutory

​Full CCA compliance at first Limited Deployment ATP3; confirmation of compliance at additional ATPs

Functional Requirements & Acquisition Planning

Limited Deployment ATP(s)

Title 40, Subtitle III (Division D, E)

Statutory

Confirmation of CCA compliance Initial Operational Test and Evaluation Report (for business systems on the DOT&E oversight list)

Functional Requirements & Acquisition Planning

Full Deployment ATP

​Title 40, Subtitle III (Division D, E)

Statutory

​Capability Support Plan

Acquisition Testing & Deployment

Capability Support ATP

10 USC 2222(b)(4) sustainment strategy

Statutory 

​DOT&E Report on IOT&E (for programs on DOT&E oversight list)

Acquisition Testing & Deployment

Capability Support ATP

​10 USC 139

Statutory

Test and Evaluation Master Plan (for programs on DOT&E oversight list)

Acquisition Testing & Deployment

Capability Support ATP

​10 USC 139

Statutory

​Operational Test Plan (for programs on DOT&E oversight list)

Acquisition Testing & Deployment

Capability Support ATP

​10 USC 139

Statutory

None​

Capability Support

N/A

None​

None

Table Notes:

 
1. CMO certification can occur during prior phases, but must occur before the Acquisition ATP is approved.
2. SEC 901 of the 2021 NDAA repealed the CMO position; awaIting the decision on the transfer of the CMO duties and responsibilities.
3. Full CCA compliance can occur during prior ATP decisions points, but must occur no later than the first Limited Deployment ATP.  Separate documentation should not be needed to confirm CCA compliance.