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  • Question

    Are there any prohibitions (legal and/or regulatory) preventing a separate command (HRC, AMC, etc.) from developing a new capability (ie. business or software system), on their own, outside of the Acquisition process?


    Answer

    I am assuming that this is a business system and you have to follow the DTM
    11-009 which can be found here:
    https://acc.dau.mil/adl/en-US/508418/file/63606/#113449 ACQ Policy for Defense Business Systems.pdf
    The DTM states that any modernization effort with a TOTAL cost of $1M is subject to the BCL process.  If this is true for this effort, then the functional sponsor would develop the business case and it would either be approved or disapproved by the MDA at the MDD after the Investment Review Board review. 
     
    If it is not a MAIS, then it's up to the head of the component for oversight and they have to follow the same process with similar governing bodies.  Bottom line, the problem statement still has to be approved by an IRB-like chair. 
     
    The DTM also lists all statutory and regulatory requirements for defense business system in Attachment 3.  It also discusses the Clinger Cohen Act Compliance in Attachment 4 which covers any IT investment. Funding has to be approved and if the effort doesn't line up with the IT investment priorities set by the CIO then it would be tough to get an MDA approval, much less Clinger Cohen Act Compliance Certification. 
     
    The regulation that covers this for the Army is the AR 25-1.  It discusses the CIOs role in the Army's IT investment and IT capital planning which feed into the PPBE decision process.
     

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