Does an Army ACAT III program of record require DASA review/approval before a government cost position can be finalized?
The new DoDI 5000.02 released on 26 Nov 2013, has easy to interpret tables which are a great deal of help. For example, Table 2 (Milestone and Phase Information Requirements) shows for ACAT III programs, a DoD Component Cost Estimate is required at various points, but a DoD Component Cost Position and an Independent Cost Estimate are not required at any point. The latest Army Regulation 70–1 (Army Acquisition Policy), dated 22 July 2011, states “The DASA–CE will…e) Approve the Army cost position for milestones A, B, C, and FRP decision reviews for all MDAPs, MAIS, and other programs where the AAE is the MDA.”
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Since, according to DoDI 5000.02, a government cost position is not required for an ACAT III program, DASA review/approval would not be required, unless, according to AR 70-1, the Army Acquisition Executive is the Milestone Decision Authority of the ACAT III program. Because the new DoDI 5000.02 has not been incorporated into all of the services’ acquisition policies, I’d recommend that you contact your PEO staff for the latest service guidance as it could be more restrictive.