If the MDA determines that a MS C decision is not required for a program, what is the expectation for completing the documentation that is normally required at that decision point? For example, the statutory requirement for the Clinger-Cohen Act Compliance was met at MS B; it will be met again for FDD, but is it required to be met at some point prior to that as would normally occur?
From the Interim 5000.02 on Model 3, Incrementally Fielded Software Intensive Program - "This model is distinguished from the previous model by rapid delivery of capability through several limited fieldings in lieu of single Milestones B and C and a single deployment. Each limited fielding results from a specific build, and provides the user with mature and tested sub-elements of the overall capability." Although the program office "has been given direction to proceed to FDD without a MS C decision", specific guidance for the next limited fielding or decision point (Full Deployment Decision) should be captured in an Acquisition Decision Memorandum (ADM).
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Although the Interim 5000.02 gives MDAs the ability to tailor program strategies, statutory requirements must be still be complied with, unless waived in accordance with relevant provisions and the proper authority. "While these generic decision points and milestones are standard, MDAs have full latitude to tailor programs in the most effective and efficient structure possible, to include eliminating phases and combining or eliminating milestones and decision points, unless constrained by statute." Clinger-Cohen Act is one of several statutory requirements and the program office would still have to demonstrate compliance with these requirements. There also may regulatory requirements that cannot be waived.
Although your question does not indicate the ACAT level for your program, we recommend a review of the regulatory and statutory requirements in Enclosure (1) of the Interim 5000.02 to determine what applies to your situation and then have a discussion with the PM to get amplifying guidance from the MDA and determine the best way to show compliance.