Is an R&D contract awarded under FAR 35 truly subject to the EVMS requirements cited in FAR 34 for Major Acquisitions?
EVM applicability is governed by three tenets: If the nature of the work is measurable, contract type and dollar threshold. Contract type and dollar value are pretty straight forward. Measurability of planning and executing the work requires more effort to determine. Factors driving that determination include plannability of the work in objectively measurable work packages. That determination is made by OSD PARCA upon review of your SOW. PARCA will provide a formal recommendation to the Program Office with regard to whether an EVM exclusion waiver should be pursued.
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DODI 5000.02 Enclosure 2 Para 6 excerpt
c. Earned Value Management (EVM). Program Managers will employ EVM unless its use is waived by the CAE. EVM is one of DoD’s and industry’s most powerful program planning and management tools. It is normally used in conjunction with cost plus and fixed-price incentive contracts. The purpose of EVM is to ensure sound planning and resourcing of all tasks required for contract performance. It promotes an environment where contract execution data is shared between project personnel and government oversight staff and in which emerging problems are identified, pinpointed, and acted upon as early as possible. EVM provides a disciplined, structured, objective, and quantitative method to integrate technical work scope, cost, and schedule objectives into a single cohesive contract baseline plan called a Performance Measurement Baseline for tracking contract performance. (Table 8 in Enclosure 2 summarizes EVM requirements.)
DFARS: http://www.acq.osd.mil/dpap/dars/dfars/html/current/234_2.htm#234.201 <http://www.acq.osd.mil/dpap/dars/dfars/html/current/234_2.htm%23234.201>
FAR 35.003 -- Policy.
(a) Use of contracts. Contracts shall be used only when the principal purpose is the acquisition of supplies or services for the direct benefit or use of the Federal Government. Grants or cooperative agreements should be used when the principal purpose of the transaction is to stimulate or support research and development for another public purpose.