Is Cost Reporting waived for Firm Fixed Price Contracts?
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The Department of Defense (DoD) has three primary cost data collection methods: Cost and Software Data Reporting (CSDR), which includes the Contractor Cost Data Report (CCDR) and the Software Resource Data Report (SRDR); the Integrated Program Management Report (IPMR); and the Visibility and Management of Operating and Support Costs (VAMOSC) systems.
CSDR is the primary method the Department of Defense (DoD) uses to collect data on the costs that contractors incur on DoD programs. Per DFARS 234.7100(a), the CSDR requirement is mandatory for major defense acquisition programs (as defined in 10 U.S.C. 2430), and major automated information system programs (as defined in 10 U.S.C. 2445a) as specified in DoDI 5000.02, Operation of the Defense Acquisition System and the DoD 5000.04–M–1, CSDR Manual. The CSDR system is applied in accordance with the reporting requirements established in DoDI 5000.02. The two principal components of the CSDR system are contractor cost data reporting and software resources data reporting.
CSDR reporting and processing requirements are determined by Acquisition Category (ACAT) program category and the value of individual contracts and subcontracts within the program. Programs are classified according to estimated dollar value for Research, Development, Test and Evaluation (RDT&E), production, annual acquisition and life-cycle costs. Via the CSDR, CCDR requirements are the same for all contracts and subcontracts within all categories. In addition, the services have discretion in applying CCDR requirements to ACAT II, and ACAT III programs. The CSDR requirement applies to all ACAT IAM, IAC, IC, and ID programs, as follows, regardless of contract type:
In accordance with DoDI 5000.02, Enclosure 1, Table 7, CCDR applies to all contracts, regardless of contract type greater than $50M. In addition, CCDR is required for major components (i.e., government furnished equipment) of an ACAT I program that are managed by the Services as ACAT II or ACAT III, and if the contract value exceeds $50 million or if determined to be a high-risk or high-technical-interest contract priced between $20 million and $50 million by the Program Manager and/or the Deputy Director of Cost Assessment (DDCA). In addition, with approval by the DDCA, the CCDR requirement on high-risk or high-technical-interest contracts priced between $20 million and $50 million is left to the discretion of the DoD Program Manager. CCDR is not required for contracts priced below $20 million (then-year dollars).
Per your question, “Is Cost Reporting waived for Firm Fixed Price Contracts”. Reference DoDI 5000.02, Enclosure 1, Table 7, if the Program Manager requests and obtains approval for a reporting waiver from the DDCA, CCDR is not required for procurement of commercial systems or procurement of non-commercial systems bought under competitively-awarded firm fixed-price contracts, as long as competitive conditions continue to exist.
As provided by DFARS 234.7100(a), prior to contract award, contracting officers shall consult with the Defense Cost and Resource Center to determine that the offeror selected for award has proposed a standard CSDR system, as described in the offeror’s proposal, in response to the provision at 252.234–7003, that is in compliance with DoDI 5000.02, Operation of the Defense Acquisition System, and the DoD 5000.04–M–1, CSDR Manual. Contact information for the Defense Cost and Resource Center and the DDCA is located at PGI 234.7100.
DFARS 234.7101 prescribes use of the solicitation provision DFARS 252.234-7003 and contract clause. DFARS 252.234-7004, which establish content requirements of the solicitation provision and contract clause, respectively.
All MDAP and MAIS programs that meet the requirements for CSDR reporting shall implement MIL-STD-881C as a contract requirement. Existing programs using the MIL-HDBK-881A WBS shall evaluate the cost impact, if any, to execute using the MIL-STD-881C as a contract requirement, and implement where deemed cost effective. The MIL-STD-881C contains 11 different WBS appendices, addressing Aircraft, Ships, Vehicles, Space, UAV, etc. The WBS is a product-oriented family tree composed of hardware, software, services, data, and facilities.
The Integrated Program Management Report (IPMR) Data Item Description (DID) DI-MGMT-81861A contains data for measuring contractors' cost, schedule and performance on Department of Defense (DoD) acquisition contracts. Concerning application of IPMR Guidance for Firm-Fixed-Price (FFP) Contracts, only the Milestone Decision Authority (MDA) can grant a waiver allowing application of EVM to a FFP contract (see DODI 5000.02 Enclosure 5). Once granted, only the minimal EVM requirements necessary to provide the Government team with the desired visibility into program performance should be applied.
Visibility and Management of Operating and Support Costs (VAMOSC) data systems are managed by each Military Department and collect historical O&S costs for major fielded weapon systems. DCAPE conducts annual reviews of VAMOSC systems to address data accessibility, completeness, timeliness, accuracy, and compliance with CAPE guidance. The annual reviews also assess the adequacy of each military department’s funding and resources for its VAMOSC systems. DoDI 5000.02 references DoD Manual 5000.4-M for the procedural and data reporting requirements for VAMOSC; however, DoDI 5000.73, June 9, 2015 incorporates and supersedes DoD 5000.4-M.
The Operations and Support (O&S) Cost Estimating Guide, March 2014 was prepared by the Office of the Secretary of Defense (OSD) Director of Cost Assessment and Program Evaluation (DCAPE) for use by the Department of Defense (DoD) Components (i.e., military departments and defense agencies) in developing estimates of system O&S costs.
References in pdf format are accessible via the following created links:
DFARS SUBPART 234.71—COST AND SOFTWARE DATA REPORTING (CSRD) <http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/dfars/dfars234.htm#P253_16585>
DoDI 5000.02 Operation of the Defense Acquisition System, Jan 7, 2015 <http://dcarc.cape.osd.mil/Files/Policy/DoDI_5000.2_Jan072015.pdf>
DoDM 5000.04-M-1, Cost and Software Data Reporting (CSDR) Manual, Nov 4, 2011l <http://dcarc.cape.osd.mil/Files/Policy/500004m1.pdf>
MIL-STD-881C, DoD Standard Practice, Work Breakdown Structures for Defense Material Items, 25 Mar 1993 <https://acc.dau.mil/adl/en-US/482538/file/61223/MIL-STD%20881C%203%20Oct%2011.pdf>
DoDI 5000.73, Cost Analysis Guidance and Procedures, Jun 9, 2015 <http://www.dtic.mil/whs/directives/corres/pdf/500073p.pdf>
OSD Operations and Support (O&S) Cost Estimating Guide, March 2014 <http://dcarc.cape.osd.mil/Files/CSDRSR/OS_Guide_v9_March_2014.pdf>