Is it necessary to create an ECP to support functional changes to software that is being incrementally developed and has not met FOC/FD?
An Engineering Change Proposal (ECP) is not necessarily required for each change. Any internal Contractor changes that do not impact Government approved (baselined) configuration documentation will not require an ECP. (MIL-HDBK 61A Configuration Management Guidance, ¶22.214.171.124. Change Classification)
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However, if due to feedback from the incremental deliveries or for other reasons the Government wants to change from the approved Baseline system functions or performance, then an ECP will be necessary. For example: if the
Government has already approved the top level system specification for use as a Functional Baseline (top level system functions), then changing any of those system functions will require an ECP. Depending on how your Performance Work Statement (PWS) is written, you may or may not need to modify the contract for each ECP.