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    What combination of Clinger-Cohen Act provisions prohibits direct interaction between SMEs and IT developers? How does combination this affect DODI 5000.75 regarding Agile development processes?


    The Background information states that: “Clinger-Cohen Act has been regularly cited as the basis for prohibiting functional subject matter experts (SMEs), who prepare functional requirement packages for software applications, from dealing directly with information technology (IT) developers who have been appropriately contracted to develop the application.” Without providing the actual citations I cannot verify that the CCA actually “prohibits” this interaction.  The background information refers to IT developers “who have been appropriately contracted to develop the application,” so there is an actual contract in place.  Once the contract has been signed, it is the responsibility of the procuring contracting officer, in support of the program manager, to control all communications between the program office and the contractor.  This serves multiple purposes, not the least of which is, as the background information states: “to ensure that no financial obligations accrue between SMEs and developers.”  This has nothing to do with the CCA according to our Information Resource Management faculty.

    It would appear that the questioner, as an employee of the contracted “developer,” (?) is struggling to fit “Agile practices” into a DoD Business Systems acquisition process that may not be readily adaptable to Agile management. 
    Neither the CCA nor the DODI 5000.75 refer to Agile software development (or any other software development approach as far as I can tell), or Agile management practices.  In fact, the DODI 5000.75 actually states that it is DoD policy that: “DoD acquisition of business systems will be aligned to commercial best practices and will minimize the need for customization of commercial products to the maximum extent possible.”  This statement appears to contain slightly conflicting guidance.  “Agile practices” are a “commercial best practice.” On the other hand, the policy states that there should be minimal “need for customization of commercial products.”

    I recommend a Systems Requirements Review to ensure that system requirements have been completely and properly identified and that a mutual understanding between the government and contractors exists.

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