What is the best or recommended course of action to take with only five months of performance left?
Do we still need to seek an MDA waiver for the CPR reporting?
Policy requires that on cost plus and incentive type contracts in excess of $50 million dollars that the Government require the contractor to use a ANSI/EIA - 748 compliant and validated Earned Value Management System (EVMS). The Government will also require the contractor submit a CPR Report with all five formats (no tailoring) that covers the entire Scope of Work. There is no provision in the guidance for the Milestone Decision Authority (MDA) to waive this requirement, in part or whole, although MDAs have great latitude in how they manage their programs.
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That said, given that you only have five months remaining, I'm not sure how much good getting some sort of waiver from the MDA will do besides documenting past decisions for the record.