Recommended DFARS Revisions

Recommendations provided below meet the following objectives:

The House Armed Services Committee (HASC) held a hearing on 10/29/13 to kick off a fresh drive to fix the way the Pentagon buys weapons and services, vowing to "look past Band-Aid fixes and parochial interests" and implement meaningful reforms. The subject was “25 Years of Acquisition Reform: Where Do We Go from Here?”

Two speakers provided recommendations which are applicable to EVMS reform. Pertinent topics:  

 1. Repeal or amend regulations that provide no benefit.
2. Amend regulations to alleviate the financial impact while preserving the fundamental intent.
Moshe Schwartz, Specialist in Defense Acquisition Policy, Congressional Research Service: 
Repeal or amend regulations that no longer provide a benefit could serve to simplify the acquisition process.
​ Remove unnecessary regulatory burdens on industry that add to the costs of doing business.
​ Adopt an approach of weighing the costs to industry and government against the policy and oversight benefits of the regulations in question.
​ Congress could also choose to amend certain statutes and regulations in such a way as to alleviate the regulatory or financial impact while preserving the fundamental intent of the regulation.
Dov Zakheim, former  Undersecretary of Defense (Comptroller)​What to do about Process:
Substantive challenge begins with requirements definition.
Requirements must not only be defined, but upheld in the course of the development and production process.​
Revise Defense Federal Acquisition Regulation Supplement (DFARS)
​My recommendations to revise DFARS to improve the effectiveness of EVMS, consistent with the recommendations made at the HASC hearing. 
​ ​Revise DFARS EVMS clauses 252.234-7001 and 252.234.7002 to:
1. Tailor 4 guidelines.
2. Remove compliance with 12 guidelines.

The detailed recommendations are in the letter to Letter to HASC Chairman Adam Smith, 11/21/20 Subject: NDAA Conference Committee Support for H. R. Sec. 1745, Requirements Relating to Program and Project Management
with attached white paper, “DOD Acquisition Reform: EVMS-lite to Program/Project Management, Rev. 35.“

Performance-Based Earned Value