Do not assume anything when you are writing a task order against an Indefinite Delivery Indefinite Quantity (IDIQ) contract. Why? Ever write a task order and miss something or miss ensuring the proper contract language rigor is included? For example, what happens when a task order is written against an IDIQ contract and language requiring Earned Value Management (EVM) at the task order level is omitted?
The result is you will not obtain the proper level of EVM data needed and you could quickly find yourself well behind the power curve when reporting required data to stakeholders.
Here we will look at a real world example of how one can get in a tight spot when assumptions are made and sufficient contract coverage is not planned for.
Contract Disconnect
A task order was written for a Test IV&V contract which was a Cost Plus Fixed Fee over $20 Million. This met the current policy requirements. The overarching IDIQ for this particular task order stated the requirement for sound EVM practices. The assumption when the task order was written against the overarching IDIQ was that the requirements stated in the IDIQ would adequately cover EVM reporting required from the potential vendor. Therefore, within the task order no such language was included, subsequently resulting in no reporting by the vendor. This lack of reporting further complicated matters when required reporting to senior leadership was inadequate due to no EVM data. The vendor was queried but, since no requirements were within the task order they did not have to comply.
How could this have been prevented? The solution is to understand the policy and guidance, apply it wisely, and leverage best practices to ensure task orders written against an existing IDIQ contract contain all FAR and DFAR language requiring EVM.
Understand the Policy and Guidance
For example, if the task will result in a “cost or incentive” task order with an anticipated value of $20 million or more, include the proper EVM language. For “cost or incentive” task orders under $20 million, the application of EVM is optional and is a risk-based decision. If applied, it must be based on a cost-benefit analysis and documented in the contract file. DFARS 234.201 and the Earned Value Management Implementation Guide (EVMIG), Section 2.2.3.1 contain the proper guidelines for what to include. The guidance further stipulates “the application of EVM is discouraged, regardless of dollar value, on Firm Fixed Price, Level of Effort, or Time and Materials task orders.”
Apply Policy and Guidance
- Incorporate applicable language into Task Order templates such as:
- The Contractor shall use an Earned Value Management System (EVMS) in compliance with DFARS clauses 252.234-7001 and 252.234-7002 to plan, track, and manage program activities
- The Contractor shall provide Contract Performance Reports (CPRs) (Deliverable 7) in accordance with the requirements of DID DI-MGMT-81466A, “Contract Performance Report (CPR)
- For awards valued at or over $20 million, but under $50 million, the CPR may be tailored to CPR Format 1 (Work Breakdown Structure), Format 3 (Baseline), and Format 5 (Explanations and Problem Analyses) if requested by the Contractor and approved by the COR
- For awards valued under $20 million , but containing an EVM requirement, the CPR may be tailored to CPR Format 1 (Work Breakdown Structure), and Format 5 (Explanations and Problem Analyses) if requested by the Contractor and approved by the COR
- The Contractor shall prepare Contract Funds Status Reports (CFSR) (Deliverable 8) in accordance with DID DI-MGMT-81468, “Contract Funds Status Report”
What Did the Agency Learn?
With an understanding of the utility of IDIQ contracts and the proper requirements for language required, you can avoid problems when executing the task order. The agency in this example learned the importance of thoroughly reviewing the requirements for the service the task order will cover and ensuring all applicable language is included in the task order.
Some tips to ensure success:
- Do include all DFARS and FARS EVM required language for CPFF contracts over $20M
- Do not assume the overarching IDIQ will cover your requirements at the task order level
- Always consult with the Contracting Officer of the office holding the IDIQ
- Ensure the vendor receives the required Integrated Program Review ensuring proper reporting requirements are well understood
How will you write your next task order?
