Section 893 of the FY 2011 NDAA
requires the improvement of contractor business systems to ensure
that they provide timely, reliable information for the management
of DoD programs. Contractor business systems and control systems
are the first line of defense against waste, fraud, and abuse. Weak
control systems increase the risk of unallowable and unreasonable
costs. It is essential that DoD immediately commence to require
these improvements to contractor business systems.
The change in burden is the
result of using: (1) actual data from the subject matter experts
who manage the DoD program for conducting the EVMS reviews and
using, as a baseline, the three most recent fiscal years for which
EVMS reviews were conducted; and (2) the current OPM GS hourly
labor rates for fiscal year 2018 to calculate the cost per hour.
The main driver in reducing respondent burden was a change made in
2015 to thresholds determining when an EVMS review is required.
This was part of a DoD Better Buying Power 3.0 initiative that led
to an increase in the review threshold from $20 million to $100
million. This reduced the number of contracts requiring an EVMS
review by 50% and resulted in fewer contractors requiring an EVMS
review that may result in a determination requiring a response. One
area where the burden did increase was on the Government burden,
where DoD has experienced more time consumed as overhead in
managing the process.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.