Report | Jan. 6, 2022

Evaluation of Contract Monitoring and Management for Project Maven (DODIG-2022-049)

Evaluation

Publicly Released: January 10, 2022

 

Objective

The objective of this evaluation was to determine whether the Army Contracting Command (ACC), the Army Research Laboratory (ARL), and the Algorithmic Warfare Cross-Functional Team (AWCFT, also known as Project Maven) monitored Project Maven contracts in accordance with the Federal Acquisition Regulation (FAR), Defense Federal Acquisition Regulation Supplement (DFARS), and DoD policy.

 

Background

To support AI development, the AWCFT partnered with the ACC to award four contracts and one cooperative agreement. Federal procurement guidelines define the structures, mechanisms, and roles for conducting contract administration, surveillance, and monitoring to track contract performance and contract deliverables and to mitigate risks. The primary roles that support contract monitoring and management include the Contracting Officer (KO), the Contracting Officer Representative (COR), and the Technical Monitor (TM).

 

Findings

The ACC-Aberdeen Proving Ground Contracting Center KO appointed a Contracting Officer Representative (COR) for Project Maven’s four contracts and one cooperative agreement in accordance with the FAR, and the Army Research Laboratory COR and the AWCFT TM successfully monitored and managed Project Maven’s four contracts and one cooperative agreement in accordance with the FAR, DFARS, Defense Grant and Agreement Regulatory System, and contract requirements. Specifically, the TM, with the support of the AWCFT, actively monitored contract deliverables using AWCFT‑developed reporting, metrics, processes, and procedures to monitor and manage the Project Maven contracts and meet Project Maven objectives.

However, the AWCFT did not document its approach to monitoring by formalizing the reporting metrics, processes, and procedures for monitoring and managing Project Maven contracts.

Without formalized and documented processes, there is an increased risk of lapses occurring in the monitoring and management of the Project Maven contracts as the program grows and as project personnel change. This could negatively affect the long-term success and growth of the project.

In addition, as AI and machine learning programs expand within the DoD, future DoD acquisitions related to this complex, rapidly moving technology may not benefit from the monitoring and management lessons learned.

Best practices that can further refine and develop these types of acquisitions, as well as help provide continuity for management and monitoring of emergent technology, could be lost if these processes are not documented.

 

Recommendations

We recommend that the Chief of the AWCFT formalize Project Maven’s processes and procedures for monitoring and managing AI development contracts to ensure knowledge management, continuity, and efficiency when the project is transferred to a mission owner and for reference by subsequent novel technology projects and cross-functional teams.

We recommend that the Assistant Secretary of Defense for Acquisition conduct a review of the AWFCT’s emerging technology acquisition processes and procedures to evaluate whether any of the processes and procedures used by the AWCFT should be further formalized in acquisition policies, implemented by other programs and cross-functional teams, or incorporated into relevant curriculum and training.

 

Management Comments and Our Response

Throughout the evaluation, we discussed the need to formalize Project Maven’s processes and procedures with AWCFT personnel and AWCFT regularly shared draft documentation in support of that need. On October 14, 2021, we discussed the specific recommendations of this report with the AWCFT. During the discussion, the AWCFT Chief stated that the Joint Requirements Oversight Council Memorandum supporting the transition of Maven’s [REDACTED].

Additionally, following the October 14, 2021, discussion, the AWCFT provided evidence of actions taken to address the recommendation in this report, including a description of roles and responsibilities, standard operating procedure, and a Maven acquisition guide. The AWCFT also provided us the Joint Requirements Oversight Council Memorandum supporting the transition of Maven to a mission owner, which also outlined several requirements to ensure continuity and a seamless transition. These actions meet the intent of the recommendation; therefore, the recommendation is closed.

The Assistant Secretary of Defense for Acquisition concurred with the recommendation to review the AWFCT’s emerging technology acquisition process for possible inclusion in DoD acquisition guidance. To support this effort, the Office of the Assistant Secretary of Defense for Acquisition will interact with the Project Maven team to gather additional details, such as approaches that dynamically handle changing performance metrics and needs, and determine if and how those approaches can be elaborated upon in DoD acquisition guidance. The comments meet the intent of the recommendation; therefore, the recommendation is resolved, but will remain open. We will close the recommendation when the Assistant Secretary of Defense for Acquisition provides us the results of the review of Project Maven’s practices and resulting determination of whether those practices were incorporated into DoD acquisition guidance.

 

This report is the result of Project No. D2021-DEV0PD-0023.000.