Aerospace Industries Association released a 52-page response to the Senate and House armed services committees’ call for input as lawmakers pursue acquisition reform this summer. The group suggested a slew of actions to reduce the cost and time of an acquisition project, better train and develop the acquisition workforce and foster better relationships with defense contractors and trade associations.United States Capitol

AIA identified four key areas of struggle for its member companies. First, it notes the challenges related to the Defense Department’s auditing requirements.

“Over the past decade, the number of regulations has grown substantially,” according to the report. “With these new regulations come requirements for a more exhaustive compliance regime that seeks to mitigate all risk of misconduct and malfeasance. This compliance regime is costly to both industry and government, yet its benefits are difficult to quantify. Audits have become more complex, requiring more government and industry personnel to complete them. This complexity often adds time to completing the audits, impacting delivery schedules and key milestones as well as contract closeouts.”

Audit-related delays are frustrating to the government, but they can be crippling to small businesses that need a steady source of revenue to stay in business. AIA urges DoD to clear its audit backlog, reduce excessive documentation requirements and eliminate redundant audits.

The report also cites DoD’s push to collect intellectual property (IP) rights, particularly as it looks to boost competition in maintenance and modernization contracts to keep program lifecycle costs down.

“While competition and long term sustainment options are important and laudable objectives, DoD policies advocating for broad IP rights to privately developed technologies are fundamentally incompatible with corporate business strategies and dissuade private investment,” AIA wrote.

The report also points to a lack of industry engagement as new regulations are developed and implemented, as well as inconsistencies as DoD tries to buy more commercial off-the-shelf items, as challenges to smart acquisition.

The report makes dozens of recommendations in various categories, the first being to develop an effective governance model. “Examine the cost of oversight and assess whether the burden adds real value to the outcome of an acquisition program. Demand the logic inherent in the value proposition behind the oversight,” AIA suggests. The group also notes that program managers ought to have more control over their programs–not only should they have the people and resources needed for success, but the oversight infrastructure should serve their needs instead of the other way around. “Let program managers buy support from the Defense Contract Management Agency (DCMA) and the Defense Contract Audit Agency (DCAA)–rather than the DCMA and DCAA deciding what the program needs, as well as when and how the requirement is met.”

To improve communication, AIA suggests a DoD-Industry Acquisition Board to continually discuss areas for improvement in acquisition.

As for Congress’s role in improving acquisition, AIA suggests Congress should provide budget stability; understand and assess the benefits of new regulations, oversight and reporting requirements before lawmakers vote to implement them; insure DoD interprets new laws as intended; and educate all lawmakers on the health and fragility of the defense industrial base.

Other categories of recommendations include steps to take to reduce costs, get weapons to the warfighter faster, improve the acquisition workforce, empower key personnel to make sound choices throughout the acquisition process, and develop and foster technical expertise needed to support successful acquisition.

The Senate and House armed services committees reached out to National Defense Industrial Association, Aerospace Industrial Association, TechAmerica, Professional Services Council, Information Technology Industry Council, American Bar Association, American Federation of Government Employees, International Federation of Professional & Technical Engineers and the Metal Trades Department of the AFL-CIO on March 31. The letter to each organization asks for steps DoD or Congress could take to achieve a list of goals that would, as a whole, improve defense acquisition.