Changing a humanitarian project

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1. An approved project belongs to a year

Approval of a humanitarian project does two things at once. It authorizes the work, and it ties that work to one appropriation. Once the decision is made, "the CCMD has the authority to expend OHDACA funds from the approved FY appropriation to execute the project in accordance with the approved project scope" (SAMM C12.6.8).

Both halves of that sentence bind. The money is from a particular year, and the work is what was described. Changing either one means going back for permission, and how the approval was obtained in the first place is covered in how an OHDACA project is approved.

Everything that follows in this part of the manual is about two kinds of drift: costs that rise, and projects that cannot be executed in the year they were funded.

2. The first question when a cost rises

Not all increases are equal, and the test is asked before anything else. "CCMDs will first determine whether the project cost increase is for a requirement that is within the approved project scope or represents a change-of-scope from the approved project" (SAMM C12.6.7).

A within scope increase is the same project costing more. A change of scope is a different project. The routes for the two diverge sharply, and the second is slower and more expensive.

3. Ten percent, and a record in the file

Small within scope increases are handled locally. "CCMDs may fund within-scope project requirements that exceed the approved project cost by up to 10 percent" (SAMM C12.6.7.1) using either the original year money or current year money.

There is a stated preference between those two. "It is generally preferable to use prior year funds so that current year funds are preserved for current/new requirements" (SAMM C12.6.7.1). Old money for old problems, so this year can buy this year.

The only formality is documentary. "The CCMD will enter a record of their actions in the project comment field" (SAMM C12.6.7.1). No approval is sought, but the decision is visible afterwards.

4. Above ten percent

Beyond that margin the first move is not a request for more money. "CCMDs should seek to offset requirement costs with equal cost decreases in project cost elsewhere" (SAMM C12.6.7.2).

If the books cannot be balanced internally, a formal request follows, and its contents show what the reviewer is testing. It carries a within scope determination from the contracting office, an "Explanation of the requirement and why it was unforeseen" (SAMM C12.6.7.2.1.2), and the amount of prior year money being asked for (SAMM C12.6.7.2.1).

The word unforeseen is doing the work. A cost that could have been predicted is a planning failure rather than an adjustment.

Review is two stage. The humanitarian division considers it and, if content, passes it to the general counsel, who must concur with the within scope determination before the approved cost is changed (SAMM C12.6.7.2.2). Then the money moves: "The DSCA (Office of Business Operations, Comptroller Directorate (OBO/CMP)) issues prior-year funds to the CCMD" (SAMM C12.6.7.2.4), or the command is told to use current year funds if prior year money is not available.

5. When the project itself changes

The manual opens this subject with advice rather than procedure. "Scope changes after project approval should be avoided" (SAMM C12.6.7.3).

Where one is unavoidable, the new scope has to satisfy the same legal and policy tests the original did, because a humanitarian purpose is a condition of the money rather than of the project. Nothing can be committed in advance: "DSCA must approve both the project scope change and the increased project amount before the CCMD may obligate funds against the requirement" (SAMM C12.6.7.3).

The request explains why the requirement was unforeseen, states the new total cost, and shows the effect on the current year budget submission (SAMM C12.6.7.3.1).

And the funding answer is different from a within scope increase. "Approved changes in scope and new scope constitute requirements of the FY in which they are identified, so the CCMD will use current year funding to cover the expense" (SAMM C12.6.7.3.4). New scope is this year’s problem, whatever year the project came from.

6. Moving a project to a different year

Two moves are possible, and both are requests rather than choices. The first goes backwards. "The CCMD may request to fund an approved project with available funds from the previous FY appropriation, rolling back the project into the previous FY program" (SAMM C12.6.8.1).

That needs a specific assertion, because spending old money on a new requirement is exactly what appropriations law forbids. The request explains the circumstances while "confirming that the requirement is a bona fide need of the earlier FY" (SAMM C12.6.8.1.1). The reviewer then checks the other direction: "DSCA reviews the project to ensure that an early execution of the project will not violate legal and policy guidance under the new appropriation FY" (SAMM C12.6.8.1.2).

The second goes forwards, and it exists for projects that simply could not be delivered in time. "In the event a CCMD is unable to execute a high-priority, approved project before the end of the funds period of availability, the CCMD may request a rollover of the project to a subsequent FY program" (SAMM C12.6.8.2).

Three things must still hold. "CCMDs will confirm that the identified project remains valid, still has the commitment of the partner, and there is no scope or cost change" (SAMM C12.6.8.2). A project that has quietly grown cannot be rolled; it has to be changed instead.

7. Two years, and no more

There is a hard limit on how long a project can be carried. "DSCA will not approve any rollover requests beyond two years" (SAMM C12.6.8.2) of the original approved funding year.

Late requests are visible in the program. Where the new year budget submission has already gone in, "the project will be listed in the new FY as an out-of-cycle project" (SAMM C12.6.8.2.3), which is why "CCMDs are encouraged to submit project rollover requests prior to submittal of the CCMD ABS" (SAMM C12.6.8.2.3).

Both moves are recorded in the project system rather than by memorandum, with the funding year changed directly in the record (SAMM C12.6.8.2.3).

8. What a supplier can take from this

The ten percent margin is the most useful number here. Within scope growth under that threshold is absorbed locally with a note in the file. Above it, a determination from the contracting office and a legal concurrence are required, and the money may have to come out of the current year.

The word unforeseen is where variation claims are won or lost. A cost the contractor could have identified at nomination stage is hard to fund afterwards, which makes an accurate initial estimate worth more than a competitive one.

And a project that slips gets at most two years of grace, on condition that nothing about it has changed. A slipping project that also grows is no longer eligible for rollover at all, which is a strong reason to keep scope and schedule problems separate.

Key terms

Within scope increase	The same project costing more. Up to ten percent is handled locally with a record in the file.
Change of scope	A different project, needing approval before any funds are committed, and paid from current year money.
Rollback	Funding an approved project from the previous year, on a confirmed bona fide need of that earlier year.
Rollover	Carrying an unexecuted project into a later year, for no more than two years and only if nothing has changed.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

How Sentfore supports this

A project that slips or grows still has to be delivered somewhere difficult. Sentfore provides secure movement, protective security, facilities and life support for defense programs in complex environments. Requirements can be sent through the contact page.