I work for a large gov?t agency on a level I acquisition program as the gov't EVM lead. We have a $1B contract with a prime. Under one large task order with many CLINs and many Control Accounts (CAs), we have several CAs that have under-run their budget. This is a LOE on a CPFF contract. The PM would like to have the contractor continue performing LOE work until the funds are exhausted. The CO has issued a contract mod to extend the PoP and allow the contractor to continue working - but will not add ceiling. My contractor EVM team is telling me that in order to plan the additional work, they need additional budget (ie, ceiling) against which to plan the additional work. Note the distinction - they don't need funding - they need ceiling.
As an example, say we are funded for, and plan $1M worth of LOE work over 12 months. As we set up our EV system, we budget $1M worth of work over 12 mos (BCWS) at a planned value of $1M (BCWP). At the end of 12 months, we've only spent $800k (ACWP = $800k). In EV terms, we have a cost variance of +200k - not a bad thing! We have measured costs against the $1M. Now, we want to spend an additional 200k. We have to plan that against an additional 200k, as we've already planned and measured against the original $1M. To do this, we need additional budget authority (again, ceiling) so that we will have planned $1.2M worth of work - which should come in at the funded amount of $1M. At the end, the BCWS = 1.2M, BCWP - 1.2M, and ACWP - 1M. Without the additional ceiling against which to plan the additional work, we will have a situation where we plan $0 work, schedule $0 work, but have $200k of cost - kind of tough to tell the taxpayer that we spent $200k on nothing.
My CO tells me that the FAR doesn't allow him to add ceiling when funding is sufficient. I say that he is adding scope (additional time on LOE work is scope, isn't it?) I say his options are to 1) add ceiling, but manage the contractor not to exceed funded amount, OR 2) close out the CA, de-obligate the remaining funds, and issue a new task/CA/whatever you want to call it, for the additional work the PM would like to have performed.
Am I wrong here? Certainly, I could be... but would welcome any comments that let me know where/how I'm wrong. I've looked for FAR clauses but can't find anything concrete. I know that EVMS guidelines (the 32 ANSI guidelines) definitely don't allow you to perform work that hasn't been properly planned. Thanks!!