The memorandum the September industrial base memo keeps referring back to directs contracting officer access to actual cost data at prime and supplier level for actions of $10 million or more, regardless of whether certification is required, and ordered delinquent CSDR reports submitted within 30 days. That deadline has passed.

DCMA and DCAA are directed to overhaul how forward pricing rate agreements are built. Estimating system and MMAS reviews are to be folded into commercial-aligned accounting system criteria within 90 days. Earned value management is confined to major development programs. And a DFARS profit policy rulemaking starts within 90 days.