AIA’s National Security Policy Division is responsible for the implementation of national security policy-related goals stemming from the AIA strategic plan. To do this, the division uses two councils to direct analysis and action on all national security policy related issues, the Defense Policy Council and the Acquisition Policy Council. The Defense Policy Council is composed of senior representatives from AIA’s corporate membership and is responsible for defense policy, budget, resources, and strategy. The Acquisition Policy Council is comprised of the senior corporate contracts Vice Presidents of the major Executive Committee companies and is the primary coordination point for initial input development of acquisition topics for executive-level meetings with DOD.

Better Buying Power 3.0 released in April 2015, identified several proposed changes to IR&D allowability criteria. AIA has commented substantially on what is in BBP 3.0 and has held a number of meetings with DoD where this topic has been addressed that has enabled industry to voice its concerns with what AT&L has proposed. In response, AT&L issued a “White Paper” in August 2015 that revised what was in BBP 3.0 and reflected a number of industry concerns voiced by AIA. The White Paper has now been succeeded by two new IR&D proposed rules issued in February 2016. The first, issued as an ANPRM or Advance Notice of Proposed Rulemaking is focused on IR&D used to reduce bid price on proposal submissions in competitive source selections. The second proposed rule focuses on changes to allowability criteria and follows the roadmap of what was in the August 2015 AT&L “White Paper”. AIA recently provided remarks in a public meeting on the ANPRM (see attached). In addition, both rules are being evaluated by the AIA IR&D Working Group which will coordinate with other affected AIA councils and committees and provide formal response submissions to the DAR Council in April 2016.

AT&L released a commercial item and price reasonableness proposed rule in 2015, along with a Feb 4 2015 memo to contracting officers on commercial pricing. Both of these drew heavy criticism from AIA, Congress and others, as being out of step with what was in NDAA 2016 as well as being in conflict with internal OSD strategic planning, such as the 3rd Offset Strategy. Subsequently, both the proposed rule and memo to contracting officers have been withdrawn by OSD. With the enactment of NDAA 2016 which contained a significant number of commercial item pricing legislative actions, OSD has indicated it is working on the release of a revised proposed rule that will incorporate what is in NDAA 2016. In addition, OSD has also stated it will concurrently release (in draft for industry comment) an update to its commercial item guidebook that also will reflect the intent of NDAA 2016. AIA will take an active role in thoroughly reviewing and commenting on the release of the proposed rule and guidebook later this year upon release.