that, “Consistent with section 2334, cost data reporting is required for all MTA programs with total estimated acquisition expenditures greater than $100 million” and established CAPE as responsible for “approval of cost data collection plans” for Acquisition Category (ACAT) I-sized programs. Individual Service test and evaluation (T&E) organizations made clear that T&E played a significant role in MTAs. For example, the USAF/TE’s January 2019 Interim Rapid Acquisition Test Policy noted that “Rapid does not mean reckless, nor does rapid acqui- sition skimp on test.” In addition to these functional or- ganizations clarifying their role in MTA programs, OSD also saw the need to establish some additional governance. First, the USD(A&S), on Oct. 9, 2018, published a memorandum establish- ing “monthly MTA governance meet- ings” and “quarterly data collection,” while noting that “MTA programs do not require OSD approval; however, OSD may determine that specific pro- grams are not appropriate for MTA.” In a Dec. 19, 2019, memorandum, the Deputy Secretary of Defense took it a step further for ACAT I-sized pro- grams, by requiring written approval from the USD(A&S) in order to follow the MTA pathway. Shortly after publication of the Deputy Secretary’s memo, which in- cluded many other acquisition policy decisions, the USD(A&S), on Dec. 30, 2019, published DoDI 5000.80, Operation of the Middle Tier of Ac- quisition, even preceding the formal establishment of the Adaptive Acqui- sition Framework (AAF) with DoDI 5000.02 being reformatted from 188 to only 17 pages and published on Jan. 23, 2020. Over the next two years, each of the six AAF pathways gained its own DoDI, and the previous DoDI 5000.02’s functional enclosures also became standalone DoDIs. Several of these functional DoDIs provide spe- cific MTA guidance. Recently, DoDI 5000.80 has been updated (Change 1, Nov. 23, 2024), and the law was changed shortly
thereafter with enactment of the FY 2025 NDAA (Dec. 23, 2024). OSD recognized that with several years of growing up, some policy needed to change, and some previous language needed clarification. For example, the original DoDI 5000.80 identifies three circumstances where MTA is discouraged, including programs that are “critical to interagency require- ment, primarily focused on technol- ogy development, or have significant international partner involvement.” Change 1 explains this by adding, “For programs that include interna- tional partner involvement, program managers (PMs) must ensure that all efforts to design and implement exportability to foreign partners are consistent with” applicable laws and statutes. This makes sense, as the DoD can benefit both operationally and economically via vehicles such as foreign military sales and direct commercial sales. Some items needing better ex- planation included the program start date and the major defense acquisi- tion program equivalent definitions. With speed as a key ingredient in pursuing new innovative technol- ogy, OSD demonstrated concern for ensuring “scale” was considered by requiring each MTA program to em- ploy a product support manager. This planning for “scale” has been further reinforced with each Rapid Fielding (RF) program including “sustainment requirements in its design require- ments, system specifications, and contracts,” as well as requiring MTA PMs to consider “intellectual prop- erty” in their acquisition strategy. Functional DoDIs that specifically address MTA are now referenced
throughout Change 1. For example, “programs on the DOT&E [Director, Operational Test and Evaluation] oversight list shall ensure that they are operating in full compliance with DoDI 5000.89.” In the past, there were some questions about how or- ganizations such as CAPE and DOT&E interfaced with an MTA program. An area of confusion in the origi- nal DoDI 5000.80 was the transition out of MTA. DoDI 5000.80, Change 1 made the transition much clearer for both MTA-Rapid Prototyping and MTA-Rapid Fielding. A transi- tion plan is required within two years of program start. Furthermore, “the transition plan will provide a time- line for completion of all necessary documentation required for transi- tion ... no later than 3 months be- fore program completion.” This is a welcome clarification. Finally, Change 1 introduces a newer concept. It states that the “online requirements specified at AAFDID (the Adaptive Acquisition Framework Document Identification [https ://www.dau.edu/aafdid/mta] ) will in- form MTA program management and are to be treated the same as if the requirements were published in this issuance.” In other words, readers are well advised to check the MTA requirements in the AAFDID to en- sure they are following the most cur- rent guidance. While some may find this a tad cumbersome, it’s essential as new law and program experience will most likely dictate policy changes. In walks the FY 2025 NDAA! This has provided significant changes to the original FY 2016 language, such as deleting some aspects of the FY 2016 NDAA Section 804 that previ-
20 | DEFENSE ACQUISITION | May-June 2025
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