Acquisition
Earned value management (EVM), explained
What earned value management measures, how CPI and SPI are computed, which EIA-748 revision and DFARS thresholds apply in 2026, and what GAO found when programs relied on EVM data.
Oct 22, 20265 min read8 sources
Why it matters
Contractor EVM data drive estimates of final cost, and GAO calculated in 2024 that the Columbia class lead submarine's likely overrun was more than six times the shipbuilder's own estimate.
The short version
- 1Earned value is the budgeted cost of work performed; CPI divides it by actual cost, and SPI divides it by planned value.
- 2SAE revised EIA-748 in February 2026, and DoD's June 2026 interpretation guide assesses systems against its 27 guidelines, down from 32.
- 3Under DoD class deviation 2026-O0011, effective February 1, 2026, EVM compliance applies at $50 million and a validated system at $100 million.
Earned value management (EVM) is a project control method that compares the value of work actually accomplished with the work planned for the same period and with what the accomplished work cost. The Department of Defense (DoD) requires it on large cost-type and incentive contracts through the Defense Federal Acquisition Regulation Supplement (DFARS). The Government Accountability Office (GAO) Cost Estimating and Assessment Guide of March 2020 ties EVM to cost estimating: actual costs and measured progress replace forecasts as work proceeds. Two things changed in 2026. The industry standard, EIA-748, was revised in February, and a DoD class deviation effective February 1 raised the contract dollar thresholds.
What EVM measures
GAO's guide uses three quantities. Planned value is the budgeted cost of work scheduled. Earned value is the budgeted cost of work performed. Actual cost is the actual cost of work performed. GAO's tables label them BCWS, BCWP, and ACWP; other texts use PV, EV, and AC. Two indexes follow. The cost performance index (CPI) is earned value divided by actual cost; below 1.0, the work done cost more than planned. The schedule performance index (SPI) is earned value divided by planned value; below 1.0, less work was done than planned. Schedule variance is stated in dollars, not time.
GAO's worked example shows why spending alone misleads. A contract calls for 4 miles of track in 4 weeks for $4 million. After 3 weeks, $2 million has been spent, which looks like an underrun. Only 1 mile is laid, so the work is 25 percent complete. At that rate the job costs $8 million and takes 12 weeks.
The standard's abstract states the same idea. Each scheduled element of work gets a planned value, its budget, which is earned when the element is completed.
The EIA-748 guidelines
EIA-748, Earned Value Management Systems, is published by SAE International, which sells the full text. The SAE record lists revision E as revised February 17, 2026 and first issued in June 1998, with revision D dated January 8, 2019. The National Defense Industrial Association (NDIA) EIA-748-E Intent Guide, dated May 14, 2026, says revision E revised, merged, or deleted the earlier guidelines to create a streamlined set of 27. The earlier set had 32.
DoD followed. The DoD EVM System Interpretation Guide, dated June 24, 2026, is the basis for DoD compliance reviews against the 27 guidelines. The guide sorts them into five categories: organization (1 to 4); planning, scheduling, and budgeting (5 to 13); progress assessment and data collection (14 to 16); analysis and management reports (17 to 23); and revisions and data maintenance (24 to 27). When DoD is the cognizant Federal agency, the Defense Contract Management Agency (DCMA) determines compliance, not the procuring contracting officer.
DFARS thresholds in 2026
The codified clause, DFARS 252.234-7002 dated January 2025, requires a system that complies with EIA-748. At $50 million or more, the system must be one the cognizant Federal agency has determined acceptable. Below $50 million, the Government makes no formal compliance determination.
DoD contracting officers now use different text. Class deviation 2026-O0011, signed December 18, 2025 and effective February 1, 2026, substitutes a revised DFARS Part 234 and clause 252.234-7999. Cost or incentive contracts and subcontracts of $50 million or more must use a system that complies with the guidelines. Those of $100 million or more need a system the cognizant agency has determined compliant. Below $50 million, EVM is optional and a risk-based decision. On firm-fixed-price contracts it is discouraged and needs a waiver. Contracts primarily for software, including those on the software acquisition pathway, are exempt. An integrated baseline review must still occur within 180 calendar days of award, a significant option, or a major modification.
One mismatch remains. The deviation still names high-risk guidelines by numbers that run to 32, from the old set, while the June 2026 guide uses 27.
What GAO found
GAO's guide reports that studies of more than 700 defense programs found limited chance of recovery once a program is 15 to 20 percent complete. After 20 percent, the cumulative CPI varies by less than 10 percent and usually worsens, so an estimate at completion based on it tends to be a best case.
The September 2024 Columbia class report applied that research. Using shipbuilder EVM data from January 2022 through May 2023, GAO found lead submarine construction performing very inefficiently in cost against its baseline. Electric Boat's estimate at completion still assumed a dramatic improvement. GAO's calculated overrun was more than six times the shipbuilder's estimate and almost five times the Navy's. Reports flagged variances without identifying root causes, impacts, or corrective actions. Construction was 40 percent complete as of November 2023.
Data can also fail outright. In July 2010, GAO could not use EVM data for two Missile Defense Agency contracts, Ground-based Midcourse Defense and Targets and Countermeasures, because their baselines no longer matched the program. The midcourse program had three restructures since 2007 totaling over $2 billion and no integrated baseline review since December 2006.
What to check
- Does the contract carry clause 252.234-7999 under deviation 2026-O0011 or the codified 252.234-7002, and do its thresholds match that text?
- Is the contract primarily for software, and so exempt under the deviation?
- Does the contractor's system description map to the 27 guidelines of revision E or to the older 32?
- Was the integrated baseline review held within 180 calendar days of award or of the last major modification?
- Does the estimate at completion assume better efficiency than the cumulative CPI to date, and what justifies it?
- Do variance reports give root causes, impacts, and corrective actions, the gaps GAO found on Columbia?
Azcuna's LEDGER turns a trade study into a Decision Package in which every number cites its source and AI agents draft but never decide. It was proposed to the Army under SBIR Phase I topic ARM26BX06-NV012, and the proposal was submitted on October 21, 2026.
Sources
- 1GAO-20-195G, Cost Estimating and Assessment Guide: Best Practices for Developing and Managing Program Costs · U.S. Government Accountability Office, March 2020
- 2EIA748E, Earned Value Management Systems · SAE International, revised February 17, 2026 (abstract page)
- 3Earned Value Management Systems EIA-748-E Intent Guide · National Defense Industrial Association, Integrated Program Management Division, May 14, 2026
- 4Department of Defense Earned Value Management System Interpretation Guide (EVMSIG) · OUSD(A&S), Defense Pricing, Contracting, and Acquisition Policy, June 24, 2026
- 5252.234-7002 Earned Value Management System · Acquisition.gov (Defense Federal Acquisition Regulation Supplement), DFARS Change 5/7/2026
- 6Class Deviation - Revolutionary Federal Acquisition Regulation (FAR) Overhaul Part 34, Defense FAR Supplement (DFARS) Part 234 (DARS Tracking Number 2026-O0011) · Defense Pricing, Contracting, and Acquisition Policy, effective February 1, 2026
- 7GAO-24-107732, Columbia Class Submarine: Overcoming Persistent Challenges Requires Yet Undemonstrated Performance and Better-Informed Supplier Investments · U.S. Government Accountability Office, September 2024
- 8GAO-10-676, Defense Acquisitions: Missile Defense Program Instability Affects Reliability of Earned Value Management Data · U.S. Government Accountability Office, July 2010
Where this shows up in our work
- LEDGER, auditable Army acquisition decisions turns a trade study into a package where every number cites its source and AI drafts but never decides.
- ELLMENT, the offline LLM for E-2D crews answers a crew's question from the aircraft's own manuals and cites the page, with no network.
- TRACE, the offline S1000D and IETM viewer opens S1000D, MIL-STD-3001 and PDF technical manuals on a tablet with every marking intact.
