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Key Product Support Definitions

As a quick reference, this site provides concise definitions of and sources for key DoD product support terms listed below. For additional information, visit the sources listed after each term, as well as the ACQuipedia website, the DAU Glossary of Defense Acquisition Acronyms and Terms, and the DoD Dictionary of Military Terms (JP 1-02). In addition -- although not an official DoD source -- the Council of Supply Chain Management Professionals (CSCMP) also maintains a Supply Chain Management Definitions and Glossary site, which may serve as a potentially useful, although unofficial, source of related definitions.

 


 

  • Best Value — Best value is “the expected outcome of an acquisition that, in the Government’s estimation, provides the greatest overall benefit in response to the requirement.” (Source: Federal Acquisition Regulation FAR 2.101) See also: FAR 1.102 Statement of Guiding Principles for the Federal Acquisition System: "The vision for the Federal Acquisition System is to deliver on a timely basis the best value product or service to the customer, while maintaining the public’s trust and fulfilling public policy objectives.” It goes on to articulate a vision whereby “all participants in the System are responsible for making acquisition decisions that deliver the best value product or service to the customer” and that “best value must be viewed from a broad perspective and is achieved by balancing the many competing interests in the System.” See also: FAR 15.101 Best Value Continuum, “An agency can obtain best value in negotiated acquisitions by using any one or a combination of source selection approaches. In different types of acquisitions, the relative importance of cost or price may vary. For example, in acquisitions where the requirement is clearly definable and the risk of unsuccessful contract performance is minimal, cost or price may play a dominant role in source selection. The less definitive the requirement, the more development work required, or the greater the performance risk, the more technical or past performance considerations may play a dominant role in source selection.” Note: Additional information on the “Best-Value Continuum" is also available in section 1.2 of the Department of Defense Source Selection Procedures and USD(AT&L) 4 Mar 15 memo entitled “Appropriate Use of Lowest Priced Technically Acceptable Source Selection Process and Associated Contract Type.” According to the latter, “LPTA is the appropriate source selection process to apply only when there are well-defined requirements, the risk of unsuccessful contract performance is minimal, price is a significant factor in the source selection, and there is neither value, need, nor willingness to pay for higher performance….Lowest Priced Technically Acceptable (LPTA) has a clear, but limited place in the source selection “best value continuum.” See also DAP Blog Post on Best Value for additional sources, examples, and references.

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  • Contractor Logistics Support (CLS) — CLS “is broadly defined as contracted weapon system sustainment that occurs over the life of the weapon system. Examples of CLS include contractor provided aircraft and engine overhaul, repair and replenishment of parts, sustaining engineering, and supply chain management." (Source: U.S. House Report 112-110 – 2012 DoD Appropriations Bill "Contractor Logistics Support (CLS)” Section). This House report also cited a 2009 RAND study that defined CLS as "contractor sustainment of a weapon system that is intended to cover the total life cycle of the weapon system and generally includes multiple sustainment elements. CLS does not include interim contractor support, a temporary measure for a system's initial period of operation before a permanent form of support is in place. CLS also excludes contractor sustainment support for a specific sustainment task that the Air Force would otherwise conduct itself; a typical example would be a weapon system's prime contractor providing sustaining engineering." CLS can also be defined as "the performance of maintenance and/or materiel management functions for a DoD system by a commercial activity. Current policy allows for the provision of system support by contractors on a long-term basis. Performance-Based Logistics (PBL) contracts should be used when utilizing CLS. Also called Long-Term Contractor Logistics Support." (Source: DAU Glossary)

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  • Core Logistics Analysis — By Milestone A, the DoD Component will document its determination of applicability of core depot-level maintenance and repair capability requirements in the LCSP in accordance with 10 U.S.C. 2366a. For Milestone B, the Program Manager will attach the program's estimated requirements for maintenance, repair and associated logistics capabilities and workloads to the LCSP in accordance with 10 U.S.C. 2366b. The program's maintenance plan will ensure that core depot-level maintenance and repair capabilities and capacity are established not later than 4 years after IOC in accordance with 10 U.S.C. 2464. The Program Manager will ensure that a depot source of repair designation is made not later than 90 days after the Critical Design Review. Before entering into a contract for low rate initial production, supportability analysis must include detailed requirements for core depot-level maintenance and repair capabilities, and associated sustaining workloads required to support such requirements. (Source: DoDI 5000.02, Enclosure 6, Para 3.d.(2))

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  • Diminishing Manufacturing Sources & Material Shortages (DMSMS) — The loss or impending loss of manufacturers of items or suppliers of items or raw materials may cause material shortages that endanger a weapon system’s or equipment’s development, production, or post-production support capability. (Source: DoD Manual 4140.01-V3 (Volume 3) Enclosure 3, Para 6.a)

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  • Integrated Product Support (IPS) Elements — Product support is scoped by the IPS elements, which provide a structured and integrated framework for managing product support. The IPS elements include product support management; design interface; sustaining engineering; supply support; maintenance planning and management; Packaging, Handling, Storage, and Transportation (PHS&T); technical data; support equipment; training and training support; manpower/ personnel; facilities and infrastructure; and computer resources. (Source: Product Support Manager (PSM) Guidebook)

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  • Interim Contractor Support (ICS) — ICS is “temporary contractor support that allows a Service to defer investment in all or part of required support resources (spares, Technical Data (TD), support equipment, training equipment, etc.), while an organic support capability is phased in.” (Source: DAU Glossary). The Army defines Interim Contractor Support (ICS) as “the use of commercial support resources in lieu of organic capability for a predetermined amount of time (goal is not to exceed 3 years). This includes the use of contractor support for initial fielding.” The glossary itself defines ICS slightly differently as “a method of support used in compressed or accelerated acquisition programs, or when design is not sufficiently stabilized. Provides all or part of a materiel system support by contract for a specified interim period after initial deployment to allow organic support capability to be phased in. A support acquisition technique rather than a support concept.” (Source: Army Regulation 700-127). ICS is similarly defined as “a temporary support method for an initial period of the operation of the system, equipment, or end-item. This strategy is utilized for controlling capital investment costs while design stability is being achieved and complex product support elements are being developed.” (Source: Air Force Instruction 63-101/20-101)

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  • Life Cycle Logistics - The Life Cycle Logistics career field spans the entire system life cycle, encompassing both acquisition and sustainment activities. It includes defense acquisition workforce professionals responsible for planning, development, implementation, and management of effective and affordable weapons, materiel, or information systems product support strategies. Life cycle logisticians perform a principal joint and/or DoD component logistics role during both the acquisition and operational phases of a system's life cycle to: ensure product support strategies meet program goals for operational effectiveness and readiness; ensure supportability requirements are addressed consistently with cost, schedule, and performance; ensure supportability considerations are implemented during systems design; meet system availability, reliability, operations and support cost, and mean down time objectives; and deliver optimal life cycle product support. Life cycle logisticians pursue two primary objectives, namely to ensure that weapons systems are designed, maintained, and modified to continuously reduce the demand for logistics; and to ensure effective and efficient logistics support. Life cycle logisticians achieve these objectives by ensuring the integration of the twelve Integrated Product Support (IPS) elements to maximize supportability, reliability, availability, maintainability, mission effectiveness, and affordability of the system throughout its life cycle. They influence system design and provide effective, timely product support capabilities that drive effective, best value product support planning and execution. (Source: DAU Catalog)

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  • Life Cycle Management (LCM) — Life Cycle Management is the implementation, management, and oversight, by the designated Program Manager (PM), of all activities associated with the acquisition, development, production, fielding, sustainment, and disposal of a DOD system across its life cycle.” (Source: JCIDS Operation Manual) “Life Cycle Management (LCM) is defined as the designated PM's implementation, management, and oversight of all activities associated with the acquisition, development, production, fielding, sustainment, and disposal of a DoD system across its life cycle. Under LCM, the PM, with support from the PSM for sustainment activities, is responsible for the development and documentation of an acquisition strategy to guide program execution from program initiation through re-procurement of systems, subsystems, components, spares, and services beyond the initial production contract award, during post- production support, and through retirement or disposal.” (Source: DoD Product Support Manager (PSM) Guidebook, Para 1.2)

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  • Life Cycle Sustainment — According to the DoDI 5000.02, “life-cycle sustainment planning and execution seamlessly span a system’s entire life cycle, from Materiel Solution Analysis to disposal. It translates force provider capability and performance requirements into tailored product support to achieve specified and evolving life-cycle product support availability, reliability, and affordability parameters. Life-cycle sustainment planning shall be considered during Materiel Solution Analysis, and shall mature throughout Technology Development. As LCSP (Life Cycle Sustainment Plan) shall be prepared for Milestone B. The planning shall be flexible and performance-oriented, reflect an evolutionary approach, and accommodate modifications, upgrades, and reprocurement. The LCSP shall be a part of the program’s Acquisition Strategy and integrated with other key program planning documents. The LCSP shall be updated and executed during Production and Deployment and Operations and Support. Life-cycle sustainment considerations include supply; maintenance; transportation; sustaining engineering; data management; configuration management; HSI; environment, safety (including explosives safety), and occupational health; protection of critical program information and anti-tamper provisions; supportability; and interoperability. Effective sustainment of systems results from the design and development of reliable and maintainable systems through the continuous application of a robust systems engineering methodology.” (Source: 2008 Version of DoDI 5000.02)

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  • Life Cycle Sustainment Plan (LCSP) — The Program Manager’s plan for formulating, implementing, and executing the product support strategy. It describes the efforts to ensure that the system’s design, as well as the development of the product support package, are integrated and contribute to achieving life cycle sustainment metrics. (Source: DTM 10-015). It serves as the program’s primary management tool to satisfy the Warfighter’s sustainment requirements through the delivery of a product support package. (Source: USD AT&L 14 Sep 11 Memo “Document Streamlining - Life-Cycle Sustainment Plan (LCSP)”)

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  • Logistics Assessment (LA) — An analysis of a program's supportability planning. Preferably, it is conducted by an independent and impartial team of Subject Matter Experts (SMEs) not directly associated with the program being assessed. An LA is not a compliance audit, but an effective and valid assessment of the program office's product support strategy, as well as an assessment of how this strategy leads to successfully operating a system at an affordable cost. As part of the LA, statutory, regulatory, and Component required documentation is reviewed and assessed for completeness and compliance prior to the milestone decision. The focus is on whether the program planning and methodology has a basis and can be successfully executed. Conducting the LA early in the program phase where the design can be influenced, and re-assessing the planning at each milestone and periodically thereafter as the design matures, is critical to fielding a sustainable system. It also provides senior decision makers critical information for making strategic trades within and across various programs. Also referred to as an “Independent Logistics Assessment" or ILA. (Source: DoD Logistics Assessment (LA) Guidebook)

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  • Major Weapon System — A system for which the Department of Defense is responsible shall be considered a major system if: (1) the total expenditures for research, development, test, and evaluation for the system are estimated to be more than $115,000,000 (based on fiscal year 1990 constant dollars); or (2) the eventual total expenditure for procurement for the system is estimated to be more than $540,000,000 (based on fiscal year 1990 constant dollars). (Sources: 10 USC 2337 Life-Cycle Management and Product Support and 10 USC 2302d: Major System: Definitional Threshold Amounts)

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  • Operating & Support (O&S) Life Cycle Cost Category — Life-cycle cost is defined as the sum of four major cost categories: (1) research and development costs; (2) investment costs, consisting of procurement, military construction, and acquisition-related operations and maintenance (O&M) associated with the production and deployment activities; (3) O&S costs; and (4) disposal costs. …O&S consists of sustainment costs incurred from the initial system deployment through the end of system operations. Includes all costs of operating, maintaining, and supporting a fielded system. Specifically, this consists of the costs (organic and contractor) of personnel, equipment, supplies, software, and services associated with operating, modifying, maintaining, supplying, and otherwise supporting a system in the DoD inventory…. O&S costs are composed of the following lower-level elements: Unit-Level Manpower, Unit Operations, Maintenance, Sustaining Support, Continuing System Improvement, Indirect Support, and Disposal. (Source: CAPE O&S Cost Estimating Guide)

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  • Operation & Maintenance (O&M) Appropriation — Funds current operations of force and for maintenance of equipment the Armed Services need to operate the force (includes expenses such as maintenance services, civilian salaries, travel, minor construction projects, operating military forces, training, education, depot maintenance, stock funds, and base operations support). (Source: DoD FMR 7000.14R)

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  • Operations & Support (O&S) Life Cycle Phase — Purpose of the Operations & Support phase is to execute a support program that meets materiel readiness and operational support performance requirements, and sustains the system in the most cost-effective manner over its total life cycle. Planning for this phase shall begin prior to program initiation and shall be documented in the Life Cycle Sustainment Plan (LCSP). Operations and Support has two major efforts: Life-Cycle Sustainment and Disposal. (Source: DoDI 5000.02)

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  • Performance-Based Agreement (PBA) — Performance Based Agreements formally document the agreed to level of support and associated funding, required to meet performance requirements. The PBA with the user states the objectives that form the basis of the performance-based product support effort. They establish the negotiated baseline of performance and corresponding support necessary to achieve that performance, whether provided by commercial or organic support providers. The Program Manager (PM) negotiates the required level of support to achieve the users desired performance at a cost consistent with available funding. Once the performance and cost are accepted by the stakeholders, the PM enters into PBAs with the user community which specify the level of support and performance. Likewise, PMs enter into performance-based agreements with organic sources and/or contracts with commercial sources which focus on supporting the users in terms of cost, schedule, and performance. Consequently, PBAs can describe agreements between 1) user and PM, 2) PM and support integrator(s), or 3) support integrator and support provider(s). The agreements should maintain flexibility to facilitate execution year funding and/or priority revisions and spell out the 1) objective outcomes, 2) performance measures, 3) resource commitments, and 4) stakeholder responsibilities. (Source: Defense Acquisition Guidebook Section 5.1.4)

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  • Performance Based Logistics (PBL) — PBL is synonymous with performance based life cycle product support, where outcomes are acquired through performance based arrangements that deliver Warfighter requirements and incentivize product support providers to reduce costs through innovation. These arrangements are contracts with industry or inter-governmental agreements. Attributes of an effective PBL arrangement include:
    • Objective, measurable work description that acquires a product support outcome.
    • Appropriate contract length, terms, and funding strategies that encourage delivery of the required outcome
    • A manageable number of metrics linked to contract requirements that reflect desired Warfighter outcomes and cost reduction goals.
    • Incentives to achieve required outcomes and cost reduction initiatives.
    • Risks and rewards are shared between government and commercial product support integrators and providers.
    • Synchronization of product support arrangements to satisfy Warfighter requirements.

(Source: ASD(L&MR) “PBL Comprehensive Guidance” memo, Nov 22, 2013)

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  • Procurement Unit Cost (PUC) — PUC "applies at the level of the subprogram and means the total of all funds programmed to be available for obligation for procurement for each such major subprogram, divided by the number of fully-configured end items to be procured under such major subprogram." (Source: 10 U.S.C. §2430a)

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  • Product Improvement — The procurement, installation, retrofit, modernization, upgrade, or rebuild of a component or subsystem of a weapon system platform or major end item that would improve the reliability, availability and maintainability, extend the useful life, enhance safety, lower maintenance costs, or provide performance enhancement of the weapon system platform or major end item. (Sources: Pilot program outlined in FY08 NDAA (Public Law 110-181), Sec. 330 as amended by FY13 NDAA (Public Law 112-329), Sec. 332)

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  • Product Support — The term “product support” means the package of support functions required to field and maintain the readiness and operational capability of major weapon systems, subsystems, and components, including all functions related to weapon system readiness (Source: 10 U.S.C §2337), including but not limited to materiel management, distribution, technical data management, maintenance, training, cataloging, configuration management, engineering support, repair parts management, failure reporting and analyses, and reliability growth tracking and the logistics (integrated product support) elements (e.g., support equipment, spares) related to weapon systems readiness. (Source: DTM 10-015)

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  • Product Support Arrangement (PSA) — The term “product support arrangement” means a contract, task order, or any type of other contractual arrangement, or any type of agreement or non-contractual arrangement within the Federal Government, for the performance of sustainment or logistics support required for major weapon systems, subsystems, or components. The term includes arrangements for any of the following:
    • Performance-based logistics
    • Sustainment support
    • Contractor logistics support
    • Life-cycle product support
    • Weapon systems product support

(Sources: 10 U.S.C. §2337 and DTM 10-015)

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  • Product Support Business Case Analysis (BCA) — The Product Support Business Case Analysis (BCA) is a structured methodology and document that aids decision making by identifying and comparing alternatives by examining the mission and business impacts (both financial and non financial), risks, and sensitivities. BCAs may be somewhat different from other decision support analyses through their emphasis of the enterprise wide perspective of stakeholders and decision makers and assessment of the holistic effects impacted by the decision. Other names for a BCA are Economic Analysis, Cost-Benefit Analysis, and Benefit-Cost Analysis. Broadly speaking, a BCA is any documented, objective, value analysis exploring costs, benefits, and risks. The Product Support BCA concludes with a recommendation and associated specific actions and an implementation plan to achieve stated organizational objectives and desired outcomes. One principle application of the Product Support BCA guidebook is to assist the Product Support Manager (PSM) in identifying the product support strategy that achieves the optimal balance between Warfighter capabilities and affordability. (Source: DoD Product Support Business Case Analysis (BCA) Guidebook)

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  • Product Support Business Model (PSBM) — The PSBM defines the hierarchical framework in which the planning, development, implementation, management, and execution of product support for a weapon system component, subsystem, or system platform will be accomplished over the life cycle. The PSBM effectively describes the methodology by which DoD intends to ensure achievement of optimized product support through balancing maximum weapon system availability with the most affordable and predictable total ownership cost. The model provides a clearly delineated description of the roles, relationships, accountability, responsibility and business agreements among the managers, integrators, and providers of product support. (Source: DoD Product Support Manager (PSM) Guidebook)

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  • Product Support Integrator (PSI) — The term “product support integrator” means an entity within the Federal Government or outside the Federal Government charged with integrating all sources of product support, both private and public, defined within the scope of a product support arrangement. (Sources: 10 U.S.C. §2337 and DTM 10-015)

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  • Product Support Management — As an element of product support, product support management is the development and implementation of product support strategies to ensure supportability is considered throughout the system life cycle through the optimization of the key performance outcomes of reliability, availability, maintainability and reduction of total ownership costs. The scope of product support management planning and execution includes the enterprise level integration of all twelve integrated product support elements throughout the lifecycle commensurate with the roles and responsibilities of the Product Support Manager position. Note: product support management is not synonymous with product support manager, although the product support manager plays a primary role in executing product support management activities. (Source: DoD Integrated Product Support (IPS) Element Guidebook)

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  • Product Support Manager (PSM) — The individual responsible for managing the package of support functions required to field and maintain the readiness and operational capability of major weapon systems, subsystems, and components, including all functions related to weapon system readiness, in support of the program manager’s life cycle management responsibilities. (Source: DTM 10-015)

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  • Product Support Provider (PSP) — The term “product support provider” means an entity that provides product support functions. The term includes an entity within the Department of Defense, an entity within the private sector, or a partnership between such entities. (Sources: 10 U.S.C §2337 and DTM 10-015)

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  • Product Support Strategy — The business and technical approach to design, acquire, and field the product support package to execute the sustainment strategy. It begins as a broad concept and evolves into a detailed implementation plan documented in the Life Cycle Sustainment Plan. (Source: DTM 10-015)

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  • Product Support Strategy Process Model — The Product Support Strategy Process Model represents the major activities required to implement, manage, evaluate, and refine product support over the life cycle. It is not a onetime process, but rather a continuing, iterative process in which the sustainment of a system (or systems) is adapted and evolved to optimally support the needs and requirements of the Warfighter in an effective and affordable manner. The DoD Product Support Strategy Process Model provides a ready reference to the iterative 12 steps for defining and implementing product support strategies. Note: as an implementation process model, this DoD Product Support Strategy Process Model should not be confused with the 12 Integrated Product Support (IPS) Elements, nor is it synonymous with the DoD Product Support Business Model, both of which are defined elsewhere on this page. (Sources: Product Support Manager (PSM) Guidebook (Section 4) and the PSM Toolkit)

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  • Program Acquisition Unit Cost (PAUC) — PAUC "applies at the level of the subprogram and means the total cost for the development and procurement of, and specific military construction for, the major defense acquisition program that is reasonably allocable to each such major subprogram, divided by the relevant number of fully-configured end items to be produced under such major subprogram." (Source: 10 U.S.C. §2430a) In addition, "PAUC is a funding measure defined by statute (10 U.S.C. §2430a) consisting of the total acquisition funding divided by the acquisition quantity as reported in the SARs (Selected Acquisition Reports). For PAUC, 'cost' is synonymous with the total amount of funding because it reflects the prices paid on RDT&E and production contracts as well as program execution costs. (Acquisition funding in this instance is defined as being equal to the sum of: (1) the development funding for prime mission equipment and support items, (2) the procurement funding for prime mission equipment, support items, and initial spares, and (3) the system-specific facilities funding)." (Source: Performance of the Defense Acquisition System: 2015 Annual Report, September 16, 2015, page xxi)

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  • Program Manager (PM) — The Program Manager (PM) is the designated individual with responsibility for and authority to accomplish program objectives for development, production, and sustainment to meet the user's operational needs. The PM shall be accountable for credible cost, schedule, and performance reporting to the MDA. (Source: DoDD 5000.01, Para 3.5). The term "program manager" means, with respect to a defense acquisition program, the member of the Acquisition Corps responsible for managing the program, regardless of the title given the member. (Source: 10 USC §1737. Definitions and general provisions)

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  • Public-Private Partnership (PPP) — A public-private partnership for depot-level maintenance under 10 U.S.C. §2474 is a cooperative arrangement between an organic depot-level maintenance activity and one or more private sector entities to perform DoD or Defense-related work and/or to utilize DoD depot facilities and equipment. Other government organizations, such as program offices, inventory control points, and materiel/systems/logistics commands, may be parties to such agreements. The terms public-private partnership and public-private partnering are frequently used interchangeably and are both often abbreviated as “PPP.” (Source: DoD Instruction 4151.21)

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  • Superior Suppliers — As part of BBP, the three Military Departments and the Defense Logistics Agency (DLA) each established a Superior Supplier Incentive Program (SSIP) to incentivize contractor performance by recognizing the contractors that provide the greatest value to the DoD through superior performance and by informing those who perform below average. The basis for SSIP designations are contract performance assessments reported by the PM (or equivalent) to CPARS. Each assessment rates the quality, schedule, cost control, management, utilization of small businesses, regulatory compliance, and other optional aspects of the contractor’s performance on a specific contract for a specified period. The contractor is allowed to review and comment on each assessment before it is finalized. There are some differences between the methods adopted by each Component. The three Services use the last 3 years of performance data from Contractor Performance Assessment Reporting System (CPARS) to rate the largest firms doing business with each Service. The 3-year periods results are weighted 3,2,1 in the scoring with the most recent rated highest. The DLA’s top 40 consists of the top performers in CPARS over the last 2 years and several companies that partnered with DLA on considerable cost-reduction initiatives. The Services are working to harmonize their methodologies. Companies with primarily service-oriented contracts were not considered by DLA at this time. Based on this analysis, the top suppliers are sorted into three tiers, with only alphabetical ordering within each tier. The very top-performing business units are in Tier 1 or Gold. The Tier 2 or Silver business units are the next highest performers. Finally, there are the Tier 3 or Bronze business unit performers. Additional information is available here. (Source: Performance of the Defense Acquisition System: 2015 Annual Report, September 16, 2015, page 99)

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  • Supply Chain Risk — The risk that an adversary may sabotage, maliciously introduce unwanted function, or otherwise subvert the design, integrity, manufacturing, production, distribution, installation, operation, or maintenance of a system so as to surveil, deny, disrupt, or otherwise degrade the function, use, or operation of such system. (Source: DoD Instruction 5200.44) In addition to risks posed by adversaries, other potential supply chain risks may also include parts obsolescence, diminishing manufacturing sources and material shortages (DMSMS), counterfeit parts, vanishing vendors, availability of trusted sources, unanticipated consequences of high velocity "just in time" supply chains, weather, strikes, economic factors, disruption or non-availability of key raw materials or critical sources, etc.

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  • Supply Chain Risk Management (SCRM) — A systematic process for managing supply chain risk by identifying susceptibilities, vulnerabilities and threats throughout DoD’s "supply chain" and developing mitigation strategies to combat those threats whether presented by the supplier, the supplied product and its subcomponents, or the supply chain (e.g., initial production, packaging, handling, storage, transport, mission operation, and disposal). (Source: DoD Instruction 5200.44)

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  • Third-Party Logistics Providers (3PL) — Providers of multiple logistics services. Some examples of logistics services are the management of transportation, demand forecasting, information management, inventory maintenance, warehousing, and distribution. (Source: Defense Federal Acquisition Regulation Supplement (DFARS) 247.301-70). The term 'third-party logistics provider' means a person who solely receives, holds, or otherwise transports a consumer product in the ordinary course of business but who does not take title to the product. (Source: 15 U.S.C. §2052)

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