Standardization of Clinger-Cohen Act Confirmation

DON CIO Memo - Publish Date: 10/31/14

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In an effort to standardize the content of Clinger-Cohen Act (CCA) Confirmation packages, and to simplify the CCA preparation effort for Program Managers, this memo was released to clarify what the standard CCA confirmation package should look like. It is specifically not desired that any documentation, not otherwise required for program acquisition management and oversight, be created solely to support CCA Confirmation. There are no changes with respect to CCA applicability, and this standardization policy applies to all Acquisition Category programs acquiring IT, as defined in the CCA.


Ref: (a) DODI 5000.2 Defense Acquisition 26 Nov 13
(b) SECNAVINST 5000.2e Department Of The Navy Implementation And Operation Of The Defense Acquisition System And The Joint Capabilities Integration And Development System 1 Sept 11
(c) PDUSD(AT&L) Memorandum Improving Milestone Process Effectiveness 23 Jun 11

Encl: (1) Clinger-Cohen Act Confirmation Process
(2) Clinger-Cohen Act Confirmation Package contents

Subtitle III of Title 40, U.S.C., commonly known as the Clinger-Cohen Act (CCA) established a structured approach to information technology (IT) capital investment evaluation and decision making. The legislation, implemented in references (a) and (b), applies to all programs that acquire IT, including National Security Systems, at any Acquisition Category (ACA T) level. A Milestone Decision Authority may not initiate a program or program increment, or approve entry into any acquisition phase that requires formal milestone approval; and a Component may not release a Request for Proposals or award a contract for an acquisition phase until:

a. The sponsoring Component or program manager has satisfied the applicable requirements of the CCA as shown in enclosure 1, table 9 of reference (a).
b. The Component Chief Information Officer (CIO), or authorized designee, confirms CCA compliance.

Per reference (b), ACA T I and II CCA confirmation packages are to be submitted to DON CIO and DASN (C41/10/Space). The purpose of this Memorandum is to reduce and streamline the requirements for processing CCA Confirmation Packages. Effective immediately, those packages are to include the following documentation:

1. A completed CCA confirmation table indicating which page(s) and paragraph(s) of cited documents support CCA compliance.
2. Electronic copies of, or access to electronic copies of, documents cited in the CCA confirmation table.

It is specifically not desired that any documentation, not otherwise necessary for program acquisition management and oversight, be created solely to support CCA confirmation. As provided in reference (c), "final draft" quality documents may be cited to support CCA confirmation if final approvals are in staffing. Further, in CCA packages submitted subsequent to a program's initial confirmation, elements that remain unchanged from a previous decision shall be so noted in the confirmation table (e.g., "unchanged from MS C") and no additional documentation provided.

CCA confirmation authority for ACAT Ill, IV, Abbreviated Acquisition and Urgent Need Programs remains delegated to Command Information Officers, as indicated in reference (b). This guidance on minimization of CCA confirmation packages also applies to those lower level programs.

The point of contact for this memorandum is Geoff Sheffer, who can be reached at or 703-695-2008.

Signed by:
John Zangardi, Acting