Why does my competitively awarded, Firm Fixed Price (FFP) contract for a commercial item have a CSDR requirement?

The word “cost” in “Cost and Software Data Reporting (CSDR) is the key part of this answer. Even though your contract with the United States Government (USG) includes a fixed price for the services performed or products delivered, your internal cost of providing that service or producing that item may vary from the contractual price. As Department of Defense (DoD) cost analysts prepare estimates for the next contract or program similar to yours, this information provides the DoD with the necessary insight to forecast an executable budget in support of the contract or program. Executable budgets, supported with granular cost data and sound analysis, allows the DoD to justify and secure resources within the overarching Federal budget. The CSDR requirement ensures that you, the vendor, will report the actual, internal cost incurred and not simply regurgitate the contract’s Fixed Firm Price.

Neither contract type (e.g., FFP, Cost Plus Fixed Fee (CPFF), etc.), commerciality determination (e.g., Commercial off the Shelf (COTS), MOTS), award procedures (e.g., sole-source, full and open competition), nor contract vehicle (e.g., Federal Acquisition Regulation (FAR Part 12, FAR Part 15, Other Transaction Authority (OTA)) justify a deviation from the requirement for CSDR reporting. 10 USC 3227 (formerly 2334(g)) and DoDI 5000.73 do not differentiate contract type when establishing cost data collection thresholds in statute and DoD policy. This assessment was fully vetted and endorsed by the Office of the Secretary of Defense’s Office of General Council and Acquisition and Sustainment senior leadership as well as the individual Service Acquisition Executives in preparation of the DoDI 5000.73. Further, while 10 USC 3227 states that these CSDR requirements may only be waived by the Director of Cost Assessment and Program Evaluation (DCAPE), DCAPE delegated this waiver authority to the Deputy Director, Cost Assessment (DDCA) in DoDI 5000.73.


I don’t have a Certified Accounting System (CAS), but I just signed a contract with CSDR requirements. Do I still need to provide CSDRs?

Yes. The DoD has successfully collected CSDR data from businesses with non-certified accounting systems. In fact, the DoD’s Cost and Hours Report (FlexFile) CSDR deliverable was developed and implemented primarily in acknowledgement of the substantial differences between contractor accounting systems, CAS or otherwise. The Defense Cost and Reporting Center (DCARC) and DoD cost community will work with your company to align your standard accounting system output to the FlexFile Data Item Description (DID) requirements.

While a CAS may be explicitly required by the FAR for cost type contracts, it is typically not a requirement for FFP contracts. In addition, contracts executed under OTA authority (10 USC 2371b) are not subject to the Federal Acquisition Regulation (FAR) and are unlikely to specify a CAS requirement. As a result, the DoD often awards contracts to small or non-traditional defense contractors without specifying that the contractor must possess a CAS. 10 USC 3227 and DoDI 5000.73 do not accommodate cost data collection exemptions based on CAS considerations. Moreover, DoDI 5000.73 specifies cost data collection requirements for non-FAR contracts (i.e., Other Transaction Agreements). As a result, contracts without CAS requirements that otherwise meet statutory and policy thresholds for cost data reporting must still include an approved CSDR plan and corresponding Contract Data Requirements List (CDRLs).


The contract that my company is currently negotiating with the USG includes a CSDR requirement. As long as the USG negotiators are okay with it, can I de-scope CSDR from the contract?

No.Program Managers, Program Executive Officers, the Senior Contracting Officer, and the Procurement/Agreement Officer are not authorized to waive, omit, or ignore CSDR data collection. This position was fully vetted and endorsed by the Office of the Secretary of Defense’s Office of General Council and Acquisition and Sustainment senior leadership as well as the individual Service Acquisition Executives. Per Section 3227 of Title 10, U.S.C. and DoDI 5000.73, CSDRs may only be waived by the Deputy Director of Cost Assessment and Program Evaluation (DDCA) within the Office of the Secretary of Defense. Removal of CSDR without DDCA approval abrogates statute while placing the program and contract’s future funding resources in jeopardy until CSDR is reinstated or legitimately waived by the DDCA.


I think the products my company is selling to the USG, under a contract with CSDR requirements, are commercial in nature and/or my contract is awarded under FAR Part 12. Do I have to submit CSDRs for my commercial products?

Unless the Deputy Director of Cost Assessment and Program Evaluation has waived the requirement, you must provide CSDR data as described in the contract’s CSDR plan. Commerciality – either by part number or for a contract in total – does not disqualify a contract from CSDR reporting. Although commerciality is often considered when reviewing waiver requests, it does not guarantee a waiver will be provided. Only the program manager for your contract can submit a waiver request to CAPE. OSD CAPE considers waiver requests on a case-by-case basis and will render a binding decision for the DoD. The waiver request includes a cover letter on Program Office letterhead with the rationale for the waiver, and a copy of the Commercial Item Determination (CID) signed by a Government contracting officer or by DCMA CID Group. For subcontracts, the waiver request and CID may be signed by the prime contractor’s Principal Contracting Officer.


If my contract has a Truth in Negotiation Act (TINA) waiver or otherwise has no requirement to provide TINA data, does this waiver extend and apply to the requirement for CSDR data as well?

No. CSDR data and TINA data are not the same thing and requirements for one are unrelated to requirements for the other. TINA data is related to information provided with a proposal, CSDR data is related to data collected during and at the end of contract execution).


Why did my contract receive a waiver for Earned Value Management (EVM) reporting, yet it still includes CSDR requirements?

Per Section 3227 of Title 10, U.S.C., the DDCA is the only authority that can waive CSDR requirements. The waiver authority for EVM is a separate authority depending on the program. Therefore, waivers for EVM do not waive CSDR requirements. Additionally, the purpose of EVM is a to measure contractors' cost and schedule during contract execution to ensure USG has oversight into the acquisition contract. EVM falls under the purview of the Office of the Undersecretary of Defense for Acquisition and Sustainment (OUSD (A&S)). Whereas CSDR is administered by Office of Cost Assessment and Program Evaluation (OSD CAPE) and is used to capture expenditure, technical, and programmatic data after contract execution. CSDR reporting is the primary data source utilized when completing cost and budget estimates. While OUSD (A&S) officials may have deemed an EVM waiver appropriate, this does not pre-suppose the decision to include or waive CSDR requirements. Although both systems rely on financial information and work breakdown structures, the resulting products from the EVM and CSDR systems are used by different DoD communities, are required at different frequencies, and are used for expressly different purposes.


I received a CSDR waiver for my last contract with the USG. Will my next contract also be exempt from CSDR?

No. CSDR waivers are granted on a case-by-case basis. Previous waiver decisions may be included as supporting information to the program manager’s waiver request to the DDCA; however, the DDCA reserves the right to not to grant a waiver request for a similar contract in the future, based on changes in conditions.


My company’s production processes and business systems don’t track costs at a serial number / vehicle level. Is there a way for me to comply with a “unit-level” cost reporting requirement?

Yes. The DoD cost community recognizes economic optimization drives contractor purchasing and production decisions. We are looking to collect CSDR data from weapon system contracts, not create CSDR data contracts that also produce weapon systems. In most cases, we’ve found that contractors execute purchase and/or work orders at a much smaller quantity than lot/option totals. In some cases, this quantity might be 1, but it’s more often the case that the quantity is some fraction of the overall quantity required by the delivery order or contract option. Providing direct labor and/or material at this lower “sub-lot” level is acceptable and even a desirable alternative to forcing serial number / vehicle level reporting, to the degree that the data matches your company’s production approach for the item being manufactured. Bottom line: USG wants data that resembles your company’s process for batching or grouping smaller quantities as it works toward meeting the overall quantity requirement. Although simply reporting/rolling up data to the whole contract lot/ delivery order/task order level is not an acceptable alternative to “unit-level” reporting, providing data at the “sub-lot” level likely is. Contractors should identify their proposed “sub-lot” reporting at or before the CSDR Readiness Review (previously Post Award Conference.). If your CSDR plan indicates unit/sublot reporting, ensure your system is set up in advance to accommodate the reporting requirement.


The DDCA disapproved the CSDR waiver request for my contract. Does this decision mean that waiver requests for my subcontractors, which qualify for CSDR requirements by virtue of the dollar amounts of the subcontracts, are also automatically denied?

No. The DDCA will separately consider CSDR waivers for qualifying subcontractors, irrespective of the decision rendered on a prime contractor’s waiver request. Requests for waivers for all contracts and subcontracts will be considered on a case-by-case basis.


I am a small business and this is my first time seeing the CSDR requirement, can the CSDR plan be tailored/modified since I am a small business?

All CSDR plans are tailored to the contractor's accounting system(s) and technical approach to accomplish the contractor's scope of work requirements, irrespective of the size of the contractor, experience with CSDR, or the type of contract (e.g., FAR, MTA). The review of the CSDR plan's requirement and potential tailoring occur at the CSDR Readiness Review. The CSDR Readiness Review should happen as early in the acquisition process as is practical and allowed by the contracting officer (preferably before contract award) in order to ensure accounting systems and the like are prepared to collect data as required.


How does the Cost Working Integrated Product Team (CWIPT) decide what requirements to include in an initial CSDR plan and which requirements can be tailored?

The CSDR process requires CWIPTs prepare initial CSDR plans before solicitations are released and before the CSDR Readiness Review can be held, therefore, initial CSDR plans in solicitations are unlikely to be tailored to a contract's accounting system(s) or technical approach to contract execution. CWIPTs prepare these initial CSDR plans to include the data collection requirements they believe are necessary to ensure CSDR deliverables will contain data needed to complete estimates & analysis and ensure DoD decision makers can make data-informed decisions. During the CSDR Readiness Review, the CWIPT and contractor may identify CSDR requirement modifications in order to tailor reporting to the contractor's accounting system and technical approach, thereby increasing the quality of data collected. Which requirements may be tailored cannot be known before the CSDR Readiness Review or before the CWIPT understands gains an understanding of the contractor's systems and processes.


My accounting system & technical approach does not collect any of the data required by the CSDR plan, does that mean the CSDR plan can be removed?

The goal of CSDR is to collect quality cost data and enable DoD to make data-driven decisions while not causing an undue burden to contractors, their accounting system(s), processes, or technical approach to execution. However, all contracts include minimally acceptable terms and conditions which must be met; the collection and reporting of CSDR is one such requirement. Generally, if a contractor can pay their employees, send and receive invoices from supplies, and pay taxes, they have an accounting system and processes mature enough to be compliant to CSDR requirements.


Page 2 (Reporting) of my contract’s approved CSDR plan (DD Form 2794) includes an “X” next to WBS elements with no actual scope under the contract. Should I report zero costs against those elements, or just not include them in my data submission?

If the Cost Working Integrated Product Team (CWIPT) decided to retain a WBS element without any scope under the contract, report $0 for that element if no funds were expended towards it. It’s likely due to a desire for uniformity or consistency between contracts and programs in the DoD’s CSDR database. In many cases, these elements, which may seem superfluous to your contract, are included to ensure the plan remains compliant with the current version of MIL-STD-881. In other cases, the superfluous elements might be included for consistency with previous contracts for the same item or an antecedent system. By keeping these elements, analysts are able to observe a “meaningful” zero, as the $0 cost submission is accompanied by a remark indicating no scope in the CSDR WBS dictionary entry. This outcome is preferred to an ambiguous lack of reporting against an otherwise standard cost element.


I have a CSDR plan (DD Form 2794) with an “optional requirement” on page 5 (Scope Def). Does that mean my company has the option to not submit the “optional requirement” data?

No. The term “optional” on page 5 refers to the ability of the USG CWIPT to exercise discretion in adding the associated requirements. By exercising the option to include, say, unit-level reporting on the CSDR plan, the CWIPT has introduced unit-level reporting as a contractual requirement via the approved CSDR plan.


What happens if my company is unable to comply with the exact dates on Page 3 (Events) of the DD2794 associated with my contract?

Approval of submission date changes is within the purview of the program office and DCARC. The CWIPT will want to understand your desired submission event dates and how they align with your accounting calendar, equipment delivery dates and contract close out dates; changes to these dates are based on programmatic and schedule changes. Requests for submission date extensions submitted after the due date are not permitted.


I understand that CSDR reporting wants “cost” (not “price”) data, but my data is proprietary and we are very hesitant to release it. How can I rely upon you to protect my proprietary data from my competitors?

CSDR data is marked and protected as “contractor proprietary” data and meets DoD IL-5 classification as “Controlled Unclassified Information”. The data is tightly controlled, with only access granted to individuals that meet a rigorous vetting process to ensure control of the data, nor is it releasable under FOIA requests. CSDR data is encrypted both in transit and at rest and stored within the CADE database. In addition, there is a recurring process to ensure the CADE system retains its protection of contractor data. During these reviews CADE is often quoted as having the “platinum standard” for data integrity.


I have a contractual requirement to flow down CSDR to several of my subcontractors, who are resistant to the idea that my company (the prime contractor) will see their proprietary information as part of CSDR. How do I put their minds at ease?

Your subs will be treated as “Direct Reporting Subcontractors” for the purposes of this contract, and are required to submit directly to CADE, not the Prime Contractor. You, the prime contractor, will not receive the subcontractor’s data deliverables. Your subs will have the opportunity to conduct separate CSDR Readiness Reviews (formerly Post Award Conferences) with the CWIPT, and most importantly, they will submit all CSDR deliverables directly to OSD’s CADE database (not to you, the prime contractor).


I noticed my contract includes CSDR requirements but my contract is not associated with an ACAT I/II program. CSDR requirements therefore should be removed from my contract, correct?

The current reporting requirements are designated in DoDI 5000.73 and essentially follow a two-part process. First, the CWIPT determines if the total acquisition program funding is greater than $100M. This is regardless of the program acquisition pathway. If the acquisition program funding is greater than $100M and any of the reporting thresholds for CSDR requirements are met in Table 1, then CSDR requirements should be levied.


Why does the competitively awarded, Firm Fixed Price (FFP) contract for a commercial item that I’m soliciting have a CSDR requirement?

The word “cost” in “Cost and Software Data Reporting (CSDR) is the key part of this answer. Even though the contract with the United States Government (USG) includes a fixed price for the services performed or products delivered, the contractor’s internal cost of providing that service or producing that item will vary from the contractual price. As Department of Defense (DoD) cost analysts prepare estimates for the next contract or program similar to yours, this information provides the DoD with the necessary insight to forecast an executable budget in support of the contract or program. Executable budgets, supported with granular cost & hours data, combined with sound analysis, allow the DoD to justify and secure resources within the overarching Federal budget. The CSDR requirement ensures that the vendor will report the actual, internal cost & hours incurred and not simply regurgitate the contract’s Firm Fixed Price.

Neither contract type (e.g., FFP, Cost Plus Fixed Fee (CPFF)), commerciality determination (e.g., Commercial off the Shelf (COTS), MOTS), award procedures (e.g., sole-source, full and open competition), nor contract vehicle (e.g., FAR Part 12, FAR Part 15, Other Transaction Authority (OTA)) justify a deviation from the requirement for CSDR reporting. 10 USC 3227 (formerly 2334(g)) and DoDI 5000.73 do not differentiate contract type when establishing cost data collection thresholds in statute and DoD policy. This assessment was fully vetted and endorsed by the Office of the Secretary of Defense’s Office of General Council and Acquisition and Sustainment senior leadership, as well as the individual Service Acquisition Executives, in preparation of DoDI 5000.73. Further, while 10 USC 3227 states that these CSDR requirements may only be waived by the Director of Cost Assessment and Program Evaluation (DCAPE), DCAPE delegated this waiver authority to the Deputy Director, Cost Assessment (DDCA) in DoDI 5000.73.


The contract that I’m negotiating with industry includes a CSDR requirement, but I’m not sure that I need or want CSDR data. Can I de-scope CSDR from the contract or change the approved CSDR plan as a negotiating tactic?

No. Program Managers, Program Executive Officers, the Senior Contracting Officer, and the Procurement/Agreement Officer are not authorized to waive, omit, or ignore CSDR data collection. This position was fully vetted and endorsed by the Office of the Secretary of Defense’s Office of General Council and Acquisition and Sustainment senior leadership as well as the individual Service Acquisition Executives. Per Section 3227 of Title 10, U.S.C. and DoDI 5000.73, CSDRs may only be waived by the Deputy Director of Cost Assessment and Program Evaluation (DDCA) within the Office of the Secretary of Defense. Removal of CSDR without DDCA approval abrogates statute while placing the program and contract’s future funding resources in jeopardy until CSDR is reinstated or legitimately waived by the DDCA.


I think the products or services I’m acquiring are commercial in nature and/or the contract will be awarded under FAR Part 12. Do I need to include an approved CSDR plan for my contract?

Yes. If the Deputy Director, Cost Assessment (DDCA) of CAPE has not provided a waiver for the contract in question, you must include an approved CSDR plan and corresponding CDRLs as contractual requirements. If you believe the commercial nature of the product warrants official consideration for CSDR purposes, you (program manager) may submit a waiver request to the DDCA. This waiver request must be accompanied by a Commercial Item Determination from one of two sources: 1) DCMA CID Group, or 2) Government Principal Contracting Officer. The DDCA considers waiver requests on a case-by-case basis and will render a binding decision for the DoD. An approved CSDR plan must be included within the solicitation, while awaiting the waiver decision. If the CSDR waiver is approved, the CSDR plan may be removed from the solicitation.


I submitted and received a CSDR waiver for the last contract my program awarded to industry. Will the next contract awarded under my program also be exempt from CSDR?

No. CSDR waivers are granted on a per-contract/delivery order/task order basis. Previous waiver decisions may be included as supporting information to the program manager’s waiver request to the DDCA; however, the DDCA reserves the right to disapprove a waiver request for a similar contract in the future, based on changes in conditions.


The vendor that just received a contract award from my office wants to report “price” (not “cost”) data in their CSDR deliverables. Is this allowed?

Reporting of only “price” data in CSDR is not allowed and offers no additional value beyond price information already included in other contract documentation. The Data Item Descriptions (DIDs) associated with CSDR deliverables specify that submissions are not limited only to price: “All contract costs accrued by the reporting entity, and the effect on the reporting entity’s profit, shall be reported even if these costs exceed the contract price” (via DI-FNCL-82162).


My vendor is concerned that they are being asked to provide proprietary cost data for CSDR. How can I assuage their concerns about their extremely proprietary cost data being made public or shared with their competitors?

CSDR data is marked and protected as “contractor proprietary” data and meets DoD IL-4 classification as “Controlled Unclassified Information”. The data is tightly controlled, with only access granted to individuals that have completed a rigorous vetting process to ensure control of the data, nor is it releasable under FOIA requests. CSDR data is encrypted both in transit and at rest, stored within the CADE database. In addition, there is a recurring process to ensure the CADE system retains its protection of contractor data. During these reviews CADE is often quoted as having the “platinum standard” for data integrity.


The contract I’m preparing is greater than $50 million, but it is in support of a former ACAT I program that has been in sustainment for at least 10 years. Do I need to include an approved CSDR plan in my Request for Proposals if this contract isn’t an ACAT I program?

Yes. The designation of ACAT I is given to weapon system programs (e.g., Abrams, Bradley, F18, V-22), based on total anticipated development and procurement costs. Once this designation occurs, the ACAT level of the program may be reduced if lifetime acquisition costs decrease for programmatic reasons, but otherwise the program maintains this designation indefinitely. Individual contracts are not ACAT I programs. Individual contracts/agreements/MIPRs are utilized to support one or more programs. If the contract is procuring parts or services that could or will be utilized by an ACAT I program, then CSDR policy for ACAT I programs applies to the contract/agreement/MIPR per Table 1 of DoDI 5000.73.


If my program decreases from ACAT I to ACAT II, do I need to include CSDR requirements on future contracts?

Yes. CSDR data is required even if a program’s ACAT has been downgraded, so long as the contract value is over $50 million (or $20 million if MTA) and the total acquisition expenditure for the program is anticipated to exceed $100 million. See Table 1 of DoDI 5000.73 and 10 USC 3227 for policy and statutory cost reporting thresholds, respectively.


What is the value of CSDRs to my program?

CSDRs provide valuable insight into both Prime and Subcontractor profit, recurring vs. nonrecurring costs, software development efforts, and detailed insight into contractor functional categories. The data can be used by PMs to inform contract negotiations on future lots or delivery orders, provide additional insight into engineering and manufacturing at the product level of the WBS, and support lifecycle program decisions, such as acquisition or contracting strategies. Additionally, the CSDR data collected on programs today enable cost estimating and analysis efforts for future programs. The historical collection of actual cost and software data in CADE is invaluable to the cost community, as it provides the basis for reliable cost estimates and accurate budgets. Many companies have a long history of providing cost reporting in accordance with CSDR plans, including smaller businesses. These requirements can easily be incorporated into your Program’s budget to aid the cost community, as well as assist your program with contract execution analysis.


Resources in my program are tight, and I think industry is going to charge me way more than I want to pay for CSDRs. If I don’t include CSDRs on my contract, what are the consequences?

If your acquisition program surpasses $100M, 10 USC 3227 requires you to collect cost data on your program in accordance with the policies, procedures, guidance, and collection method developed by OSD-CAPE. These policies, procedures, guidance, and collection methods are described in DoDI 5000.73 and DoDM 5000.04. In addition, DFARS 252.234–7003 and 252.232–7004 require that the CSDR plan be included within the solicitation and on the awarded contract. If your acquisition program surpasses $100M and you elect not to include CSDRs on a contract for your program, you are in violation of Title 10, DFARS, and DoDI 5000.73. Furthermore, if your program is required to submit DAES reports, the Defense Cost and Resource Center (DCARC) will provide a CSDR compliance rating for your program to OUSD (A&S), based solely on your contractor’s adherence to any approved CSDR plans assigned to your program. If a program consistently receives a “Red Critical” DAES rating, as a result of severe violation of CSDR policy, there is a risk that OSD CAPE will delay the milestone decision in order to obtain the data it needs to conduct its statutory independent cost estimate.


I have a long term, sole source vendor for a mission critical subsystem. What do I do if my sole source vendor takes exception to CSDR on the grounds that “they’ve never done it before?

CSDR policy has changed significantly over the past 5 years, to include extension of CSDR requirements to sub-ACAT 1 level programs, sustainment contracts for fielded ACAT programs, new acquisition pathways (e.g., Middle Tier of Acquisition), and government performed efforts (e.g., DoD depots performing in Public-Private Partnerships). As a result of these changes, many DoD contractors are receiving CSDR requirements for the first time, even in situations with long-standing contractual relationships with a single vendor. If the vendor takes exception to CSDR, you can contact the DCARC and/or OSD CAPE for assistance with communication of the statutory and policy justification of the requirement in question. CAPE has extensive experience in assisting contractors with navigation of the CSDR process for the first time and can work to address and/or alleviate any practical concerns and provides training as requested for a specific program and on a recurring basis for the general audience.


If I’m executing a contract under “Other Transaction Authority” via 10 USC 2371b, is the contract subject to CSDR policy?

Yes. OTA actions are subject to CSDR policy per Section 3227 (formerly 2334(g)) of Title 10, U.S.C. and Table 1 of DoDI 5000.73 (see non-FAR agreements). The agreements officer for the OTA contract is not authorized to waive, omit, or ignore CSDR requirements. Furthermore, if the OTA is part of a program with a declared acquisition pathway (e.g., Major Capability Acquisition or Middle Tier of Acquisition), the OTA assumes the CSDR policy associated with that pathway. Page 5 of the OUSD (A&S) OTA guide states, “any program executed under the DoDI 5000.02 pathway is subject to DoDI 5000.02 policy once this pathway is selected, regardless of whether an OT or traditional contract is used. Similarly, any program executed under the Middle Tier of Acquisition (MTA) pathway, in accordance with Section 804 of the National Defense Authorization Act for Fiscal Year 2016, is subject to MTA policy.” When defining the program, the PM should include all parts of the program to generate an accurate reflection of the overall scope. Subdividing the program into increments and releases does not mean these efforts can be excluded from determining the overall program cost.


I made sure an approved CSDR plan, SOW language, and associated CDRLs were all included in my contract. I also made sure that my prime contractor flowed down to subcontractors appropriately. What other responsibilities do I have?

In accordance with DoDM 5000.04, your CSDR-related responsibilities have just begun but the hardest part is over! The PMO is responsible (in conjunction with the PCO) for ensuring that the contractor complies with all contractual provisions related to CSDR and promptly resolves any reporting deficiencies identified during the validation process. The PMO, as part of the Cost Working Integrated Product Team (CWIPT), is also responsible for assisting with the review of the cost reports submitted to the CADE system in accordance with the CDRLs on the contract and identifying any necessary plan revisions during contract execution. The PMO should provide comments to the DCARC as part of the submission validation process. The CWIPT is composed of team members from CAPE (whose participation is required for programs that exceed the reporting threshold), the Service Cost Agency (SCA), the PMO, the DCARC, and other organizations, as needed and recommended by the CAPE, the SCA, and the PMO.

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