Policy vs. Guidance (Revised 10/2007)

The Acquisition Management System (AMS) is the collective body of information within the FAA Acquisition System Toolset (FAST). FAST is the official record of the AMS, which consists of "acquisition management policy" and "acquisition management guidance."

1. Definitions of AMS Policy and Guidance

Acquisition Management Policy. Agency-wide, mandatory requirements of the AMS, applicable to all activities associated with the analysis of agency needs for products, services, and facilities, determination of requirements, analysis of investment alternatives, establishment of investment programs, allocation and expenditure of resources, procurement, deployment of products and services, in-service management of fielded capabilities, and eventual disposal of obsolete assets. Acquisition management policy applies to all investment programs of any cost and any appropriation, including programs managed at headquarters, regions, centers, and other field activities. The Administrator approves acquisition management policy. Only the FAA Acquisition Executive may approve waivers or deviations from policy.

Acquisition Management Guidance. A set of agency-endorsed guidelines, processes, instructions, templates, databases, handbooks, checklists, and other information that supplements, expands, illustrates or implements acquisition management policy. This information guides and supports the workforce in planning and executing acquisition management policy and all related lifecycle management and functional discipline activities and processes. Acquisition management guidance is derived from acquisition management policy and should be followed unless there is rational basis for adopting a different approach. The Director of Acquisition Policy and Contracting approves all guidance. All guidance is officially sanctioned and approved using the same formal AMS change management process as for policy.

2. Core Terminology 

AMS policy and guidance is mainly written using straight-forward declarative sentences. Practitioners shall comply with AMS policy as written unless waivers or deviations are obtained from the FAA Acquisition Executive.

Practitioners are expected to comply with AMS guidance as written unless a rational basis exists for alternative action. The rational basis shall be recorded in official program planning documentation (e.g., Exhibit 300 and Implementation Strategy and Planning attachment) and approved by the appropriate officials.

Examples of rational basis include factual statements showing that:

  • A deviation from the guidance will clearly enhance one or more factors of cost, schedule, requirements, or benefits.
  • Congressional direction requires adopting a different approach.
  • Circumstances of the program clearly show that deviations from guidance are required.
  • In certain circumstances, due to the nature of the rational basis, a team may determine that a responsible official shall document the rationale for deviating from AMS guidance. Such documentation shall be filed in the official program record.

    The following terms, when used throughout AMS, shall be interpreted as follows:

    Shall, Must, and Mandatory. The terms "shall," "must," and "mandatory" indicate requirements where it is necessary to comply. Waivers are required from the FAA Acquisition Executive in advance if there is intent to not abide by the requirements.

    Should. The term "should" indicates requirements or procedures that allow discretion to adopt different approaches consistent with applicable law and AMS policy. Acquisition personnel are expected to use principles of reasoned decision making and to document, to an appropriate extent, the rational basis for adopting a different approach.

    May. The term "may" confers authority to exercise full discretion by the user in implementing the applicable part of AMS where the term is used.

    3. Identifying and Policy versus Guidance

    Within FAST, policy and guidance is labeled at the top of every screen with either the word "policy" or "guidance," to help the user identify which category of information is being accessed.

    The policy is accessed from the FAST home page, under the major heading "AMS Policy."

    Unless specifically and clearly marked as "policy," all information displayed in FAST is officially designated as guidance.