Contract Administration

Especially in capital-intensive industries like construction, dispute resolution is a core element of contract and procurement management. With arbitration being the main adjudicatory mechanism, Nepal law incorporates a systematic mechanism for dispute resolution. The entire process of claim and dispute management, from prevention and mitigation to formal resolution, has been detailed in this paper. It compares adjudicative and consensual solution approaches and delineates the procedural mechanisms provided under local legislation and the related regulations. The study examines the core reasons for disputes, especially in the construction sector, and identifies system factors in the Nepalese setting, viz., judicial interference, delay in enforcement, and institutional arbitration capacity limitations. Based on statutory practice and law, the study concludes that though there is a strong legal

Nepal's chronic infrastructure deficit, characterized by delays, cost overruns, and poor quality, remains a primary barrier to achieving its Sustainable Development Goals (SDGs). This paper identifies the root cause as a procurement system that seriously emphasizes the lowest initial bid, entirely overlooking long-term lifecycle value. In employing a comparative study of best international practices and a critical examination of Nepal's procurement system, this study directs the attention to the revolutionary capability of Value Engineering (VE). By comparative examination of the Public Procurement Act (PPA), Standard Bidding Documents (SBDs), and FIDIC contracts, the research proposes realistic, law-oriented reforms for VE mainstreaming. Empirical case information, lifecycle cost analysis, and estimated national savings (more than NPR 100 billion annually) prove the viability of VE. Evidence points out

To provide guidance on integrating software architecture analysis and evaluation in DoD and Government system acquisitions. This presentation contains both implicit and explicit guidance. We will use this icon to indicate when we are giving explicit guidance. The guidance is based on real experience and a series of technical notes and reports that were developed by the Business and Acquisition Guidelines (BAG) group of the Product Line Systems Program at the SEI. (See References.

The RAND Corporation is a nonprofit institution that helps improve policy and decisionmaking through research and analysis. RAND's publications do not necessarily reflect the opinions of its research clients and sponsors. R ® is a registered trademark.

Forecasting Total Quality Management (TQM) performance in hospitality remains underdeveloped despite its strategic role in pricing, staffing, and service quality. Existing approaches, dominated by univariate and deterministic models such as ARIMA, struggle to capture the volatility and interdependencies that define hotel operations. This study addresses this gap by employing a simulation-based framework to evaluate the Bayesian Autoregressive Moving Average (BARMA) and Vector Autoregression (VAR) models using three core TQM indicators-defect rates, quality costs, and customer satisfaction. The objectives were to (i) demonstrate the methodological integration of BARMA and VAR, (ii) compare their predictive and interpretive capacities, and (iii) generate actionable managerial insights for quality management under uncertainty. Using simulated monthly time-series data calibrated to industry benchmarks, BARMA (1,1) consistently outperformed VAR in predictive accuracy. For example, BARMA reduced RMSE for defect rates (0.37 vs. 0.39) and delivered lower MAPE for customer satisfaction (1.08% vs. 1.11%). In contrast, VAR revealed statistically significant causal pathways, such as defect rates predicting quality costs (β = 0.38, p < 0.05), and customer satisfaction feeding back into reduced defects (β =-0.22, p < 0.05). These findings highlight methodological complementarity: BARMA as a robust predictor for short-term operational planning, and VAR as a diagnostic tool for tracing structural feedback loops. The study contributes to forecasting research by showing how integrating Bayesian and multivariate approaches, even within a simulated environment, can overcome the limitations of linear, univariate models. For practitioners, the results emphasise the need to balance predictive accuracy with structural diagnosis when managing quality costs and customer outcomes in luxury hotel operations.

Public reporting burden for this collection of information is estimated to average 1 hour per response, including the time for reviewing instruction, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to Washington headquarters Services, Directorate for Information Operations and Reports,

where he teaches defense acquisition courses. He served for over twenty years as a contracting officer in the USAF, retiring at the rank of lieutenant colonel. His career included assignments as a contracting officer for the Peacekeeper ICBM, Maverick Missile, and the F-22 Raptor. He was also the director of contracting for the Space Based Infrared satellite program and the Evolved Expendable Launch Vehicle rocket program. Rendon has

translation, reprinting, reuse of illustrations, recitation, broadcasting, reproduction on microfilms or in any other physical way, and transmission or information storage and retrieval, electronic adaptation, computer software, or by similar or dissimilar methodology now known or hereafter developed. The use of general descriptive names, registered names, trademarks, service marks, etc. in this publication does not imply, even in the absence of a specific statement, that such names are exempt from the relevant protective laws and regulations and therefore free for general use. The publisher, the authors and the editors are safe to assume that the advice and information in this book are believed to be true and accurate at the date of publication. Neither the publisher nor the authors or the editors give a warranty, express or implied, with respect to the material contained herein or for any errors or omissions that may have been made.

translation, reprinting, reuse of illustrations, recitation, broadcasting, reproduction on microfilms or in any other physical way, and transmission or information storage and retrieval, electronic adaptation, computer software, or by similar or dissimilar methodology now known or hereafter developed. The use of general descriptive names, registered names, trademarks, service marks, etc. in this publication does not imply, even in the absence of a specific statement, that such names are exempt from the relevant protective laws and regulations and therefore free for general use. The publisher, the authors and the editors are safe to assume that the advice and information in this book are believed to be true and accurate at the date of publication. Neither the publisher nor the authors or the editors give a warranty, express or implied, with respect to the material contained herein or for any errors or omissions that may have been made.

translation, reprinting, reuse of illustrations, recitation, broadcasting, reproduction on microfilms or in any other physical way, and transmission or information storage and retrieval, electronic adaptation, computer software, or by similar or dissimilar methodology now known or hereafter developed. The use of general descriptive names, registered names, trademarks, service marks, etc. in this publication does not imply, even in the absence of a specific statement, that such names are exempt from the relevant protective laws and regulations and therefore free for general use. The publisher, the authors and the editors are safe to assume that the advice and information in this book are believed to be true and accurate at the date of publication. Neither the publisher nor the authors or the editors give a warranty, express or implied, with respect to the material contained herein or for any errors or omissions that may have been made.

The sourcing decisions of contract bidding in a Military organization is complex to manage largely due to the increasing complexity of products requirements, multiple suppliers, and the nature of Air Force Hardware and Software installations pricing structures. This paper presents a set-covering model (formulation) that allows the user to select the most economical bid among offerors (contractors) that meet all the critical product requirements while minimizing the total cost. The optimization process is carried out in two phases. The first phase deals with the construction of a biddable combination matrix by mapping out the critical product requirements against the offerors' (contractors) specifications. In the second phase, the model makes an optimal assignment of offerors to each feasible or contracting product by utilizing economies of scales offered by credible offerors volumes. This gives an optimization model for selecting the set of bid among multiple offerors' proposals for installation services. The selection achieves the most favorable objective based on balancing the confidence performance level in past performance of the offerors and the cost to the Air Force. The research findings based on a realistic scenario demonstrate improvements in both overall performance and cost than the status quo.

The sourcing decisions of contract bidding in a Military organization is complex to manage largely due to the increasing complexity of products requirements, multiple suppliers, and the nature of Air Force Hardware and Software installations pricing structures. This paper presents a set-covering model (formulation) that allows the user to select the most economical bid among offerors (contractors) that meet all the critical product requirements while minimizing the total cost. The optimization process is carried out in two phases. The first phase deals with the construction of a biddable combination matrix by mapping out the critical product requirements against the offerors' (contractors) specifications. In the second phase, the model makes an optimal assignment of offerors to each feasible or contracting product by utilizing economies of scales offered by credible offerors volumes. This gives an optimization model for selecting the set of bid among multiple offerors' proposals for installation services. The selection achieves the most favorable objective based on balancing the confidence performance level in past performance of the offerors and the cost to the Air Force. The research findings based on a realistic scenario demonstrate improvements in both overall performance and cost than the status quo.

The sourcing decisions of contract bidding in a Military organization is complex to manage largely due to the increasing complexity of products requirements, multiple suppliers, and the nature of Air Force Hardware and Software installations pricing structures. This paper presents a set-covering model (formulation) that allows the user to select the most economical bid among offerors (contractors) that meet all the critical product requirements while minimizing the total cost. The optimization process is carried out in two phases. The first phase deals with the construction of a biddable combination matrix by mapping out the critical product requirements against the offerors' (contractors) specifications. In the second phase, the model makes an optimal assignment of offerors to each feasible or contracting product by utilizing economies of scales offered by credible offerors volumes. This gives an optimization model for selecting the set of bid among multiple offerors' proposals for installation services. The selection achieves the most favorable objective based on balancing the confidence performance level in past performance of the offerors and the cost to the Air Force. The research findings based on a realistic scenario demonstrate improvements in both overall performance and cost than the status quo.

Il mercato dei contratti pubblici rappresenta un settore chiave per l’economia italiana. Oltre a influenzare sviluppo territoriale, occupazione e innovazione, il public procurement è oggi uno strumento fondamentale per promuovere la sostenibilità ambientale e sociale, in linea con le direttive europee e l’Agenda 2030. In questo contesto, le società benefit, introdotte con la legge n. 208/2015, rappresentano un modello d’impresa innovativo che integra la ricerca del profitto con finalità di impatto sociale e ambientale. Tuttavia, il nuovo Codice dei contratti pubblici (d.lgs. n. 36/2023) non menziona espressamente queste imprese né inserisce il principio dello sviluppo
sostenibile tra i principi fondamentali della materia. Sebbene il Codice preveda criteri di premialità per gli operatori economici sostenibili, lascia ampia discrezionalità alle stazioni appaltanti nell’adozione di tali misure, con il rischio di un’applicazione frammentata e poco incisiva. Dal punto di vista del diritto dell’economia, l’evoluzione del public procurement riflette un più ampio processo di regolazione economica, che mira a conciliare efficienza di mercato e obiettivi di interesse generale. L’integrazione della sostenibilità e della responsabilità sociale nel sistema degli appalti pubblici rappresenta un passaggio cruciale verso un modello normativo che non si limiti alla concorrenza, ma promuova una crescita equa e duratura. Per garantire un’effettiva integrazione delle società benefit nel sistema dei contratti pubblici, sarebbe necessario un quadro normativo più chiaro e vincolante, capace di trasformare il procurement pubblico in un vero strumento di innovazione e sviluppo sostenibile, in linea con l’evoluzione del diritto dell’economia e delle politiche di governance pubblica.

Use of any trademarks in this report is not intended in any way to infringe on the rights of the trademark holder. Internal use. Permission to reproduce this document and to prepare derivative works from this document for internal use is granted, provided the copyright and "No Warranty" statements are included with all reproductions and derivative works.

This study is designed to support one of three major focus areas in the Naval Supply Systems Command (NAVSUP) Worldwide Husbanding Improvement Process initiative. Existing contracting methodologies were analyzed using the following methods: characteristics of existing contract vehicles within forecasting and simulation frameworks; strengths, weaknesses, opportunities, threats (SWOT) analysis, and stakeholder analysis. Conclusions are drawn and recommendations are outlined for optimum methods of contracting for husbanding services as requested by the Worldwide Husbanding Process Improvement Action Team. Historical husbanding contract data were reviewed, including constraints and desired performance criteria. Implementation of a flat-rate, low-variability, well-defined and constant set of requirements minimizes risk and price fluctuations. Conversely, adoption of a cost-reimbursable contract type is both undesirable and infeasible. A contracting methodology that represents a best-value trade-off within constraints should be flexible and risk-based while offering performance-based incentives.

Public reporting burden for the collection of information is estimated to average 1 hour per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to Washington Headquarters Services, Directorate for Information Operations and Reports, 1215 Jefferson Davis Highway, Suite 1204, Arlington VA 22202-4302. Respondents should be aware that notwithstanding any other provision of law, no person shall be subject to a penalty for failing to comply with a collection of information if it does not display a currently valid OMB control number.

Public reporting burden for the collection of information is estimated to average 1 hour per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to Washington Headquarters Services, Directorate for Information Operations and Reports, 1215 Jefferson Davis Highway, Suite 1204, Arlington VA 22202-4302. Respondents should be aware that notwithstanding any other provision of law, no person shall be subject to a penalty for failing to comply with a collection of information if it does not display a currently valid OMB control number.

Considering that Portugal is currently suffering one of the most severe financial crisis in its history, this paper examines to what extent PPPs have contributed to Portugal's external debt problems and evaluates how Portugal's PPP contracts can be managed in order to contribute to the necessary solution. Although the interests of the various PPP Stakeholders are acknowledged, the focus is on the Government as the public partner, from a sovereign risk and taxpayer perspective. The paper shows how countries like Portugal with large PPP programmes but fragmented PPP institutions and and inadequate budget practices can be exposed to greater fiscal risks, leading to the accumulation of PPP liabilities which later contribute to public sovereign debt problems.

In Nigeria, taxation serves as a mandatory financial instrument for national interests, wealth redistribution, and economic stability. This study investigates the impact of tax adjustments on mitigating economic crises in the construction sector from 2020 to 2024. The research examines project viability, job creation, and continuity, evaluating amendable levy arrangements, identifying profitable financial approaches, and discussing challenges in implementing these strategies to enhance sectoral resilience. The study employs thematic analysis, comparative regional policy evaluation, and case studies to highlight issues such as construction costs, investment trends, government revenue fluctuations, project viability, employment, compliance, and macroeconomic effects. Tax revenues in the construction industry steadily increased from ₦10 billion in 2020 to a peak of over ₦50 billion in 2023, driven by aggressive tax adjustments, improved compliance, and economic recovery. A slight decline to ₦42.5 billion in 2024 suggests the introduction of tax relief measures or reduced construction activity. The construction indicator showed consistent improvement, reaching baseline efficiency (100%) in 2024, reflecting recovery from inefficiencies observed in 2020 (123%) and 2021 (118%). Nigeria's GDP growth fluctuated, with a significant contraction in 2021 (-1.79%) during the post-pandemic recovery, followed by stabilization at 2.86% in 2024. Inflation rates, however, rose steadily, from 11.40% in 2020 to 24.66% in 2024, imposing macroeconomic challenges. Key reforms, such as the 2020 Finance Act, which increased VAT to 7.5%, contributed significantly to higher revenues, with VAT collection peaking at 45.02% in 2023 before stabilizing at 19.10% in 2024. These findings underline the necessity of balanced tax policies to sustain economic stability, emphasizing their role in mitigating crises and ensuring the viability of construction projects. The insights aim to guide Quantity Surveyors in incorporating tax adjustments into cost estimates, enabling adaptive strategies during economic downturns while fostering sectoral and national resilience.

As the U.S. Air Force (USAF) considers privatizing unaccompanied housing at bases facing high rental costs or geographic isolation, the lessons learned from previous military housing privatization efforts must guide decision-making. While privatized family housing has improved housing conditions and infrastructure investment, it has also suffered from inconsistent oversight, contractor accountability issues, and tenant dissatisfaction. The Air Force must carefully structure its oversight mechanisms to avoid repeating past mistakes.

The United States Air Force (USAF) faces escalating challenges in housing privatization, particularly in ensuring cost-effective, high-quality accommodations that cater to the needs of Airmen and their families. Traditional methods of bid evaluation, proposal assessment, and project cost estimation often suffer from being manual, inconsistent, and disconnected from actual housing market conditions. Furthermore, Basic Allowance for Housing (BAH) rates frequently fail to mirror genuine housing costs, resulting in affordability gaps and dissatisfaction among service members. This paper argues that leveraging Artificial Intelligence (AI) and Machine Learning (ML) in USAF housing privatization can revolutionize the process by
enhancing efficiency, sustainability, and fairness.

Abstract: The System Software Safety Technical Review Panel (SSSTRP) is tasked with reviewing the software safety processes and practices of US Navy software-intensive Gun System acquisition programs from the early stages of the acquisition process. As these ...

This essay is a valid legal argument-style essay advocating for the benefits and opportunities to transition government contracting regulations from Earned Value Management (EVM)-based performance incentive fees to a product-focused incentive concept. This essay integrates legal reasoning grounded in the Federal Acquisition Regulation (FAR), Defense Federal Acquisition Regulation Supplement (DFARS), and other statutory authorities, while addressing foreseeable counterarguments and offering a compelling case for reform. The argument is structured to persuade policymakers, contracting officers, and stakeholders of the merits aligned with this concept. This is not a scientific research project but rather a legal business case argument advancing modernization of robust inefficient government systems.

Proceedings Paper (for Acquisition Research Program)Acquisition policy and, even more so, acquisition practice today presumes that certainty is key to success, and that uncertainty or delays in achieving certainty regarding user needs or solution approach will necessarily impede progress. This means that when uncertainty arises during an acquisition effort, the natural response is to make decisions that resolve this uncertainty. Uncertainties arise for various reasons, such as poorly understood, conflicting, or changing needs. If, under pressure to maintain progress, an acquisition effort makes decisions to resolve these uncertainties without sufficient information, expertise, or deliberation, they are really only creating an illusion of certainty; in a practical sense, the uncertainty still exists. This artificial certainty then leads to flaws such as insufficient detail concerning specific needs or premature limiting of solution options. A new approach to acquisition is needed tha...

Qëllimi i këtij punimi është të trajtojë disa çështje që lidhen me kontratat e prokurimit publik; Lidhja me procesin e prokurimit, Trajtimi i kontratës së prokurimit publik si kontratë administrative; Kuptimi/tiparet e kontratës administrative; Dallimi i kontratës administrative nga kontrata civile; Kompetenca lëndore e gjykatës për shqyrtimin e mosmarrëveshjeve që lidhen me kontratat administrative;

The construction industry has had a history of nonperformance in the delivery of services [in terms of being on time and on budget]. Other industries such as IT and professional services have also experienced nonperformance. The problem seems complex, as there are many participants who are involved in the project nonperformance including the owner, the buyer, the vendor, sub vendors, manufacturers, and project managers. An industry structure analysis proposes that the problem is caused by parties managing, directing, and controlling (MDC) another party. This could happen anywhere in the supply chain. This paper proposes that a major source of the nonperformance in projects is caused by project managers who are managing the projects from the different supply chain participants including the owner, the designer, the vendors, and procurement. This has been identified in numerous project tests where the objective of the test was to minimize the MDC in the projects and the major difficulty was the resistance from project managers. The paper also proposes that the project managers are educated to manage, direct, and control in their education and training including their professional certifications from the Project Management Institute (PMI) and the International Project Management Association (IPMA).

As governments the world over move to reduce global warming, public procurement has become an increasingly important means of leveraging governments’ vast purchasing power to reduce greenhouse gas (GHG) emissions through “green” or environmentally sustainable procurement. This article reviews emerging strategies in green procurement in the European Union and the United States. The article notes that those green procurement strategies are remarkably consistent on both sides of the Atlantic, from sector-specific preferences for low-carbon products to eco-labels to life-cycle cost analyses which take into account broader environmental impacts. On both sides of the Atlantic, however, parallel problems have emerged as well. While initial efforts have been made to force firms to chronicle their products’ and services’ GHG emissions so that those emissions can be assessed (including in awarding contracts), those efforts have faltered politically in both the United States and the European Union because of the high costs of implementation. These initial results from both continents suggest that while green procurement can evolve in parallel around the world, using common strategies and devices, the costs of implementation — until now, a largely overlooked variable — may play a critical role in deciding which environmentally sustainable strategies are likeliest to succeed, at least in the short run.

In this article, we show how you can use the MBASE process framework to generate a family of acquisition process models for delivering usersatisfactory systems under schedule, cost, and quality constraints. We present the six major steps of the Schedule/Cost/Schedule-Cost-Quality as Independent Variable (SAIV/CAIV/SCQAIV) process using SAIV and a representative Department of Defense (DoD) Command, Control, and Communications Interoperability application as context. We then summarize our experience in using SAIV on 26 University of Southern California electronic services projects, followed by discussions of SAIV/CAIV/SCQAIV application in the commercial and defense sectors, of model application within the DoD acquisition framework, and of the resulting conclusions. • Determination of a top-priority core capability and quality level strongly assured to be achievable within the schedule-cost-quality constraints. • User expectations management and continuing update of feature priorities. • Architecting the system for ease of dropping borderline-priority features and future addition of lower-priority features. • Careful progress monitoring and corrective action to keep within cost-schedule-

This paper was prepared by the Institute for Defense Analyses (IDA) for the Office of the Director, Acquisition Program Integration, under a task entitled "Program Risk Analysis and Management." This paper partially fulfills that task by comparing the feasibility and costs of two procedures whereby contractors reveal probability distributions of cost while bidding on defense contracts.

The Texas Department of Transportation (TxDOT) has continued to be proactive in finding innovative practices in programming and administering projects, including the construction contracting area. Warranty specifications show potential for reducing the life-cycle cost of facilities while ensuring the quality of constructed facilities. This report documents the research effort and findings for TxDOT Project 0-4498, "Warranty Based Specifications for Construction." The overall approach to this research leverages off of the guidelines documented in National Cooperative Highway Research Program (NCHRP) Report 451. The researchers modified these guidelines for consistency with TxDOT design, contracting, and maintenance systems.

thank Mike Hawk, Department of State for his consistent and continuous contributions throughout the life of this project. We would like to acknowledge Michael Ferraiolo, National Institute of Standards and Technology, for his assistance in developing the appendices and the following authors of the Key Practices and Implementation Guide for the DoD Comprehensive National Cybersecurity Initiative 11 Supply Chain Risk Management Pilot Program who were instrumental in developing the initial content of this NISTIR (contributors are listed alphabetically):

If you have driven recently along the north bank of the Clyde past the Erskine Bridge, you would have noticed nothing unusual going on across the river. Reality, however, is deceptive. Look again: where Erskine gives way to green flatlands there stands a town that has been there since pre-medieval times-Ardcalloch. It was a flourishing medieval burgh and supported the Bruce cause in the Wars of Independence; it is mentioned in Froissart's Chronicles; in the sixteenth century for a short time, like Fraserburgh, it had a university (a distinguished centre for the new Ramist curriculum in law); in the eighteenth century Boswell and Johnson visited it on their progress northwards. In the late twentieth century its riverside dereliction was transformed into a post-industrial Silicon Docks. In reality, it exists on a web server at the Glasgow Graduate School of Law. It represents the beginning of a twenty-first century transformation of Scottish professional legal education.

Federal agencies install many security controls for Federal Information Security Management Act (FISMA) implementation. National Institute of Standards and Technology (NIST) Special Publication (SP) 800-53 revision 4 (rev4) standardizes these security and privacy controls. This article presents a study of NIST SP 800-53 security controls. The purpose is to classify the security controls from dimensions relevant to software security. This classification highlights issues and motivates opportunities to drive software security initiatives using FISMA.

Poor project performance is often attributed erroneously to PMs and SEs that must perform in an environment characterized by: task of achieving contract financial, technical, and schedule "stretch" objectives in which they may have had little opportunity for input. This paper explores each of these conditions, through illustrative examples from a range of business domains and industries perspectives, along with potential opportunities for improvement so that, fundamentally, the game itself is changed-changed to one that can be won.

Poor project performance is often attributed erroneously to PMs and SEs that must perform in an environment characterized by: Inadequate proposal preparation and analytical due diligence in understanding the user&#39;s problem space and operational needs. Unrealistic proposal assumptions and contract constraints – such as overly aggressive schedules and inadequate funding. A Source Selection Evaluation Process that is overshadowed by a highly competitive “Acquisition Game” of perceptions, influence, persuasion, and potential conflicts of interest. Project Management and Engineering “stovepipes” that limit understanding of each other&#39;s roles, accountabilities, and their respective contributions. Contract “requirements creep” by the Acquirer with an expectation or Developer accommodation without appropriate contract cost modification. Deficiencies in Engineering and Systems Engineering due to outdated educational and competency paradigms. As a result of unreasonable and unrealisti...

thank Mike Hawk, Department of State for his consistent and continuous contributions throughout the life of this project. We would like to acknowledge Michael Ferraiolo, National Institute of Standards and Technology, for his assistance in developing the appendices and the following authors of the Key Practices and Implementation Guide for the DoD Comprehensive National Cybersecurity Initiative 11 Supply Chain Risk Management Pilot Program who were instrumental in developing the initial content of this NISTIR (contributors are listed alphabetically):

The Common Criteria (CC) is a computer-security standard that some governments use for procurement, e.g., the U.S. Department of Defense. To sell information-security products in these markets, CC certification is required. Much has been published about problems with CC, and there is extensive criticism of CC. For example, a director of the U.S. CC program was recently quoted as saying, "Defending the program is a full-time effort. It is a difficult job." This paper presents a survey of the problems and criticism reported about CC. The paper provides: (a) a categorization for the reported problems, (b) a survey of the reported problems, organized by category, and (c) an annotated guide to the sources that were especially useful and authoritative. This paper is intended as a resource for those who are: evaluating CC for possible use, preparing to use CC, or researching CC itself.