Overview
Title
Information Collection Requirement; Defense Federal Acquisition Regulation Supplement; Part 239, Acquisition of Information Technology
Agencies
ELI5 AI
The government wants to make sure it collects enough information to keep our technology safe and to help with phone and internet contracts. Some people think it should be clearer about why they need this information and how it affects small companies.
Summary AI
The Defense Acquisition Regulations System of the Department of Defense has proposed a revision and extension of a collection of information under the Paperwork Reduction Act, and they have submitted it to the Office of Management and Budget (OMB) for clearance. The information is collected to ensure the security of information technology and to assist with telecommunications services contracts. Comments on this proposal can be submitted until February 12, 2021. The collection involves approximately 820 respondents who are estimated to provide around 5,932 responses annually, with an average response time of 0.5 hours per response.
Abstract
The Defense Acquisition Regulations System has submitted to OMB for clearance, the following proposed revision and extension of a collection of information under the provisions of the Paperwork Reduction Act.
Keywords AI
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AnalysisAI
The document from the Federal Register is a notice from the Defense Acquisition Regulations System within the Department of Defense (DoD). It outlines a proposed revision and extension to a previously approved collection of information. This process is conducted under the Paperwork Reduction Act, which aims to minimize the paperwork burden on individuals, businesses, and government bodies while maximizing the utility of the information they collect.
General Summary
The essence of this document is to solicit public comments on the need for collecting specific data related to the acquisition of information technology and certain telecommunications services contracts. They are chiefly interested in ensuring that the information technology used in these contracts is secure. Additionally, they want to gather proposals from telecommunications service providers regarding special construction requirements. The information collected serves to ensure compliance with security requirements and establish reasonable costs for certain services. The public has until February 12, 2021, to submit comments or suggestions regarding this proposal.
Significant Issues and Concerns
Lack of Detailed Justification: The document mentions the necessity to collect information to establish reasonable prices, but it doesn't explain how the data collected would precisely achieve this goal. A clearer explanation would enhance understanding and justify the burden placed on respondents.
Terminology Clarity: Terms such as "Protection Against Compromising Emanations" are used without explanation, potentially confusing those not well-versed in technical or regulatory language. This could lead to misunderstandings among stakeholders who would need to comply with these requirements.
Potential Impact on Small Businesses: The document does not discuss how these requirements might affect smaller entities. For small businesses, complying with extensive documentation and proposal requirements can be particularly burdensome and might need special considerations or exemptions.
Complexity and Accessibility: The overall complexity, including numerous references to regulations and control numbers, makes it challenging for individuals without prior knowledge of government contracting to fully comprehend the requirements. Simplifying language or providing an explanatory guide would be beneficial.
Broader Public Impact
For the general public, especially those involved in providing information technology services to the DoD, the impact revolves around ensuring security compliance. It underscores the importance of proposals meeting strict security guidelines to protect sensitive information.
While the process is designed to minimize unnecessary paperwork, the specifics may still increase the burden on companies required to prepare extensive documentation. This can lead to increased operational costs, potentially influencing prices for the government and, by extension, the public paying for these contracts through taxes.
Stakeholder Impact
Positive Impacts:
Security Enhancement: The focus on meeting information assurance requirements could lead to enhanced security infrastructure, benefiting both service providers and the government by reducing vulnerabilities.
Market Standards: Establishing clear expectations for proposals related to telecommunications services could standardize practices, potentially leading to more consistent pricing and service quality.
Negative Impacts:
Increased Compliance Costs: The additional paperwork and need for detailed proposals might impose greater administration costs on businesses, particularly affecting smaller entities with limited resources.
Potential Barriers: For businesses new to contracting with the government, the detailed and complex requirements could serve as a barrier to entry, reducing competitiveness and innovation in the market.
Overall, the document indicates a careful balancing act between ensuring the secure and cost-effective acquisition of technology services and managing the bureaucratic burden on those providing these services. The public feedback period allows for necessary adjustments before the regulations are finalized, giving stakeholders an opportunity to voice concerns and suggestions.
Issues
• The document does not provide detailed justification or examples of how the collected information will specifically be used to 'establish reasonable prices for special construction by common carriers.' This could potentially lead to unclear understanding of the necessity and efficiency of the information collection.
• The document does not clarify what is meant by 'Protection Against Compromising Emanations,' which may be ambiguous for those unfamiliar with this terminology.
• There is no discussion about the potential impact on small businesses, which could face challenges in complying with the documentation and proposal requirements outlined in the notice.
• The overall complexity of the document and the various references to specific clauses and control numbers may be difficult for some stakeholders to understand without prior knowledge of government contracting and the associated regulations.