Overview
Title
Information Collection; Place of Performance
Agencies
ELI5 AI
The DoD, GSA, and NASA want to know where companies will do their work for the government, like if they will work in a different place than their main office. They are asking people to say if they think asking this is helpful or too hard to do before March 16, 2021.
Summary AI
The Department of Defense (DoD), General Services Administration (GSA), and NASA are seeking public comments on the renewal and extension of an information collection about "place of performance" related to federal government acquisitions. This involves understanding whether contractors plan to use facilities or plants that differ from their main address, which helps determine responsibility and price reasonableness in government contracts. The public can submit comments until March 16, 2021, through the website regulations.gov. The information collected has been approved for use until May 31, 2021, and the agencies propose extending this approval for three more years.
Abstract
In accordance with the Paperwork Reduction Act of 1995, and the Office of Management and Budget (OMB) regulations, DoD, GSA, and NASA invite the public to comment on a renewal and extension concerning place of performance. DoD, GSA, and NASA invite comments on: Whether the proposed collection of information is necessary for the proper performance of the functions of Federal Government acquisitions, including whether the information will have practical utility; the accuracy of the estimate of the burden of the proposed information collection; ways to enhance the quality, utility, and clarity of the information to be collected; and ways to minimize the burden of the information collection on respondents, including the use of automated collection techniques or other forms of information technology. OMB has approved this information collection for use through May 31, 2021. DoD, GSA, and NASA propose that OMB extend its approval for use for three additional years beyond the current expiration date.
Keywords AI
Sources
AnalysisAI
The document under review calls for public comments on the renewal and extension of information collection related to the "place of performance" in federal government acquisitions. This involves assessing whether contractors plan to use facilities different from their headquarters, aiding in ensuring responsibility and cost-effectiveness in government contracts. Agencies like the Department of Defense, General Services Administration, and NASA have proposed extending this information collection approval for an additional three years past its current expiration in May 2021.
Document Summary
The notice is structured to solicit input from the public and provides specific details about the existing approval's expiration and the proposed extension. The collection helps determine several factors, such as contractor responsibility, price reasonableness, and the need for inspection, by identifying where contractors plan to perform contracted work. These factors play a vital role in the rigorous procurement process for federal contracts.
Significant Issues and Concerns
One concerning aspect of the document relates to transparency in communicating its processes and potential impacts. While detailing technical facets, the document assumes knowledge of government jargon and procurement regulations, which might pose a barrier to understanding for individuals without specific expertise. By referencing particular Federal Acquisition Regulation (FAR) provisions, the content may become inaccessible to the general public, complicating meaningful comment submission from less specialized stakeholders.
There's also a notable lack of detail on how the information collected contributes to improving acquisition processes. While it mentions determining factors like contractor responsibility and price reasonableness, further explanation in layman's terms could illuminate the data's utility, enhancing public understanding and participation.
Additionally, the document states that comments will be published online, possibly including personal or business-confidential information. This could deter commenters concerned about privacy, which might skew the feedback pool toward those less concerned about such issues.
Impact on the Public
On a broader scale, the process detailed in this notice affects taxpayers indirectly through the responsible expenditure of government funds. By ensuring contractors are vetted for place of performance and related factors, agencies can aim to economize public resources wisely.
Yet, the notice could better facilitate public engagement by simplifying language and reducing privacy concerns, ensuring a diverse range of voices are heard in evaluation phases.
Impact on Stakeholders
For specific stakeholders, such as contractors bidding for government work, clear guidelines about the renewal's impact are crucial. They must navigate the nuances of place of performance efficiently to remain competitive. Clarifying the practical aspects of compliance with FAR provisions could significantly ease their burden.
Furthermore, individuals or organizations involved in bidding might fear the administrative burden of conforming to these requirements. Although quantitative data on burden hours is provided, practical examples could elucidate the real-world tasks expected, helping potential respondents prepare effectively.
In essence, while the document seeks constructive dialogue on a pertinent administrative necessity, addressing these noted concerns could facilitate deeper, more inclusive public interaction and ensure clarity and efficiency in policy renewal and implementation.
Issues
• The document does not specify if there are any particular organizations or individuals that might benefit from the proposed information collection renewal, potentially raising concerns about bias.
• There is a lack of specificity in the explanation of how the collected data will be used to enhance government acquisition processes, which might make it difficult for respondents to gauge the necessity and utility of the information collection.
• The document uses technical terms and references specific FAR provisions without providing simplified explanations, which could be unclear or difficult to understand for individuals not familiar with federal procurement regulations.
• The potential burden on respondents is stated in quantitative terms (number of respondents, responses, and burden hours), but there is no qualitative explanation of what constitutes this burden or any example scenarios, which could help clarify what is expected from the respondents.
• The document mentions that comments will be posted publicly on regulations.gov, including any personal or confidential business information. This might deter some individuals or organizations from submitting comments for privacy reasons.