FR 2021-01196

The document from the Department of Defense (DoD), as published in the Federal Register, is a notice seeking public input regarding a proposed revision and extension related to the Defense Federal Acquisition Regulation Supplement (DFARS). This pertains to the ways independent research and development (IR&D) project descriptions are collected from businesses, specifically aimed at improving the information's utility for defense purposes. The time frame to send in comments runs until March 22, 2021, before the current approval expires on April 30, 2021.

General Summary

The notice highlights DoD’s intention to revise the way they gather technical descriptions of independent research and development projects. This effort aligns with existing practices under DFARS where businesses report their IR&D activities. The collection involves various reporting metrics such as response frequency and the associated time burdens on businesses. The DoD emphasizes the need for public assessment on whether the data collected is meaningful and how its collection process could potentially be streamlined for less burden.

Significant Issues and Concerns

A few issues arise from the document, notably around transparency and clarity. One concern is the absence of detailed monetary implications, both possible costs and benefits, of extending this information collection requirement. This vagueness could obscure financial impacts on the government and, by extension, taxpayers. Additionally, the criteria used to estimate the "average burden per response" time is not explained, which might raise questions regarding the accuracy of this figure. Such estimates are crucial when assessing the feasibility and reasonableness of the compliance requirements imposed on businesses.

Furthermore, while the notice calls for ideas to improve the utility and clarity of the information collected, it doesn't offer explicit examples or ideas, which could make it difficult for stakeholders to provide effective feedback. The term "in-process information," describing the content of IR&D projects, is also somewhat ambiguous and could benefit from further clarification.

Impact on the Public

Broadly, this notice could influence not just how the DoD functions but, indirectly, how taxpayer dollars are monitored and utilized through IR&D reimbursements. By improving the collection and use of research data, the efficiency and effectiveness of defense spending may increase, which could enhance national security.

Impact on Specific Stakeholders

Positive Impacts:

• For the DoD: Enhancing data collection and processing might improve the department’s ability to evaluate which IR&D initiatives should continue receiving funding, potentially leading to smarter investments in research and development.
• For Businesses: More efficient reporting processes could reduce the administrative burden and associated costs, allowing them to channel more resources toward actual research activities.

Negative Impacts:

• For Businesses: The maintained or potentially increased burden of regulatory compliance could demand extra time and resources. If the processes are not streamlined adequately, it may discourage some smaller businesses from engaging in defense-related R&D.
• For Citizens/Treasurers: Lack of transparent financial implications attached to these decisions raises concerns about unintended economic impacts.

Overall, the public and stakeholders' active engagement in commenting on such notices is crucial for ensuring that information collection requirements, like this IR&D reporting, are as effective and efficient as possible. Balancing the needs of national defense and the impacts on businesses and taxpayers is imperative.