FR 2021-02242

The document under review is a notice from the Department of Defense, the General Services Administration, and NASA, issued under the Paperwork Reduction Act. It announces a request to the Office of Management and Budget (OMB) to review and approve the revision and renewal of a previously approved information collection requirement. This requirement pertains to the organization and direction of work, specifically for certain government contractors.

General Summary

The notice clarifies that contractors, under cost-reimbursement construction contracts, will be required to submit organizational information. This involves a chart detailing the executive and administrative makeup of their teams, the personnel involved in the work, and their duties. This data ensures that the work is conducted by qualified personnel at a reasonable cost to the government. Furthermore, contractors must keep this information current and submit updates as needed. The public is encouraged to provide comments on this proposed requirement by March 5, 2021.

Significant Issues and Concerns

Several issues arise from the document, primarily its lack of details surrounding key aspects of the proposed requirement. First, the document does not specify the costs associated with the information collection requirement. Understanding these costs is crucial for evaluating the process's efficacy and avoiding wastefulness. Moreover, the document is somewhat opaque regarding how the collected data will be utilized to assess cost reasonableness, leaving stakeholders without clear criteria for evaluation.

Additionally, the language of the instructions for comment submission may be complex for the general public. The need to navigate multiple websites and the comprehensive explanatory requirements could deter meaningful participation. Another point of concern is the ambiguity regarding the roadmap post the 30-day comment period. Stakeholders are left without a clear understanding of subsequent steps or decisions.

Finally, the document highlights a small number of respondents and burden hours, which might raise questions about the necessity and efficiency of this requirement. This might suggest that the administrative burden is disproportionate to the supposed benefits.

Public Impact

For the general public, this document's impact may seem indirect. However, it represents a facet of how government operations aim to ensure taxpayer money is spent efficiently by requiring contractors to prove their organizational competence and cost-effectiveness.

Impact on Specific Stakeholders

For the contractors involved, this requirement imposes an additional administrative burden, necessitating time and resources to compile and regularly update organizational charts and duties. While this might ensure qualified personnel conduct government work cheaply, small contractors with limited resources might find this requirement disproportionately challenging, potentially impacting their ability to secure government contracts.

For government agencies, this requirement aids in oversight and accountability, helping protect public resources by making sure that projects are managed effectively and economically. However, agencies must consider whether the administrative effort of processing and reviewing these submissions provides value commensurate with their objectives.

Overall, while the document seeks to implement a control mechanism over government-funded projects, clarity and refinement in communication and process could better address the interests and capabilities of all parties involved.