Overview
Title
Information Collection; Past Performance Information
Agencies
ELI5 AI
The government wants to know if continuing to collect information on how well companies did their jobs for them in the past is helpful and not too difficult for those companies to provide. They are asking people to share their thoughts on this by a certain date.
Summary AI
In this notice, the Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA) seek public comments on the renewal of information collection related to past performance in government acquisitions. The agencies are interested in feedback about the necessity, utility, and burden of this information collection, including how to improve its quality and efficiency. The Office of Management and Budget (OMB) has approved the current information collection, and the agencies propose extending this approval for three more years. Comments are open until April 12, 2021, and contributors can submit their thoughts through the regulations.gov website.
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 revision and renewal concerning past performance information. 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 April 30, 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
In the document from the Federal Register, the Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA) invite the public to provide feedback on the continued collection of information relating to past performance in government acquisitions. This information collection is meant to assist in assessing the capability of contractors and ensuring success in government projects. The agencies are seeking to understand if the current process serves its intended purpose effectively and are proposing to extend the approval for this process by three more years.
Summary
The aim of gathering past performance information is to evaluate contractors' previous work to make better-informed decisions in future government projects. This effort is part of a broader compliance activity as set out by the Federal Acquisition Regulation (FAR). The public is invited to comment on the necessity and utility of the information collected, the burden it places on contractors, and suggestions for minimizing this burden. Contributions to the consultation process should be made via the regulations.gov website by April 12, 2021.
Significant Issues and Concerns
Several notable issues warrant attention. Firstly, there is a lack of clarity on how the estimates for the burden of information collection have been determined. This lack of transparency might hinder some from providing informed feedback. Additionally, the document uses technical language when describing specific FAR requirements, which may be challenging for those unfamiliar with federal acquisition regulations.
The document does not address how the information collected will be kept confidential and secure, raising potential privacy concerns. This oversight could deter some businesses from providing candid feedback. Additionally, the document does not explain why the evaluation of past performance is sometimes deemed unnecessary for acquisitions above a certain financial threshold.
Finally, while the document briefly mentions automated collection techniques as a way to reduce the burden, it lacks a detailed discussion on these methods. More detail could help stakeholders understand potential efficiencies and encourage relevant innovations.
Impact on the Public and Stakeholders
For the general public, the impact of this document may seem indirect but substantial. Effective government procurement processes can lead to more efficient and cost-effective use of taxpayer dollars. However, the process's burden on businesses, especially smaller ones, cannot be overlooked. Small businesses may face challenges gathering and maintaining detailed past performance records, potentially leading to increased administrative costs. This could discourage their participation, reducing competition and innovation in government contracting.
Conversely, some stakeholders could find opportunities within this process. Expanding automated systems to streamline data collection could result in new business ventures geared toward aiding companies in managing their past performance records more effectively.
In summary, while the document seeks constructive feedback on an important part of government procurement, addressing these significant issues and ensuring clarity and efficiency in the review process will be vital for its success and acceptance among various stakeholders.
Issues
• The document does not specify how the accuracy of the estimate of the burden of the proposed information collection was determined. More details on the methodology used would be helpful.
• The language used to describe specific FAR requirements and provisions is highly technical and might be difficult for individuals unfamiliar with federal acquisition regulations.
• The document lacks information on how the information collected on past performance will be protected, especially concerning confidentiality and privacy.
• The document does not provide a justification or explanation on why the past performance information evaluation may not be applicable for certain acquisitions above the simplified acquisition threshold.
• There could be a more explicit discussion on how automated collection techniques or other forms of information technology could minimize the burden on respondents.
• The document does not address the potential cost implications for businesses, particularly small businesses, of gathering and maintaining the required past performance information.
• The process for submitting comments as outlined may be cumbersome for individuals who are not well-versed with digital or online platforms, such as regulations.gov.