Overview
Title
Reporting and Recordkeeping Requirements Under OMB Review
Agencies
ELI5 AI
The Small Business Administration (SBA) wants to collect some information to help decide if small businesses can argue about certain decisions. People can tell the SBA what they think about this plan until March 25, 2021.
Summary AI
The Small Business Administration (SBA) is asking for approval from the Office of Management and Budget (OMB) to collect information for an application process. This information will help determine if a small business can appeal a government contract decision. The public can comment on this process until March 25, 2021, by visiting the given website. The SBA estimates that 300 small businesses will participate annually, with a total time burden of 2,400 hours.
Abstract
The Small Business Administration (SBA) is seeking approval from the Office of Management and Budget (OMB) for the information collection described below. In accordance with the Paperwork Reduction Act and OMB procedures, SBA is publishing this notice to allow all interested member of the public an additional 30 days to provide comments on the proposed collection of information.
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Sources
AnalysisAI
The document under review involves the Small Business Administration's (SBA) request for approval from the Office of Management and Budget (OMB) to gather information for an application process. This process is essential for determining whether a small business can appeal a decision made by a government contracting officer regarding the award of a government contract. Interested parties are invited to comment on the information collection until March 25, 2021.
General Overview
The notice describes the SBA's intention to collect data to assess whether a contracting officer's decision should be overturned when a small business appeals a non-responsibility determination. This action aligns with the SBA’s role in supporting small businesses, particularly in government contracting scenarios. Under the Paperwork Reduction Act, the SBA must seek public comments and obtain OMB approval for such information collection efforts.
Significant Issues and Concerns
Several issues in the document could affect its clarity and effectiveness:
Calculation Transparency: The SBA estimates that 300 small businesses will respond annually, incurring a total of 2,400 burden hours. The document does not explain how this figure was derived, making it difficult for stakeholders to understand the cost or the time commitment required per response.
Submission Instructions: The instructions for submitting comments on the reginfo.gov website lack detail. Clearer, step-by-step guidance would help public users navigate the site more easily and effectively.
Awkward Phrasing: There is an awkward construction in the sentence regarding the information contained in the form, where an unnecessary comma creates confusion. Correcting this could enhance readability.
Open-ended Recommendations: While the document invites suggestions for minimizing the information collection burden through automated techniques or technology, it offers no examples, making it challenging for respondents to contribute constructive suggestions.
Contact Information Clarity: Although contact details are provided for Curtis Rich, the lack of specific guidance on when to use email versus phone could hinder effective communication.
Impact on the Public and Stakeholders
Broadly, this document has implications for all small businesses involved or interested in government contracts. Simplifying the application for appealing contract decisions supports small businesses in accessing fair assessment opportunities for government work.
For specific stakeholders, primarily small business owners, and potential appellants, the additional documentation requirement represents added work, though it potentially opens doors to opportunities they may have been otherwise denied. These businesses may view this as a positive avenue to contest decisions affecting their operations. At the same time, they might find the additional time and effort burdensome, especially if they lack the resources to efficiently manage additional administrative tasks.
In conclusion, while the document embodies a constructive development regarding small business government contracting, improvements in clarity and detail would enhance its accessibility and effectiveness for its intended stakeholders. The chance to weigh in through public comments empowers stakeholders, but additional guidance and examples could support a more meaningful participation.
Issues
• The document does not provide detailed information on how the estimated annual hour burden of 2,400 hours was calculated in relation to the estimated annual responses of 300. More transparency on this calculation would be beneficial.
• The instructions for submitting comments via the reginfo.gov website are somewhat vague. More detailed step-by-step instructions might aid users in navigating the website to find the information collection request.
• The phrasing 'the information contained on this form, as well as, other information' is slightly awkward due to the extra comma. Removing the comma after 'as well as' would clarify the sentence.
• The document does not specify what kind of automated techniques or information technology could be used to minimize the burden, leaving such recommendations open-ended. More specific examples or suggestions might be useful.
• The contact information for Curtis Rich includes an email address and phone number but does not specify the circumstances under which each method should be used which might affect its clarity.