Overview
Title
Information Collection; Change Order Accounting and Notification of Changes
Agencies
ELI5 AI
The DoD, GSA, and NASA want to know if the way they ask people for information when making changes to projects is good and helpful. They also want to make sure it's easy for people to give them this information and are asking for ideas on how to make it better.
Summary AI
The Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA) are looking for public input on extending the approval for collecting information related to change order accounting and notifications of changes. This is part of ensuring that these processes are necessary for efficient federal acquisitions and to minimize the burden on respondents. The agencies are asking if the information collected is useful, if the burden estimates are accurate, and how to improve data quality while reducing collection burdens. Comments are open until June 10, 2025, and submissions can be made through the specified government 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 an extension concerning change order accounting and notification of changes. 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 August 31, 2025. 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 in question is a call for public comments from three major agencies: the Department of Defense (DoD), the General Services Administration (GSA), and the National Aeronautics and Space Administration (NASA). This request relates to the continuation of a procedure allowing for the collection of information regarding change order accounting and notification of changes in federal government acquisitions. The request sets a deadline for public input until June 10, 2025, and encourages submissions through a specified government website.
General Summary
This notice invites interested parties to contribute their thoughts on whether extending the current information collection procedure is necessary. It specifically seeks feedback on several aspects: the utility and necessity of the data collection, the accuracy of the estimated burden it places on respondents, and suggestions for enhancing its quality and reducing the burden, potentially through automated technology.
The information collected under this procedure assists in making necessary changes to federal contracts, which maintain accountability and transparency in government spending. Notably, this initiative falls under the regulations set by the Office of Management and Budget (OMB) and is currently approved until August 31, 2025. The goal is to extend this approval for another three years.
Significant Issues and Concerns
While this document is comprehensive, several issues arise:
Vague Details on Automation: The document suggests that automation could ease the burden on those required to submit information, but it fails to provide specific examples or solutions, which might lead to ambiguity regarding implementation.
Complexity of Regulatory Descriptions: The text outlines clauses from the Federal Acquisition Regulation (FAR) that may be too complex for individuals not familiar with government acquisitions, limiting public engagement and understanding.
Lack of Cost Analysis: There is no breakdown of costs related to the implementation and compliance with these regulations. Without detailed financial implications, it is difficult for stakeholders to assess potential inefficiencies or burdens.
Questionable Threshold Justification: It is unclear whether the $100,000 threshold for change order accounting is suitable, nor does the document present an analysis supporting this amount.
Incomplete Burden Estimates: Although total burden hours and respondents are listed, the methodology behind these figures is not shared, raising questions about their accuracy.
Rationale for Extension: The justification for pushing for an extension beyond the original expiration date is thin, which might limit public understanding of its necessity.
Impact on the Public and Specific Stakeholders
Broad Public Impact: For the general public, this document relates to how government contracts are managed under changing conditions. Proper and transparent accounting practices ensure that taxpayer money is spent effectively. The ability to provide feedback encourages civic engagement and accountability in government operations.
Stakeholders: For contractors who work with the government, this process impacts how they handle changes in contract terms. The detailed compliance requirements could shape the administrative workload significantly. Positive impacts include potentially streamlined processes and clear protocols. However, the downside might involve increased bureaucratic complexity and potential costs due to exhaustive reporting requirements and maintaining separate accounting systems.
This document serves as a liaison between federal agencies and the public, aiming to improve processes which ultimately signify prudent financial stewardship and fair contractual arrangements. Yet, there are opportunities for improvement, especially in terms of clarity, transparency, and the consideration of stakeholder impacts.
Financial Assessment
In examining the money references within the document, two key financial aspects warrant attention.
Change Order Accounting Threshold
The document specifies that change order accounting may be mandated by the contracting officer whenever the estimated cost of a change or series of related changes exceeds $100,000. This threshold amount is significant as it determines when contractors must implement a potentially extensive accounting process to track the financial impact of changes to contracts. However, the document does not provide any analysis or reasoning regarding whether this $100,000 threshold is still appropriate or if it could be revised. An evaluation of this threshold could reveal whether it sufficiently captures the relevant changes without imposing unnecessary administrative burdens on contractors, aligning with the issue identified about the absence of justification for current financial thresholds.
Clause Usage Based on Contract Amount
There's a stipulation that discourages the use of certain contractual clauses if the contract amount is expected to be less than $1,000,000, unless exceptional circumstances are anticipated by the contracting officer. This figure sets a limit under which these clauses are generally not considered cost-effective to implement, suggesting an attempt to balance regulatory oversight with practicality and cost efficiency. Nonetheless, as per one of the issues raised, there is a lack of specific breakdowns or cost analyses associated with implementing these clauses, which might provide insights into whether this $1,000,000 threshold is an effective metric or if it unduly constrains contract management efficiencies.
These financial references highlight an ongoing requirement to balance regulatory compliance with cost-effective procurement practices. They also suggest a need for further analysis or revision to ensure that financial allocations and thresholds truly reflect current economic realities and contractor burdens. Without detailed analyses justifying these thresholds or exploring potential adjustments, stakeholders might question whether these financial references and their implications align with efficient governmental and contractor practices.
Issues
• The document does not specify examples of automated collection techniques that might be used to minimize the burden of information collection, leaving the burden reduction methods somewhat vague.
• The descriptions of the FAR clauses (FAR 52.243-1, 52.243-2, etc.) are detailed but may be complex and difficult to understand for those not familiar with Federal Acquisition Regulations.
• There is no breakdown of specific costs associated with the implementation and compliance of these regulations, making it difficult to assess potential wasteful spending or overly burdensome requirements.
• The document does not provide information on any analysis performed to determine if the $100,000 threshold for requiring change order accounting is appropriate or if it should be adjusted.
• The description of the annual burden only provides total hours and respondents but lacks specific information on how these figures were derived, making it difficult to evaluate the accuracy of these estimates.
• The reasons for extending the approval for three years beyond the expiration date are not fully justified, potentially limiting understanding of the necessity behind the extension.