Overview
Title
Information Collection; Extraordinary Contractual Action Requests
Agencies
ELI5 AI
The Defense Department, GSA, and NASA want people to say if they think it's helpful to gather certain information about special changes to contracts, like if it really helps and if it's easy enough to provide. They hope this helps them figure out better ways to collect information, especially using computers, without being too hard or time-consuming for those who help out.
Summary AI
The Department of Defense (DoD), General Services Administration (GSA), and NASA are asking the public to comment on a proposed extension of a rule that deals with extraordinary contractual action requests. They are interested in opinions on whether collecting this information is necessary and useful for federal acquisitions, how accurate the burden estimate is, and how to improve the process to make it easier for those providing information. These comments can be submitted through a government website by June 10, 2025, and they are especially focusing on how this information helps in making decisions about contract adjustments and indemnification against hazards.
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 extraordinary contractual action requests. 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 from the Federal Register outlines a request for public commentary on proposed extensions to regulations concerning extraordinary contractual action requests. This process, overseen by the Department of Defense (DoD), the General Services Administration (GSA), and NASA, aims to ensure that information collected during these actions serves its intended function in government acquisitions.
Summary
The primary aim of the request for comments is to gather public input on whether the data collection related to extraordinary contractual action requests is necessary and practical. The agencies are particularly interested in the efficiency and accuracy of this data collection process, seeking ways to reduce the burden on respondents, including through the use of technology. The current permissions for this collection expire on August 31, 2025, and the agencies hope to extend this approval for an additional three years.
Significant Issues and Concerns
Several concerns arise from the document:
Lack of Detailed Criteria: The document does not provide specific benchmarks or criteria for assessing the accuracy of the burden estimate involved in data collection. This lack of precision may make it challenging for stakeholders to offer constructive feedback.
Technical Language: The document uses specialized terms and references specific Federal Acquisition Regulation (FAR) sections without providing plain-language explanations. This might hinder comprehension for individuals not versed in federal contracting regulations.
High Estimated Burden: The estimation of 1,440 hours for 30 responses is significant, averaging 72 hours per response. The document does not adequately explain why each response requires such a substantial time commitment, potentially leading to confusion or concern among stakeholders.
Unclear Impact of Feedback: Although public feedback is solicited, it is not clear how these comments will influence changes to the current process. This lack of clarity may lead some to question the efficacy of their contributions.
Automated Solutions Not Clearly Outlined: While the notice mentions an interest in automated collection techniques, it does not specify any particular technologies or methods under consideration, missing an opportunity to engage with innovative solutions that could reduce respondent burden.
Public Impact
The document broadly impacts how federal acquisition processes might evolve, potentially streamlining how contractors engage with the government on extraordinary actions. By collecting and incorporating public feedback, the agencies aim to refine these processes, potentially benefiting from reduced administrative overheads and improved decision-making efficiency.
However, if not addressed, the significant burden on respondents could discourage participation, potentially limiting contract opportunities or stifling innovation in the private sector. The high time investment required might particularly impact smaller firms less equipped to handle intensive data collection requirements.
Stakeholder Impact
Specific stakeholders, particularly those in the defense and space industries, could be significantly affected by these regulatory extensions. Contractors in these fields may benefit from clearer guidelines and processes but also face challenges if the burdensome data requirements are not managed effectively.
Small businesses or new entrants, who might lack the resources to manage complex data submissions, could find these requirements particularly onerous. On the opposite end, larger firms, which may have more robust administrative support and processes, might experience less strain but still benefit from the clarity and efficiency improvements that this initiative seeks to achieve.
In conclusion, while the document’s call for comments provides an important opportunity for public and stakeholder input, addressing the outlined issues may be crucial in refining the data collection process to make it both more efficient and inclusive.
Issues
• The notice does not specify the specific criteria or metrics for determining the 'accuracy of the estimate of the burden of the proposed information collection', which might make it difficult for stakeholders to provide informed comments.
• The document uses technical terms and references specific FAR sections without providing lay explanations or summaries that could help a wider audience understand the content.
• The burden estimate assumes 1,440 hours for 30 responses from 20 respondents, which averages 72 hours per response. This significant time commitment is not explained or justified in detail, making it unclear why each response requires this amount of effort.
• There is a lack of information on how the feedback received from public comments will specifically influence any changes to the information collection process.
• The document does not outline specific automated collection techniques that could be implemented to minimize the burden on respondents, despite mentioning the interest in such solutions.