Comment on FR Doc # 2026-12559
Christopher ColbowSupportIndividual
Summary: The commenter supports the FAR Council's efforts to simplify procurement but argues that the current Paperwork Reduction Act (PRA) framework creates bureaucratic hurdles for necessary data collection. They recommend creating pre-cleared feedback forms, exempting routine operational data from rigid PRA clearance, and allowing for iterative approvals to facilitate faster service improvements.
I appreciate the FAR Council’s historic effort to eliminate thousands of non-statutory regulations under the Revolutionary FAR Overhaul. The intent to simplify procurement is a vital step toward modernization. However, as the Council re-evaluates the information collection burdens under the Paperwork Reduction Act (PRA), I urge OMB and the FAR Council to rethink how the PRA framework is applied to modern data collection. While the PRA's intent is to prevent unneeded burdens on contractors, its highly structured, multi-month approval process creates a massive barrier to "streamlined and expedient" data collection. To truly modernize federal procurement and improve services, agencies must be allowed to gather targeted, rapid feedback from the contracting community. When an agency needs to collect data to diagnose an inefficiency or fix a broken system, waiting months for dynamic PRA clearance stalls progress. Agencies often choose not to gather valuable industry data simply to avoid the bureaucratic hurdles of a formal PRA clearance process. Information collection should not be viewed strictly as a negative "burden." When data is collected swiftly and intelligently, it allows agencies to streamline processes, remove bottlenecks, and ultimately lower the long-term operational burden on both the government and the private sector. Fast data collection leads to faster improvements in federal services. To ensure the FAR Overhaul achieves its goal of cutting red tape, I recommend the following: (1) Create pre-cleared, standardized feedback forms for agencies to query contractors about procurement bottlenecks without triggering a new, lengthy PRA cycle; (2) Explicitly clarify in FAR Part 1 that routine, non-coercive operational feedback, market research, and user-experience (UX) data gathered to improve procurement services are exempt from rigid PRA clearance; and (3) Allow for rolling or iterative PRA approvals that match the speed of modern digital tools and agile project management. The FAR Overhaul is a unique opportunity to change how the government interacts with industry. I encourage the FAR Council and OMB to treat data collection not as an administrative hurdle to be restricted, but as an essential asset for driving continuous, expedient service improvement.