Reducing Regulatory Burdens

On June 22, 2012, the Office of Management and Budget issued a Memorandum for the Heads of Executive Departments and Agenciesentitled “Reducing Reporting and Paperwork Burdens.” The memorandum states that

“Eliminating unjustified regulatory requirements, including unjustified reporting and paperwork burdens is a high priority of this Administration.”

It then directs agencies to take further steps to achieve that goal. In addition, the memorandum provides nine examples of meaningful steps that agencies can take to reduce paperwork and reporting burdens.

The Coalition strongly supports this effort to reduce paperwork burdens on the American people and the private sector. Unnecessary, burdensome paperwork reporting requirements increase costs, reduce competitiveness for American business, and, in particular, hamstring small businesses. Fundamentally, unnecessary, burdensome paperwork collection and reporting requirements cost American jobs.

Consistent with OMB’s memorandum, there are a clear opportunities to address and reduce the costs associated with current federal procurement reporting requirements. Given the current budgetary challenges, procurement reporting requirements must be strategic, efficient, and effective. The Coalition suggests that the government consider taking the following meaningful steps to address burdensome procurement reporting requirements:

• Conduct a comprehensive inventory and review of current statutory, regulatory, and program-specific procurement reporting requirements with the goal of identifying redundant, duplicative requirements, and/or contradictory reporting requirements
• As part of that comprehensive inventory and review, also identify those data collection requirements that add no value to the government, yet increase contractor costs
• During the pendency of the inventory and review, freeze the issuance or enactment of any new procurement data reporting requirements
• Conduct an internal business process review to identify the data elements necessary to support sound acquisition and program planning by the government
• Survey, identify, and, to the maximum extent practicable, adopt commercial best practices for data collection and use, and standardize procurement data reporting across the procurement system to the maximum extent practicable
• Require a review and approval by the agency head for new or supplemental data reporting requirements to be included in a proposed contract or contract vehicle
• Re-establish the long-standing paperwork review requirement that limits the collection and reporting of data by contractors when the data is already in the government’s possession

Collectively, these steps would provide a framework to apply sound management discipline to the collection of procurement-related data. Further, they would provide an opportunity to develop and to implement more efficient and cost-effective approaches to the collection, reporting, and maintenance of data by the government and contractors than exist today. An efficient procurement data reporting system reduces operating costs for both government and contractors which, in the long run, benefits the taxpayer and the economy overall, but especially when budgets are tight.

On another data submission matter, the Coalition is seeking feedback regarding the current process for software licensing via the EULA. We are interested hearing in your experiences with GSA and EULAs. In essence, this is a status update request for our members. Please follow up with Roy Dicharry at [email protected]

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