Everything posted by PhiSig615
PhiSig615 commented on Don Mansfield's blog entry in Don Mansfield's BlogGreat thought provoking entry. Does the collection of information requirements imposed by the PRA apply to individual agency procurement actions? I could argue they do not. My rationale is that individual procurement actions resemble adjudication, rather than rulemaking. In other words, contracting officers are performing agency actions that are quasi-judicial functions rather than quasi-legislative functions when conducting acquisitions. The distinction should be made, because (Section 3502(3)( the term collection of information shall not include a collection of information described under 3518 ©(1). The exemptions listed here appear to all resemble agency adjudication functions. Specifically, the exemption at 3518 ©(1)((ii) is for an administrative action or investigation involving an agency against specific individuals or entities. In my opinion, the decision to award or not award an individual agency contract action amongst a relatively small group of private entities appears to meet this exemption definition. Thoughts?