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PhiSig615

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  1. Great 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?
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