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FAR Complexity Reduction - Two for One


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Hello All!

I stumbled across this closed topic earlier and was curious about which parts of the FAR you would propose to eliminate? Our Agency went through a discovery exercise earlier and I am not sure if we identified as many regulations for elimination as we would have liked.

An example: Subpart 4.3—Paper Documents and 11.303 Special requirements for paper are possibly an example of complexity created by private interests.

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First on my list is FAR Part 30. I'm not saying eliminate CAS Administration, but the FAR Councils shouldn't be implementing CAS Board regulations. Just provide cross-references to the applicable CASB regulations, which are already located in FAR Part 99, for topics in FAR Part 30. 

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Guest PepeTheFrog

Deleting FAR Part 19 sounds good.

 

At a minimum, delete FAR Part 26, Other Socioeconomic Programs, and move its contents into FAR Part 19, renamed "Small Business and Socioeconomic Programs." 

(Then delete FAR Part 19, anyway!)

 

Also, to keep this troll going:

FAR Part 22. I'm not saying eliminate labor law, but the FAR Councils shouldn't be implementing Department of Labor regulations. Just provide cross-references to the applicable Department of Labor regulations for topics in FAR Part 22.

 

Also, just raise every threshold you can get your webbed feet around. That's the easiest and laziest method of "acquisition reform"-- exemption. A rising pond lifts all lily pads!  

 

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Eliminate everything having to do with the service contract inventory reporting by contractors.  Seems to just be a back door way of getting head counts that the Government can never give accurately.  And guess what?  They have never gotten accurate data from it either.  FAR 4.17. 

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Herein lies the problem . . .

Quote

4.1700  Scope of subpart.

This subpart implements section 743(a) of Division C of the Consolidated Appropriations Act, 2010 (Pub. L. 111-117), which requires agencies to report annually to the Office of Management and Budget (OMB) on activities performed by service contractors. Section 743(a) applies to executive agencies, other than the Department of Defense (DoD), covered by the Federal Activities Inventory Reform Act (Pub. L. 105-270) (FAIR Act). The information reported in the inventory will be publicly accessible.

The FAR (and its supplements) parts, sections, etc., that implement law or legal decision should be highlighted in bold and italics.  In that way, one will know which text of the FAR can be eliminated without further action.  It's time that each regulation should be shown its true source very clearly so that we know who to blame for the regulatory clutter.

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Let's not forget that while size (or quantity) can increase complexity, complexity is also a function of clarity (or quality).  I'd encourage anyone concerned with FAR complexity to visit http://www.plainlanguage.gov/ and read the "Federal Plain Language Guidelines."  Those who do will likely find him/herself wondering what the FAR (and other Government regulations/documents) might look like if they followed such guidelines.

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After reading the Federal Plain Language Guidelines, assess how well the FAR Councils did here:

Quote

If an emergency or unanticipated event interrupts normal Government processes so that proposals cannot be received at the office designated for receipt of proposals by the exact time specified in the solicitation, and urgent Government requirements preclude amendment of the solicitation, the time specified for receipt of proposals will be deemed to be extended to the same time of day specified in the solicitation on the first work day on which normal Government processes resume.

 

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On ‎9‎/‎7‎/‎2017 at 6:35 AM, bob7947 said:

It's time that each regulation should be shown its true source very clearly so that we know who to blame for the regulatory clutter.

I second the motion!

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