GSA: Regulatory Management Systems Support BPA
The goal of this BPA is to build digital tools that support and enhance the rulemaking process for all affected stakeholders, including average citizens and small regulated entities. This will be accomplished by enhancing the user experience for all stakeholders involved in docket management and regulatory comment and review processes. GSA will support an open and transparent government to improve the accessibility and interoperability of regulatory information across government, promote third-party reuse of regulatory data, and improve the efficiency and effectiveness of agencies, researchers, and other legal knowledge workers.
●System / Data Security
In addition to security controls and standards addressed in H.4 and H.5, the contractor must protect personally identifiable information (PII). The best way to do that is not to collect PII at all through de-identification (e.g., by applying Privacy Preserving Record Linkage (PPRL) techniques). It needs to be made clear when PII needs to be collected, what is collected, why, and how it will be used.
● Integrity of the Rulemaking Process
Although Regulations.gov and Reginfo.gov now have reCAPTCHA on their respective comment forms for regulatory actions and ICRs, additional measures shall be continually evaluated to avoid any real or perceived threats to the rulemaking process through unsanctioned bot activity, the use of falsified identities on comments, or other risks.
● Data Accuracy
Data entry shall be reduced while ensuring data integrity and reliability. The platform shall enable data sharing, access to common services and functions, efficient use of technology in support of current functions provided by the eRulemaking and RISC systems, and collaboration with the National Archives and Records Administration (NARA) and the Government Publishing Office (GPO) for interoperable data standards and web services.
● Technology Fit for the Business Need
Any commercial or government-off-the-shelf platforms and components directly supporting legal analysis or case management should leverage existing research and development and have past performance in supporting unique challenges faced by legal knowledge workers. Regulations are complex, rely on domain-specific semantics, can involve multiple interdependencies and jurisdictions, and are impacted by frequent changes.
● System Availability / Responsiveness
Agency teams need to be able to connect to the systems to post and get responses to notice and comment requests in near real-time as they manage their rulemaking dockets. OIRA and agencies need to fulfill oversight obligations without the risk of delays.
Services for eRulemaking and RISC information systems must be understandable and straightforward. If public users find the process too hard or the tools too complicated, they will be disincentivized from engaging in the rulemaking process, making the rules and policies of the federal government less inclusive and equitable. Usability could also impact the productivity of OIRA and agency staff and their responsiveness to senior officials in the Executive Office of the President and agencies.
● Enterprise Efficiency
The contractor shall seek to achieve enterprise efficiencies through the reuse of GSA enterprise investments including, but not limited to, hosting, middleware, software licenses, and federated identity solutions.
● Future Capacity
GSA’ regulatory tools must be able to adapt to potential future legislative requirements and business needs. For example, new executive orders on the rulemaking process are often issued with each new presidential administration. A future legislative action could also require GSA to collaborate with other benefit programs to bring other information into the foundation that is built.
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