4.  What are the projected reporting, recordkeeping, Paperwork Reduction Act and other compliance requirements?

For purposes of the Paperwork Reduction Act, 44 U.S.C. chapter 35, DoD, GSA, and NASA determined that the rule imposes new reporting and recordkeeping requirements. The certification process described in 13 CFR subpart C, 127.300 to 127.302, is an information collection. The certification process requires a concern seeking to benefit from Federal contracting opportunities designated for WOSB or EDWOSB concerns to verify its status by providing documents to the WOSB Program Repository, submitting a certification to the WOSB Program Repository, and representing its status in an existing electronic contracting system (i.e., ORCA). The WOSB or EDWOSB concern will have to represent in ORCA that it meets each eligibility requirement of the program.

Specifically, the WOSB or EDWOSB concern will be required to submit certain documents verifying eligibility at the time of certification in ORCA (and every year thereafter). These documents will be submitted to a document repository established by SBA. Further, the protest and eligibility examination procedures will require the submission of documents from those parties subject to a protest and eligibility examination. To reduce the burden on the WOSB or EDWOSB concerns, the same documents submitted at the time of certification will be used for the protests and eligibility examinations, except that for protests and eligibility examinations, SBA will also request copies of proposals submitted in response to a WOSB or EDWOSB solicitation and certain other documents and information to verify the status of an EDWOSB concern.

Finally, this rule also requires the WOSB concerns or EDWOSB concerns to retain copies of the documents submitted for a period of six years. DoD, GSA, and NASA believe that any additional burden imposed by this recordkeeping requirement would be minimal since the firms would maintain the information in their general course of business.