PSC Comments on USAID Proposed Rule on Planning, Collection, and Submission of Digital Information

 
Arlington, Va. (Feb. 16, 2022)  On February 14, 2022, the Professional Services Council (PSC) submitted comments to the U.S. Agency for International Development (USAID) on a proposed rule for managing digital information data as a strategic asset related to the Agency’s foreign assistance programs.  

“PSC supports the fundamental intent of the proposed rule and believes USAID has made significant progress in developing digital polices, as evidenced by its recent Digital Strategy,” said PSC Executive Vice President for Policy Stephanie Kostro. 

“PSC recognizes both the value of digital information in international development programming and those privacy concerns related to gathering, using, and storing such information,” she continued. “It is worth noting that several countries in which the United States engages in development activities currently have non-democratic governments. Such regimes can fail to accept data-related security requirements established by USAID and its implementing partners (IPs), who seek to carry out programs in health, education, environment, human rights, rule of law, and other fields critical to development. This puts a premium on careful crafting of data-related requirements for IPs that promote consistent, achievable results.” 

Recognizing that the proposed rule seeks to reduce the burden on contractors, increase efficiency, and improve the use of digital information, PSC’s comments also noted the importance of avoiding overly complex or burdensome requirements that could negatively impact USAID’s small business partners and prevent new entrants from seeking work with USAID.

Kostro noted, “Cognizant of USAID Administrator Samantha Power’s goals to (1) increase the number of new IPs bidding on/receiving awards and (2) increase activity with local partners, it is important to acknowledge the dampening effect that multiple, complicated submission requirements will likely have on potential market entrants (whether U.S. or local) and current small business IPs. Many of these small businesses lack staffing and financial resources to meet multiple, complex submission demands. Thus, unintended consequences of the rule, as proposed, could run counter to the Biden Administration’s stated goal to attract and retain new entrants and small businesses, who can support U.S. procurement needs.”

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