Letter to DOD: Prompt Payments of Small Business Contractors (DFARS Case 2018-D068)
The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits these comments on the Department of Defense’s proposed rule, Defense Federal Acquisition Regulation Supplement: Prompt Payments of Small Business Contractors (DFARS Case 2018-D068).
Advocacy urges the DFAR Council to revisit, revise, and re-publish for comment a supplemental Initial Regulatory Flexibility Analysis (IRFA) to ensure proper alternatives are discussed, to describe better the regulated entities and the costs that the rule would impose on them, and to resolve the apparent conflicts in the FAR for accelerated payment to prime and subcontractor small businesses. DOD should not go forward with this rule until it has considered the comments on the supplemental IRFA.
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