Comment on FR Doc # 2012-21874

Some of these changes indicate the Agencies no longer are interested in honesty in fact, but only compliance with the law. For example, changing the name of the "Procurement Integrity Act" to "Restrictions on Obtaining and Disclosing Certain Information" seems to take personal integrity as a government contractor or employee out of the picture and replace it with compliance with applicable rules. In effect, the new term shifts the focus from integrity in fact, a personal trait to compliance with the law a compelled action. Federal Procurement is a profession, the hallmark of the profession is integrity in fact, taking the focus off integrity has the potential to cause significant damage to the procurement system. If any change is made in this name, it should be the simple removal of the word "Act" as with many other changes. This will leave integrity as a core value of our system. Another change that demonstrates the shift in focus from personal responsibility is the change in the name of the "Truth in Negotiation Act" to "Truthful Cost or Pricing Data." While the law requires "truthful" data, the primary purpose of the law, and its title, is to ensure honest negotiations. To me this change indicates that the government does not care about dishonest or misleading conduct in negotiations so long as the underlying data is truthful. This opens the door to a host of problems. Simply taking the word "act" out of the name is sufficient. Many of the other changes such as changing "competition advocate" to advocate for competition" and "Department of Justice" to "Attorney General" just don't seem to be worth the cost of tracking down and changing minor terms in dozens of regulations and policies which all have to be reprinted This rule sends the wrong message to the public and the contractor community, i.e. the Government is more interested in minor technicalities than the many serious issues involved in maintaining an honest and open procurement system.