Comments on TSP Interim Final Rule
Section 652.21(a)(2): the Interim Rule states: “Consequently, NRCS is taking the
opportunity to clarify its policy that licensing and state law requirements will be
the only state-level certification criteria allowed. No change to the regulation is
necessary since state law and licensure requirements are already addressed at
section 652.21(a)(2)”.
It needs to be extremely clear that States can add only licenses or items required
by State Law. It should also be made clear that NRCS employees are not to
influence the creation or “enforcement “of State requirements with licensing
Boards, etc. The TSP Provider Registry needs to be to be updated immediately to
delete state level requirements that are not the result of licensing and state law
requirements.
As the review occurs, do all you can to guard against arbitrary additional
requirements. Remember your existing agreements with groups for certification,
and try to hold the line on any additions to existing requirements—in fact, some
existing requirements should be discontinued. For instance, it seems rather
difficult to justify requiring specific courses in a certification process. Rather, the
knowledge and skill required should be the need.
Section 652.3(4): This is an excellent addition and must be “enforced”. Leave
training responsibilities to the private sector and marketplace. NRCS has
previously assumed way more training and quality control activities than they
needed to assume. Certify private sector providers through a national Tech Reg,
and let the system work. Don’t be so concerned with format, but rather with
content.
Section 652.5(e) and (f): These are good additions. The details in implementation
of a plan, and payment of it, prior to having a program contract will be very
important.
Section 652.5(m)(2)(ii): Use of procurement data must be monitored carefully. It
should include all data related to an RFP and/or GSA procurement schedule. To
use procurement data from individual contracts and cooperative agreements with
other agencies would be very misleading, as some TSP’s have had to accept far
lesser rates than are fair and reasonable simply to have some government work to
complete. Cooperative agreements with NGO’s and other agencies do not reflect
total cost as NGO’s, as these are often are subsidized from other funding sources.
Section 652.6(b): It should be clear that the GSA contracting method is
acceptable.
Section 652.6 (c): Make it clear that “non-Federal entity” includes the private
sector.
Comment on FR Doc # E9-00828
This is comment on Rule
Technical Service Provider Assistance
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