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pdfRegulatory Impact Analysis
RULE RIN# 0412-AA90
USAID Acquisition Regulation: United States Agency for International Development
(USAID) Acquisition Regulation (AIDAR): Planning, Collection and Submission of Digital
Information as well as submission of Activity Monitoring, Evaluation, and Learning Plans
to USAID.
A. Background
USAID is proposing to amend the U.S. Agency for International Development (USAID)
Acquisition Regulation (AIDAR) to implement policy and procedures to clarify and
streamline contractor reporting requirements related to digital information planning,
collection, and submission to USAID. Under current protocols, USAID contractors are
required to submit digital information to USAID under multiple award requirements using
several different information management portals. For example, contractors have
historically submitted monitoring and indicator data to locally-maintained information
systems in overseas missions; provided periodic reports in PDF format to the Development
Experience Clearinghouse (DEC) (see AIDAR 752.7005); and submitted baseline, survey,
and research-related datasets to the Development Data Library (DDL) (see USAID internal
policy at Automated Directives System (ADS) chapter 302.3.5.21 available at
https://www.usaid.gov/ads/policy/300/302). The maintenance of these separate portals has
made it challenging for USAID to integrate this information strategically to render a more
holistic and detailed view of its global portfolio. In addition, navigating a variety of
submission formats, websites, and business processes generates workload that can be
streamlined via modernized technologies and techniques. With the centralization and
standardization of digital information that USAID contractors provide to the Agency,
USAID anticipates that gathering key evidence to support evaluations and other
performance management efforts will be greatly facilitated.
Existing contractual requirements are also silent on or insufficiently address important and
emerging issues related to digital information management, such as data management
planning and digital information collection standards. USAID contractors may be aware, for
example, that the Agency is piloting the use of a new system technology called the
Development Information Solution (DIS) across multiple missions. Award changes related
to this pilot address only a part of the digital information lifecycle (e.g. indicator data
submission), are limited in scope, and apply exclusively to DIS. This rule is broader in
scope, intended to apply not only to DIS but to encapsulate the Agency’s enterprise-wide
approach to the digital information lifecycle in the years to come. Therefore, this rule
provides guidance on the entire lifecycle of digital information management, including data
management planning, digital collection methods and standards, licensing and consent to
ensure future re-use of USAID-funded digital information. It is intended to help USAID
systematically strengthen the evidence base required to implement efficient and effective
foreign assistance programs and to comply with mandates such as:
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OMB Circular A-130
Foundations for Evidence-Based Policymaking Act (“Evidence Act”) of 2018;
21st Century Integrated Digital Experience Act (21st Century IDEA Act);
Foreign Aid Transparency and Accountability (FATAA) Act of 2016;
Digital Accountability and Transparency (DATA) Act of 2014; and
Geospatial Data Act of 2018
As contractors collect and submit digital information in adherence to standards as defined in
this rule, USAID anticipates improvements to data quality, data interoperability, and the
Agency’s ability to integrate data across various disciplines and geographies in a way that
will greatly increase insight into programmatic performance and future scenario planning.
B. Summary of Impact
The following is a summary of the impact on contractors awarded contracts that include the
new AIDAR clause. The cost estimates were developed by subject matter experts (SMEs)
based on USAID’s experience collecting reports and information products through the DEC
(see AIDAR 752,7005) and piloting digital data collection through the DDL and the USAID
Digital Front Door.
a. Contractor costs
Total Annual Burden. This rule results in a total annualized (7% discount) public net cost of $6.5
million, as detailed in paragraphs C.2.a through k. The annual burden considers the current
baseline that contractors already prepare, maintain, and submit annual monitoring, evaluation,
and learning plans (AMELPs), already remove personally identifiable information (PII) from
data prior to submission, already collect standard indicator data, and already request embargoes
and data submission exemptions from contracting officers’ representatives (CORs) on a
case-by-case basis. Further, since contractors already submit documents and data to the DEC and
DDL, these costs were removed from the overall estimated cost.
b. Government costs
Total Annual Burden. This rule results in a total annualized (7% discount) government net cost
of $1.6 million, as detailed in paragraphs D.2.a through g. The annual burden considers the
current baseline that the government already reviews and approves data submission exceptions,
embargoes, and AMELPs.
c. Total Public and Government Cost
Across a 20-year period, the estimated total undiscounted cost for this rule will be $164 million.
The total discounted (7%) cost for this rule will be $86 million.
d. Benefits
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This rule has extensive benefits for the public, contractors, the research community, the private
sector, and the USG, though many of these benefits are challenging to quantify. Overarchingly,
this rule will increase efficiency for contractors, minimize data errors, and improve the privacy
and security of data. Further, this rule will help contractors to produce data assets that are
trustworthy, high-quality, and usable by the general public and the research community for
accountability, research, communication, and learning. For the public, there is an immense
richness in the data collected by USAID and its partners around the world, and this data holds the
potential to improve the lives of some of the world’s most vulnerable people. When a
development project ends, the data can yield new insights for years or decades into the future. It
is the responsibility of the Agency and those representing the government to ensure that data is
accessible, standardized and secure.
In addition, under current protocols, USAID contractors are required to submit digital
information to USAID under multiple award requirements using several different information
management portals. The maintenance of these separate portals has made it challenging for
USAID to integrate this information strategically to render a more holistic and detailed view of
its global portfolio. By implementing these changes, USAID intends to reduce administrative
burden on contractors and USG staff.
C. Public Cost/Cost Savings Analysis
1. Projected Public Cost
The following is a summary of the estimated public cost calculated over a 20-year period in 2016
dollars at a 7% discount rate:
Present Value Costs (in thousands of dollars)
Annualized Costs (in thousands of dollars)
Annualized Value Costs as of 2016 if Year 1 is 2021 (in thousands of dollars)
2. Cost Analysis
Data was pulled from the internal financial and contract writing systems, Federal Procurement
Data System (FPDS), and USAspending.gov for USAID with funding accounts affected by this
rule for FY2018-FY2020 to determine the number of contracts, entities and total spend.
The cost estimates were based on USAID’s experience engaging in digital data collection and
submission through the DDL, the DEC, and the USAID Digital Front Door. SMEs also drew
from their experience developing and approving data management plans and AMELPs.
a. Digital information planning
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 679 new
applicable prime contracts per year. The average period of performance for an applicable
contract is 1.9 years. USAID estimates that on average it would take one hour of training as well
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$69,275
$6,539
$4,662
as eight hours of planning and discussion to develop a digital information plan in the first year of
a contract. In subsequent years, USAID expects that it would take half that time (four hours) to
maintain and modify the plan.
Estimated cost of Digital Information Planning
Total Cost Per
Cost Per
Hours Per
Year
Actions Hour Number of Hours per Number of
Action
(Undiscounted, in
Per (Hourly
New
Action (New Ongoing (Ongoing
thousands of
Year Year
Wage) Contracts Contracts) Contracts Contracts)
dollars)
1
1
$67.66
679
9
0
4
$413
2
1
$67.66
679
9
619
4
$581
…
1
$67.66
679
9
619
4
$581
20
1
$67.66
679
9
619
4
$581
b. Data management plan (DMP) preparation, submission, and maintenance
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 679 new
applicable prime contracts per year. The average period of performance for an applicable
contract is 1.9 years.
Preparation: In order to determine what percentage of contracts will need a fully detailed DMP,
USAID used data from the FPDS. Based on these data, USAID determined that only 60% of all
applicable contracts will need a fully detailed DMP. Based on discussions with SMEs, we
estimate that the average contract that requires a fully detailed DMP generates five evaluation
data assets, five data quality assessment assets, three field-based monitoring assets, and one GIS
dataset. SMEs estimate that a contractor will spend three hours developing a DMP for every data
asset. Therefore, USAID estimates that the average contract that requires a fully detailed DMP
will spend 42 hours developing a DMP in the first year of the contract. For the other 40% of
contracts, USAID estimates that contractors will spend two hours filling out a very limited DMP.
USAID estimates that all contractors will spend two hours being trained on data management
planning in the first year of the contract.
(40% * 2) + (60% * 42) = 26 hours in the first year + 2 hours of training in first year = 28 hours
Maintenance: In subsequent years, USAID estimates that the annual maintenance of the DMP
should take half of the time originally spent in developing the DMP, or 21 hours per year, for full
DMPs. General tasks will include checking to confirm that nothing has changed between years,
adding any additional data assets as necessary, and modifying data assets that may have changed
between the previous year. For those who did not need to develop a detailed DMP, USAID
estimates that contractors will spend no hours on maintenance.
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(40% * 0) + (60% * 21) = 12.6 hours in subsequent years
Submission: USAID also estimates that submitting the DMP to the COR should not take more
than 30 minutes (0.5 hours), since it will involve emailing the DMP to the COR for review.
Estimated cost of DMP preparation, maintenance, and submission
Total Cost Per
Cost Per
Hours Per
Year
Actions Hour Number of Hours per Number of
Action
(Undiscounted, in
Per (Hourly
New
Action (New Ongoing (Ongoing
thousands of
Year Year
Wage) Contracts Contracts) Contracts Contracts)
dollars)
1
1
$67.66
679
28.5
0
13.1
$1,309
2
1
$67.66
679
28.5
619
13.1
$1,858
…
1
$67.66
679
28.5
619
13.1
$1,858
20
1
$67.66
679
28.5
619
13.1
$1,858
c. AMELP preparation, submission, and maintenance
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 196
applicable prime contracts per year. The average period of performance for an applicable
contract is 4 years.
Preparation: Based on discussions with SMEs, we estimate that the process of writing an
AMELP should take approximately 64 hours of labor.
Maintenance: After the first year, the AMELP will need to be maintained on an annual basis,
since it is a living document subject to changes based on new knowledge. We estimate that after
the first year, the annual time spent maintaining the AMELP will be 32 hours per year.
Submission: Every time that the AMELP is revised, it will need to be submitted to the
contracting officer’s representative for approval. We estimate that this submission process will
take approximately one hour per year to complete.
However, these costs are part of the baseline, as all of this labor is currently done by USAID
contractors as per contract specifications. Therefore, the costs specified above are not a new
burden on USAID contractors imposed by the rule and the net change is $0.
d. Digital data collection
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 679 new
applicable prime contracts per year. The average period of performance for an applicable
contract is 1.9 years. USAID estimates that there are approximately 3,395 subcontracts
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associated with new applicable prime contracts and 3,085 subcontracts associated with ongoing
prime contracts per year. Based on discussions with SMEs, USAID estimates that 95% of
contractors already have all digital technology necessary to comply with the clause. However,
5% of contractors, and therefore 5% of contracts, may not. For the 5% of contracts for whom it
will be necessary to invest in digital technology, the first year will involve purchasing technology
and paying for connectivity while the subsequent years will only include the cost of paying for
connectivity.
Purchase/acquire the technology: Based on discussions with SMEs, we have determined that the
average activity has around 60 enumerators. We estimate that to account for breakage and other
issues, the average activity will need to purchase about 65 tablets. The average tablet costs
around $200. Therefore, the average cost of procuring tablets for an activity would be $200 x 65
= $13,000 in the first year. Since only 5% of contracts will need to invest in digital technology,
$13,000 x 0.05 = $650 for tablet investment when averaged across all contracts.
Train staff to use digital data collection technology: We expect that staff who have never used
data collection software will need training on how to do so. We anticipate that staff will need
eight hours of training on how to operate the data collection software, including entering data
into the program, checking for errors, storing data(saving in the field), uploading and/or
aggregating collected data from multiple enumerators, and securing (encrypting) data.
0.05 of contracts * 8 * 60 enumerators for the average contract = 24 labor hours for the average
contract to spend on training enumerators on how to use digital data collection technology in the
first year of the contract. At a cost per hour of $11.73, USAID estimates that the average cost of
training in the first year will be $281.52 for a given contract.
Connectivity costs will be perpetual. Based on discussions with SMEs, we estimate 3 GB per
enumerator per month at $10 per GB. This breaks down into an average of 2 GB per month for
field enumerators and 4 GB per month for supervisors and M&E staff.
0.05 of contracts * $30 * 60 enumerators for average contract = $90 per year for average contract
Year 1: Total cost of purchasing technology + total connectivity costs +Total cost to train
enumerators =$1,021.52
Years 2 through 20: Total connectivity costs = $90
Estimated cost of digital data collection
Number of Number of
Actions Cost Per
New
Ongoing
Year Per Year New Action Contracts Contracts
1
1
$1,021.52
3,395
0
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Cost Per
Ongoing
Action
(Ongoing
Contracts)
Total Cost Per Year
(Undiscounted, in
thousands of dollars)
$90
$ 3,468
2
1
$1,021.52
3,395
3,085
$90
$ 3,746
…
1
$1,021.52
3,395
3,085
$90
$ 3,746
20
1
$1,021.52
3,395
3,085
$90
$ 3,746
e. Registration on USAID’s Digital Front Door
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 679 new
applicable prime contracts per year. The average period of performance for an applicable
contract is 1.9 years. USAID estimates that each contractor will create two user accounts per
contract, even though only one user will report indicator data quarterly. USAID estimates that
initial registration would take approximately 30 minutes per account. After the first year, USAID
estimates that contractors will create no additional accounts.
Estimated cost of registration on USAID’s Digital Front Door
Cost Per
Number of
Hours per
Actions Hour (Hourly
New
Action (New
Year Per Year
Wage)
Contracts
Contracts)
Total Cost Per Year
(Undiscounted, in
thousands of dollars)
1
2
$51.26
679
0.5
$34.81
2
2
$51.26
679
0.5
$34.81
…
2
$51.26
679
0.5
$34.81
20
2
$51.26
679
0.5
$34.81
f. Remove PII from data prior to submission
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 679 new
applicable prime contracts per year. The average period of performance for an applicable
contract is 1.9 years. Based on experience, USAID estimates that it will take around 16.25
minutes per applicable dataset to remove PII. The applicable datasets will be the type of data
being submitted to the DDL at this time. Therefore, it will take 1.08 datasets per contract per
year x 16.25 minutes per dataset = 0.29 hours per year to remove PII from applicable datasets.
However, all of this labor is currently done by USAID contractors as per contract specifications.
Therefore, the costs specified above are not a new burden on USAID contractors and the net
change in cost imposed by the rule is $0.
g.
Data submission
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 679 new
applicable prime contracts per year. The average period of performance for an applicable
contract is 1.9 years. Estimates are based on partner and staff experience during 2015, during
user experience testing, and confirmed by SMEs as still relevant in 2021. Time estimates for
each of the data processing steps are as follows:
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Development Experience Clearinghouse: 7.5 submissions per year per contract (on average) x
15 mins per submission = 1.875 hours per year per contract
Development Data Library: Detailed time estimates broken down by the standard steps of the
process are as follows:
1. Create Codebook = 250 minutes
Assumes a spreadsheet with 50 columns, requiring 5 minutes of documentation per column)
2. Convert to Non-Proprietary Format = 2.5 minutes
3. Complete Submission Form = 20 minutes
4. Upload Dataset = 12.5 minutes
Total Time Estimate = 4.75 hours (285 minutes) (summation of the five steps above)
1.1 datasets per year per contract (on average) x 4.75 hours per dataset = 5.13 hours per year per
contract
Digital Front Door: Based on the pilot, USAID estimates that USAID contractors will spend 15
mins per quarter (1 hour per year) submitting indicators via the USAID Digital Front Door = 1
hour per year per contract for indicators.
USAID also estimates that USAID contractors will spend 15 mins per quarter (1 hour per year)
submitting geospatial activity location data for every activity/contract via the Digital Front Door
= 1 hour per year per contract for geospatial data.
For all data submission, the total components sum to 9 hours per year per contract (5.13 hours
for the DDL + 2 hours for the Digital Front Door + 1.875 hours for the DEC, described above)
and 23.56 actions per contract per year. Therefore, USAID estimates that contractors will spend
0.38 hours per action per contract per year.
Estimated future cost of data submission
Total Cost Per
Actions Cost Per
Hours per
Hours Per
Year
Per Year Hour Number
Action Number of Action (Undiscounted, in
(New and (Hourly of New
(New
Ongoing (Ongoing
thousands of
Year ongoing) Wage) Contracts Contracts) Contracts Contracts)
dollars)
1
23.6
$67.66
679
0.38
0
0.38
$412
2
23.6
$67.66
679
0.38
619
0.38
$787
…
23.6
$67.66
679
0.38
619
0.38
$787
20
23.6
$67.66
679
0.38
619
0.38
$787
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However, USAID contractors are already doing the majority of this labor. The only new costs
these clauses will impose on contractors are those related to the submission of data via the
Digital Front Door. For these currently implemented components of data submission, the
components sum to 7 hours per year (5.13 hours for the DDL + 1.875 hours for the DEC,
detailed above) per contract and 15.58 actions per year per contract. Therefore, USAID estimates
that contractors currently spend 0.45 hours per action per contract per year.
Estimated current baseline of data submission
Total Cost Per
Actions Cost Per
Hours per
Hours Per
Year
Per Year Hour Number
Action Number of Action (Undiscounted, in
(New and (Hourly of New
(New
Ongoing (Ongoing
thousands of
Year ongoing) Wage) Contracts Contracts) Contracts Contracts)
dollars)
1
15.58
$67.66
679
0.45
0
0.45
$322
2
15.58
$67.66
679
0.45
619
0.45
$617
…
15.58
$67.66
679
0.45
619
0.45
$617
20
15.58
$67.66
679
0.45
619
0.45
$617
Net increase in cost of data submission (Undiscounted, in thousands of dollars)
Estimated future cost of Estimated current baseline of Net change in cost of data
Year
data submission
data submission
submission
1
$412
$322
$90
2
$787
$617
$170
…
$787
$617
$170
20
$787
$617
$170
h. Request data submission exemption from COR due to data sensitivity concerns
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 679 new
applicable prime contracts per year. The average period of performance for an applicable
contract is 1.9 years. Based on discussions with USAID Data Services statisticians who handle
data with sensitivity issues, USAID concluded that no more than 15% of all data submissions are
likely to require a request to the COR. USAID estimates that the time spent emailing the COR
regarding the exemption would be no more than 15 minutes per email. This would be 8.58
submissions per award (as described above) x .15 = 1.287 submissions per year per award x
(0.25) = 0.32 hours per year.
However, all of this labor is currently done by USAID contractors as per contract specifications.
Therefore, the costs specified above are not a new burden on USAID contractors and the net
change in cost imposed by the rule is $0.
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i. Request an embargo on the public release of the Digital Object from the COR
USAID awards an average of 679 new applicable prime contracts per year. The average period of
performance for an applicable contract is 1.9 years. Based on experience, USAID concluded
that no more than 5% of all data submissions are likely to require a request to the COR for an
embargo. USAID estimates that the time spent emailing the COR regarding the embargo would
be no more than 15 minutes per email. This would be 8.58 submissions per award (as described
above) x 0.05 = 0.43 submissions per year per award x (0.25) =0 .108 hours per year.
However, all of this labor is currently done by USAID contractors as per contract specifications.
Therefore, the costs specified above are not a new burden on USAID contractors. This
requirement is no different than prior to the rule and no additional cost is added as a result of the
rule. The net change in cost from the current baseline is $0.
j. Plan for the regular and systematic collection of feedback from beneficiaries
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 196
applicable prime contracts per year. The average period of performance for an applicable
contract is 4 years. Based on discussions with SMEs, we estimate that the process of planning for
the regular and systematic collection of feedback from beneficiaries will take eight hours in the
first year and four hours per year thereafter.
Estimated cost planning for the regular and systematic collection of feedback from
beneficiaries
Total Cost Per
Cost Per
Hours Per
Year
Actions Hour Number of Hours per Number of
Action
(Undiscounted, in
Per (Hourly
New
Action (New Ongoing (Ongoing
thousands of
Year Year
Wage) Contracts Contracts) Contracts Contracts)
dollars)
1
1
$67.66
196
8
0
4
$106
2
1
$67.66
196
8
196
4
$159
3
1
$67.66
196
8
392
4
$212
…
1
$67.66
196
8
588
4
$265
20
1
$67.66
196
8
588
4
$265
k. Collection of standard indicator data
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 196
applicable prime contracts per year. The average period of performance for an applicable
contract is 4 years. Based on discussions with SMEs, USAID estimates that the process of
collecting data for one standard indicator will take 21 hours. USAID estimates that the average
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applicable contract involves data collection for 6.4 standard indicators. This estimate is based on
review of Activity MEL plans retrieved from the USAID DEC. USAID searched the DEC for
documents with “MEL plan” in the title that were uploaded from 2018 and 2020. In total,
USAID included fifteen MEL plans in the calculation after excluding documents that were not
actually MEL plans, not MEL plans for contracts, duplicates, or MEL plans that did not provide
sufficient information on the number of standardized indicators.
Therefore, it will take 6.4 indicators per contract per year x 21 hours per contract = 134.4 hours
per year per contract to collect standard indicator data. However, all of this labor is currently
done by USAID contractors as per contract specifications. Therefore, the costs specified above
are not a new burden on USAID contractors and the net change in cost imposed by the rule is $0.
3. Assumptions
a. USAID consulted SMEs to estimate the number of hours and expertise required for
each element estimated above. For all costs per hour, USAID used a fringe factor of
1.3625, as per OMB Memo M-08-13, dated March 11, 2008. For paragraphs C.2.e,
C.2.h, and C.2.i, the cost per hour is based on the May 2019 U.S. Bureau of Labor
Statistics wage data for the mean hourly cost of Occupation Code 13-1198, Project
Management Specialists and Business Operations under NAICS Code: 541990 - All
Other Professional, Scientific, and Technical Services. For paragraphs C.2.a, C.2.b,
C.2.c, C.2.f, C.2.g, C.2.j, and C.2.k, the cost per hour is based on the May 2019 U.S.
Bureau of Labor Statistics wage data for the mean hourly cost of Occupation Code
15-2041, Statistician under NAICS Code: 541000 - Professional, Scientific, and
Technical Services. For paragraph C.2.d, we estimated that this will be done by
someone at the Foreign Junior level, since enumerators often have an undergraduate
degree. Foreign contractor and subcontractor wages in countries where the U.S.
provides development assistance are considerably lower than those paid by the U.S.
firms to its employees. Based on USAID’s experience, foreign contractors often pay
comparable or lower rates than the rates paid by the U.S. government to its local
employees in these countries. Thus, the labor rates used for foreign contractor and
subcontractor calculations are based on the compensation that the USG provides to its
locally-employed staff (referred to as Cooperating Country Nationals (CCNs))
throughout this document). To arrive at the average rate, USAID used the local rates
for the following countries: Kenya, South Africa, Nigeria, Tanzania, Uganda, Zambia,
Bangladesh and Vietnam. These countries represent locations where significant
amounts of development funds are spent across several regions.
b. The data obtained from FPDS was for applicable USAID awards between 2018 and
2020. The number of annual contract awards was relatively stable during this 3-year
period, so USAID used the average over the three years. For the contracts for which
the digital information clause is applicable, the average performance period was
estimated to be 1.91 years. For the contracts for which the AMELP clause is
applicable, the average performance period was estimated to be four years.
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c. To proxy for the percentage of contracts for which full data management plans will be
applicable, USAID used the percentage of contracts for which AMELPs are
applicable, which is 60% of contracts.
Based on discussions with SMEs, USAID assumes that only 5% of all contractors use
no field digital data collection technology (e.g. survey tools, tablets) and are starting
from scratch, but that they do have office computers. Based on these assumptions, the
average contract only has a 5% chance of needing these costs at all. USAID also
assumes that the data collection software will cost nothing, since Open Data Kit is the
standard tool and it is free. USAID also assumes a basic level of digital technology
literacy from contractors, though not specialized skills in digital data collection.
USAID estimated that there would be an average of five subcontractors per prime
contractor. This is based on a 2017 Economist analysis1 of 4,500 subcontracts since
2010 from USAID.
D. Government Cost/Cost Savings Analysis
1. Projected Government Cost
The following is a summary of the estimated Government cost calculated in over a 20
year period in 2016 dollars at a 7% discount rate:
Present Value Costs (in thousands of dollars)
$17,067
Annualized Costs (in thousands of dollars)
$1,611
Annualized Value Costs as of 2016 if Year 1
is 2021 (in thousands of dollars)
$1,149
2. Cost Analysis
Data was pulled from the internal financial and contract writing systems, FPDS, and
USAspending.gov for USAID with funding accounts affected by this rule for FY2018-FY2020
to determine the number of contracts, entities and total spend.
The cost/savings estimates were based on USAID’s experience engaging in digital data
collection and submission through the DDL, the DEC, and the USAID Digital Front Door. SMEs
also drew from their experience developing and approving DMPs and AMELPs.
a. COR review and approval of DMP
1
https://www.economist.com/international/2017/05/06/a-growing-share-of-aid-is-spent-by-private-firms-not-charities
Page 12 of 19
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 679 new
applicable prime contracts per year. The average period of performance for an applicable
contract is 1.9 years. To read through and evaluate the DMP in the first year, USAID estimates
that CORs will need to spend between 1 and 4 hours with it (average 2.5). CORs will also likely
need 2 hours of training in order to be comfortable reviewing DMPs. After the first year, CORs
will probably only spend one hour per year at most reviewing any changes to the DMP.
Estimated cost of COR review and approval of DMP
Total Cost Per
Actions Cost Per
Hours per
Hours Per
Year
Per Year Hour Number
Action Number of Action (Undiscounted, in
(New and (Hourly of New
(New
Ongoing (Ongoing
thousands of
Year ongoing) Wage) Contracts Contracts) Contracts Contracts)
dollars)
1
1
$64.56
679
4.5
0
1
$197
2
1
$64.56
679
4.5
619
1
$237
…
1
$64.56
679
4.5
619
1
$237
20
1
$64.56
679
4.5
619
1
$237
b. COR will consider and approve/deny any requests for long term alternatives to
producing/collecting data only in a digital format.
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 679 new
applicable prime contracts per year. The average period of performance for an applicable
contract is 1.9 years. USAID estimates that on average it would take two hours in the first year to
consider and approve/deny any requests and no additional time after that.
Estimated cost of COR approving/denying requests for digital data collection
Cost Per
Actions Per
Hour
Number of
Hours per
Total Cost Per Year
Year (New and (Hourly
New
Action (New
(Undiscounted, in
Year
ongoing)
Wage)
Contracts
Contracts)
thousands of dollars)
1
1
$64.56
679
2
$88
2
1
$64.56
679
2
$88
…
1
$64.56
679
2
$88
20
1
$64.56
679
2
$88
c. COR review and approval of submissions to USAID Digital Front Door
Page 13 of 19
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 679 new
applicable prime contracts per year. The average period of performance for an applicable
contract is 1.9 years.
USAID Digital Front Door: Based on discussions with SMEs, USAID estimates that CORs will
spend 1 hour per quarterly response for the Digital Front Door x 4 submissions per year = 4
hours per year per contract.
DDL: Based on discussions with SMEs and historical data from the DDL, USAID estimates that
CORs will spend 1 hour to review submission and make sure it contains all necessary artifacts
per dataset for DDL for 1.08 submissions per year on average = 1.08 hours per year per contract.
DEC: Based on discussions with SMEs and historical data from the DEC, USAID estimates that
CORs will spend 15 minutes to review every submission for (5-10) 7.5 submissions per year per
contract (on average) = 1.875 hours per year per contract.
Overall, USAID estimates that CORs will 6.955 hours per year per contract over 15.58
submissions per year = 0.45 hours per year per contract per submission.
In the initial year, we also estimate an additional 1 hour for the COR to receive training on the
specifics of the clause.
Estimated cost of COR review and approval of submissions to USAID Digital Front Door
Total Cost Per
Actions Cost Per
Hours per
Hours Per
Year
Per Year Hour Number
Action Number of Action (Undiscounted, in
(New and (Hourly of New
(New
Ongoing (Ongoing
thousands of
Year ongoing) Wage) Contracts Contracts) Contracts Contracts)
dollars)
1
15.6
$64.56
679
1.45
0
0.45
$992
2
15.6
$64.56
679
1.45
619
0.45
$1,272
…
15.6
$64.56
679
1.45
619
0.45
$1,272
20
15.6
$64.56
679
1.45
619
0.45
$1,272
d. COR review and approval of an embargo on the public release of the Digital Object
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 679 new
applicable prime contracts per year. The average period of performance for an applicable
contract is 1.9 years. Based on experience, USAID concluded that no more than 5% of all data
submissions are likely to require a request to the COR for an embargo. USAID estimates that the
time spent emailing the COR regarding the embargo would be no more than 15 minutes per
email. This would be 8.58 submissions per award (as described above) x 0.05 = 0.43 submissions
per year per award x (0.25) = 0 .108 hours per year. However, CORs already review and approve
Page 14 of 19
embargo requests prior to the public release of a Digital Object. Therefore, the costs specified
above are not a new burden on the government. As such, the estimated new burden of COR
review and approval of an embargo on the public release of the Digital Object is $0.
e. COR review and approval of AMELP
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 196
applicable prime contracts per year. The average period of performance for an applicable
contract is 4 years. Based on discussions with CORs, USAID estimates that in the first year,
CORs and other SMEs will spend about 64 hours reviewing, discussing, and getting to the point
of approval with contractors on their AMELPs. After that, the time will be significantly less,
with USAID estimating an average of 32 hours a year spent reviewing AMELPs in subsequent
years. However, CORs already review and approve AMELPs. Therefore, the costs specified
above are not a new burden on the government. As such, the estimated new burden of COR
review and approval of an AMELP is $0.
f. COR review and approval of data submission exemption due to data sensitivity concerns
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 679 new
applicable prime contracts per year. The average period of performance for an applicable
contract is 1.9 years. USAID estimates that on average it would take 15 minutes per year for a
COR to review and approve/deny a data submission exemption due to data sensitivity concerns.
Based on experience, USAID estimates that no more than 15% of all DEC and DDL submissions
require review by the COR related to data sensitivity concerns. This would be 8.58 submissions
per award x .15 = 1.287 submissions per year per award x 15 = 19.3 minutes per year. This is
0.32 hours per year. However, CORs already review and approve data submission exemptions
due to data sensitivity concerns. Therefore, the costs specified above are not a new burden on the
government. As such, the estimated new burden of COR review and approval of data submission
exemption due to data sensitivity concerns is $0.
g. COR approval of contractor registration in USAID Digital Front Door
According to data from the FPDS for years 2018 to 2020, USAID awards an average of 679 new
applicable prime contracts per year. The average period of performance for an applicable
contract is 1.9 years. USAID estimates that on average it would take 30 minutes for a COR to
approve each of two contractor registrations per contract in the USAID Digital Front Door.
Estimated cost of COR approving/denying requests for digital data collection
Cost Per
Actions Per
Hour
Number of
Hours per
Total Cost Per Year
Year (New and (Hourly
New
Action (New
(Undiscounted, in
Year
ongoing)
Wage)
Contracts
Contracts)
thousands of dollars)
1
2
$64.56
679
0.5
$44
2
2
$64.56
679
0.5
$44
Page 15 of 19
…
2
$64.56
679
0.5
$44
20
2
$64.56
679
0.5
$44
3. Assumptions
a. USAID consulted SMEs to estimate the number of hours and expertise required for
each element estimated above. For all costs per hour, USAID used a fringe factor of
1.3625, as per OMB Memo M-08-13, dated March 11, 2008. USAID calculated the
hourly rates using equivalent rates from the Office of Personnel Management (OPM)
2016 General Schedule for the rest of the U.S. locality pay.
b. The data obtained from FPDS was for applicable USAID awards between 2018 and
2020. The number of annual contract awards was relatively stable during this 3-year
period, so USAID used the average over the 3 years. For the contracts for which the
digital information clause is applicable, the average performance period was
estimated to be 1.91 years. For the contracts for which the AMELP clause is
applicable, the average performance period was estimated to be four years.
c. The Digital Front Door is being developed outside of this rulemaking effort and so
the costs are not included here.
E. Total Costs
The following is a summary of the estimated public and government costs calculated over 20
years in 2016 dollars at a 7% discount rate:
Year
Public
Government
Total
1
$5,504,189
$1,319,075
$6,823,264
2
$6,548,487
$1,639,216
$8,187,703
3
$6,601,533
$1,639,216
$8,240,749
...
$6,654,581
$1,639,216
$8,293,797
20
$6,654,581
$1,639,216
$8,293,797
Total undiscounted costs
$164,195,519
Present Value (PV) of Costs Discounted at 7%
$86,341,190
Annualized Costs Discounted at 7%
$8,149,998
Page 16 of 19
F. Benefit Analysis
In addition to the costs enumerated above, this rule has extensive benefits, though many of these
benefits are challenging to quantify.
a.
Planning
i. Digital information planning and data management planning
By planning in advance how to use digital approaches for information collection, contractors will
be prepared to use an approach that will increase their efficiency (contractors will not have to
transcribe analog surveys/interviews into digital information prior to submission to USAID),
minimize data errors (transcription errors are common), and improve the privacy and security of
data collected from beneficiaries.
DMPs as a component of data management planning, promote the management of data assets
across a full data lifecycle, and will help contractors to produce data assets for the government
that are trustworthy, high-quality, and usable by the general public and the research community
for accountability, research, communication, and learning. Some examples of the potential and
reach of the Agency’s data show that policy institutes have used these data to generate new
insights on subjects such as public-private partnerships and food security; USAID contractors
have used these data to tailor disaster interventions, respond to outbreaks of disease, and enhance
earning potential in low-income areas by sharing data on local market prices; and USAID staff
have accessed these data to analyze and adapt the Agency’s approach to foreign assistance
programming.
As an exercise, if we assume that the roughly 12,000 USAID staff spend even one hour more
than they would have had to otherwise over the course of a year trying to reuse poorly planned
digital information that is lacking in proper documentation and metadata, and we assume each
hour of their time is worth $45.29 (estimated rate for GS 11): 12,000 x 1 hour x $45.29 =
$543,480 in productivity loss per year. This is almost certainly an underestimate, since most
USAID staff use digital information and USAID staff likely spend more than an hour each trying
to work with poorly planned digital information. Some USAID staff also work with digital
information as their primary job function.
DMPs also help contractors clarify resource needs and timelines in advance of implementation,
ensuring that contractors are prepared to manage data as a strategic asset throughout the life of
their activity. Further, DMPs help contractors plan for compliance with US and local laws in
regard to the data gathered as part of a given activity. Performing risk mitigation on
well-planned data is also less costly than going through the process(es) of data cleaning,
formatting, redacting, and aggregating unplanned and poorly collected, processed and analysed
data. [Note: Simply passing on unplanned, poorly constructed data assets is not consistent with
the Evidence Act.]
Page 17 of 19
ii.
Activity MEL Plans
The AMELP describes the expected monitoring, evaluation, and Collaborating,
Learning, and Adapting (CLA) efforts of the contractor of a USAID activity over
a specified period of time. Activity MEL plans set common expectations for
USAID and contractors for determining whether an activity is making progress
toward stated results to reduce potential disagreements during implementation. By
prioritizing monitoring, evaluation, and learning tasks, the plan helps contractors
set appropriate budgets for these tasks and allocate the appropriate personnel
resources. The plan also helps contractors ensure that they have the information
needed to inform management decision-making and justify necessary adaptations
to their activity.
By specifically planning for the regular and systematic collection of feedback
from beneficiaries, contractors have the opportunity to avoid common data
collection pitfalls in regard to survey methodology, technology, and cadence.
These data, if collected well, will be instrumental in allowing contractors to
practice adaptive management throughout an activity.
Further, since 2018, the U.S. Congress has added a special provision to USAID
annual budget appropriation requiring that USAID (1) make development
assistance funds available for the regular and systematic collection of feedback
from beneficiaries, (2) provide procedures to implementing partners for
collecting, responding, and reporting on beneficiary feedback, and (3) conduct
oversight to ensure that such feedback is regularly collected and used. The
requirement for a MEL plan is a crucial step to ensuring that USAID
implementing partners incorporate the collection and reporting of beneficiary
feedback in their monitoring plans and enables USAID to conduct the oversight of
beneficiary feedback collection required by appropriation law.
b. Digital data collection
When contractors are able to collect data directly by using digital technology, they are more
accurate and efficient than when they transcribe analog surveys/interviews into digital
information prior to submission to USAID. A digital data collection approach will ultimately
produce data that are of a higher quality and more usable by the USG, research community,
private sector, and general public.
c. Submission of digital information using USAID’s Digital Front Door
Under current protocols, USAID contractors are required to submit digital information to USAID
under multiple award requirements using several different information management portals. For
example, contractors have historically submitted monitoring and indicator data to
locally-maintained information systems in overseas missions; provided periodic reports in PDF
format to the DEC (see AIDAR 752.7005); and submitted baseline, survey, and research-related
Page 18 of 19
datasets to the DDL (see USAID internal policy at ADS chapter 302.3.5.21 available at
https://www.usaid.gov/ads/policy/300/302). The maintenance of these separate portals has made
it challenging for USAID to integrate this information strategically to render a more holistic and
detailed view of its global portfolio. In addition, navigating a variety of submission formats,
websites, and business processes generates workloads that can be streamlined via modernized
technologies and techniques. USAID anticipates gathering key evidence to support evaluations
and other performance management efforts will be greatly facilitated with the centralization and
standardization of digital information that USAID contractors provide to the Agency. Further, by
implementing these changes, USAID intends to reduce administrative burden on contractors and
USG staff.
As another exercise, if we assume that the roughly 12,000 USAID staff spend even one hour
more than they would have had to otherwise looking for digital information located across
different portals and platforms and we assume each hour of their time is worth $45.29 (estimated
rate for GS 11): 12,000 x 1 hour x $45.29 = $543,480 in productivity loss per year. This is almost
certainly an underestimate and also does not take into account the potential productivity
improvements for contractors, who no longer have to submit digital information to multiple
platforms and maintain accounts on those multiple platforms.
Page 19 of 19
| File Type | application/pdf |
| File Modified | 2021-12-29 |
| File Created | 2021-12-29 |