Comment on FR Doc # 2026-10731

Satyadhar JoshiSupportIndividual
Summary: Satyadhar Joshi, an independent researcher, supports the proposed three-year extension of the information collection requirement for DFARS Subcontracting Policies and Procedures. He argues that the collection is necessary for defense acquisition stewardship and suggests using AI-driven automation and standardized data schemas to enhance its utility while reducing the burden on contractors.
June 17, 2026 Docket No. DARS-2026-0202 • OMB Control No. 0704-0253 To: Defense Acquisition Regulations System (DARS) Department of Defense Attn: David Johnson, 202-913-5764 www.regulations.gov Subject: Public Comment — Proposed Extension of Information Collection, DFARS Subcontracting Policies and Procedures (OMB 0704-0253) From: Satyadhar Joshi Alumnus, International MBA — Bar-Ilan University, Israel Alumnus, M.S. Information Technology — Touro College, New York, USA ORCID: 0009-0002-6011-5080 satyadhar.joshi@gmail.com Dear Mr. Johnson and the Defense Acquisition Regulations System, I write as an independent researcher to submit formal public comment on the proposed three-year extension of the information collection requirement under DFARS Subcontracting Policies and Procedures, as announced in Federal Register Volume 91, Issue 103 (May 29, 2026), FR Doc. No. 2026-10731. I support the extension of this collection. Contractor purchasing system oversight under DFARS Part 244 and clause 252.244-7001 is a foundational instrument of defense acquisition stewardship, and the authority it confers on administrative contracting officers to approve, condition, or disapprove contractor purchasing systems is essential to cost control, supply chain integrity, and mission readiness. Summary of Comments My comments address all four areas invited by the notice. In brief: Necessity and utility. The collection is necessary and should be extended. Its practical utility can be substantially enhanced through AI-enabled continuous monitoring and machine-readable standardized reporting formats. Burden estimate accuracy. The 8-hour average per response (372 total annual hours for 22 respondents) likely understates the true burden for prime contractors managing complex, multi-tier supply chains. A stratified burden analysis by contractor size and purchasing system complexity is recommended. Enhancing quality, utility, and clarity. A standardized, machine-readable data schema for DFARS Part 244 responses—analogous to XBRL tagging in financial reporting—would enable automated cross-contractor analysis and substantially increase the analytical value of the information collected. Minimizing burden through automation. AI-driven continuous purchasing system monitoring, automated data aggregation, and intelligent response-generation tools could reduce respondent burden by an estimated 50–70% within three to five years of adoption, while simultaneously improving information quality and timeliness. I attach hereto a full academic paper, “Artificial Intelligence for Corporate Governance in the U.S. Defense Industrial Base: A Scholar-Practitioner Framework for Accountability, Ethics, and National Security,” which develops these comments in detail, grounds them in established governance theory, and provides specific implementation recommendations for DoD and the contractor community. I appreciate the opportunity to contribute to this important policy discussion and welcome any follow-up questions. Respectfully submitted, Satyadhar Joshi Independent Researcher ORCID: 0009-0002-6011-5080 June 17, 2026

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