Moreover, when Congress passed the NTTAA
, small business witnesses testified that significant costs--including traveling to SDO meetings--impeded their participation in SDO standards development.
Another example of the impact of the OMB Circular A-119 and the NTTAA can be found in examining the Department of Defense policies on standards.
amp; BUDGET, EXECUTIVE OFFICE OF THE PRESIDENT, OMB CIRCULAR A-119, FEDERAL PARTICIPATION IN THE DEVELOPMENT AND USE OF VOLUNTARY CONSENSUS STANDARDS AND IN CONFORMITY ASSESSMENT ACTIVITIES (1998) (revised to conform to NTTAA standards) [hereinafter OMB Circular A-119].
This is evidenced by the implementation of the NTTAA and revised OMB Circular A-119.
71) Accordingly, this would mean that later, when the AHRQ moves from general to specific in formulating regulations on cardiac care, if the AHRQ chooses to regulate the number of PTCA a patient receives in the name of quality, if it is at all possible, the AHRQ is directed by the NTTAA
to adopt the NQF's industrial driven consensus guidelines.
Small businesses complained about just this problem when Congress enacted the NTTAA.
A-l 19 and the NTTAA was to reduce complexity from governmental standards that overlap with, but that cover largely similar ground to, privately developed standards.
287) Indeed, Congress's enactment of a statutory preference for voluntary consensus standards in the NTTAA implicitly recognizes that agencies generally possess a range of regulatory choices.
IMPLEMENTATION PLAN, supra note 254, at 5-15.