Voglio sapere a riguardo di…

jbell on DSKJLSW7X2PROD with RULES2

Federal Register / Vol. 86, No. 114 / Wednesday, June 16, 2021 / Rules and Regulations related to NRC invoices for service fees assessed under 10 CFR part 170. First, as stated in Section 102d1 of NEIMA, the NRC must ensure appropriate review and approval prior to the issuance of invoices for service fees.
Second, as stated in Section 102d2 of NEIMA, the NRC must develop and implement processes to audit invoices for 10 CFR part 170 service fees to ensure accuracy, transparency, and fairness. Third, as stated in Section 102d3 of NEIMA, the NRC is required to modify regulations to ensure fair and appropriate processes to provide licensees and applicants an opportunity to efficiently dispute or otherwise seek review and correction of errors in invoices for service fees.
For the first two sets of actions, the NRC developed and implemented process improvements to ensure accurate invoicing, which include, but is not limited to the following: 1
Implementing a process to standardize the validation of fees to ensure that fee billing data is correct before appearing on a licensees invoice; 2 redesigning the invoices to add clarity and transparency for its stakeholders such as including the names of individual NRC
staff and/or contractor companies, if applicable, who had performed the work associated with the charges; and 3 implementing a new data structure to more effectively account for and track all billable work at the project level with an EPID data element, which provides useful details regarding the type of project or work that is being billed.
Using this data structure allows NRC
licensees and other persons assessed service fees to identify how many hours are being expended on each of the various activities within a project.
For the third set of actions, as discussed in the proposed rule, the NRC
has developed and is implementing requirements for a standard method for licensees and applicants to efficiently dispute or seek review and correction of errors in invoices, which is illustrated in the process map, NRC Form 529, Processing Dispute of Fees-For-Service Charges ADAMS Accession No.
ML20311A159. Additionally, the NRC
is modifying its regulations related to accurate invoicing to clearly outline the interactions between the submitter and the NRC and enhance clarity regarding the dispute process by setting out: 1
The process for submitting a fee dispute, 2 the stages of the decisionmaking process while the dispute is under review, and 3 the manner by which the NRC will notify a debtor after it makes a final determination on a dispute.
Finally, regarding the commenters specific comments on the regulatory
VerDate Sep<11>2014

19:08 Jun 15, 2021

Jkt 253001

activities that the NRC has previously conducted and billed to the commenter e.g., inspection activities, reports, and requests for additional information on projects, this is outside scope of this final rule. If the commenter has specific questions regarding NRC invoices and fees that have been assessed, the commenter can contact the Office of the Chief Financial Officer via the eBilling system support portal, by email to FeeBillingInquiries.Resource@nrc.gov, or by mail to the Office of the Chief Financial Officer at U.S. Nuclear Regulatory Commission, Washington, DC 205550001, Attn: Chief Financial Officer.
No change was made to this final rule in response to this comment.
Comment: NRC Form 529 on page 2
has a list of 7 pre-conditions that you must certify that you have done. One of them is I Certify that the NRC Form 527
Request for Information Related to Fees-for-Service was submitted and a response was received by my organization. Who fills out the response? Do they know the details of the work the person in dispute was performing? Weve used NRC Form 527
in the past. NRC Response did not answer the questions we had in the additional disputed details. They just confirmed the information we already knew. They confirmed that the employee did work on the project, but did not detail what work they were doing. Weve disputed bills in the past, the process only confirmed that the employee spent the hours working on the project so the charges are correct.
The CFO refused to take into account the benefit to the licensee and/or fairness of the charge to the licensee. 45
days from initial demand letter invoice is not enough time in some cases to determine if the invoice was correct, provided the licensee with a benefit, or was fair for the licensee to be charged.
It should be 90 days from when the error became apparent for the licensee to dispute the charge. For example, if you dont like the dispute resolution, what is the process for future review or appeals outside of the NRC CFO
office? Anonymous Response: The NRC continues to strive to enhance the invoicing process to ensure invoice accuracy and the availability of appropriate processes for licensees to efficiently request a review or submit a dispute for invoice errors. A
licensee who requests additional information related to NRC staff/
contract costs associated with their NRC
invoice is responsible for completing all items on page 1 of the NRC Form 527, except for the dedicated response section used by NRC staff only detailed
PO 00000

Frm 00023

Fmt 4701

Sfmt 4700

32167

instructions are provided on page 2 in addition to a process map on page 3 of the form. After the licensee completely fills out their required portions of the NRC Form 527, it should be submitted to the Office of the Chief Financial Officer using one of the three listed options on the form. Once the form is received, the Office of the Chief Financial Officer will forward it to the appropriate EPID contact who will provide the response. The NRC EPID
contact will always be the responsible point of contact who is fully knowledgeable of the work performed and, therefore, the appropriate individual to provide a response.
The NRC Form 529 contains a listing of seven pre-conditions that all licensees must meet before submitting the form. These pre-conditions ensure licensees have properly adhered to NRCs standard dispute process which requires: 1 An initial submission of the NRC Form 527 to request a formal review of the charges in question, and 2 submission of the NRC Form 529 to officially request a dispute of the charges after receiving the response provided on the NRC Form 527.
Currently, most of the NRCs licensees subject to 10 CFR part 170 fees are registered in eBilling, which is a publicfacing, web-based application that provides immediate delivery of NRC
invoices in addition to the capability to view and analyze invoice details.
Therefore, it is strongly recommended that licensees not registered in eBilling consider utilizing this electronic invoice platform, if they have the capability to do so. However, consideration was given to the current initial demand letter invoice 30-day policy, and the NRC is amending 15.31 to allow licensees an additional 15 days to submit a review request from the initial demand letter invoice. The NRC
believes that 45 days from receiving an initial demand letter provides enough time for all licensees to determine if an invoice is accurate. Furthermore, upon submission of the NRC Form 529, the licensee must certify they are submitting an official dispute request to the Office of the Chief Financial Officer and agree that the final determination of the status of the disputed debt decision rests solely with the NRC. The NRCs response to a licensees request submitted on the NRC Form 529
officially completes the agencys invoice dispute process.
Finally, regarding the commenters specific comments on the regulatory activities that the NRC has previously conducted and billed to the commenter e.g., inspection activities, reports, and requests for additional information on
E:FRFM16JNR2.SGM

16JNR2