David Versus Godzilla: Bigger Stones

September 13, 2019


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For nearly four decades, U.S. presidents have issued executive orders requiring agencies to conduct comprehensive regulatory impact analysis (RIA) for significant regulations to ensure that regulatory decisions solve social problems in a cost-beneficial manner. Yet experience demonstrates that agency RIAs often fail to live up to the standards enunciated in executive orders and Office of Management and Budget guidance. We suggest four managerial changes that could increase OIRA’s leverage:  (1) Define what counts as success when a regulation is adopted and link this to the agency’s strategic goals, (2) Use budget recommendations to enforce analytical requirements and achievement of agency GPRA objectives, (3)  Combine regulatory budgets with agency budgets, and (4) Reward results, not activity.