Revising Regulatory Review: Expert Insights on the Biden Administration’s Guidelines for Regulatory Analysis
Tue, 9 May, 2023
10:30am - 3:00pm
On May 9, the GW Regulatory Studies Center and the Society for Benefit-Cost Analysis offered a timely discussion of recent changes to regulatory practices and analysis.
In April, the White House released much-anticipated revisions to federal regulatory practices, including a new Executive Order 14094 on “Modernizing Regulatory Review,” draft revisions to OMB Circular A-4 governing regulatory impact analysis, and draft guidance on meetings with entities outside of the executive branch. The Office of Information and Regulatory Affairs (OIRA) is working to implement these changes, which comprise the most significant regulatory policy initiatives of the Biden administration and raise interesting benefit-cost analysis issues, including the appropriate discount rate, who has standing in a benefit-cost analysis, and how distributional impacts should be measured.
At this forum, OIRA Administrator Richard Revesz discussed these changes with a panel of former OIRA administrators who served in the Clinton, Bush, Obama, and Trump administrations. That was followed by a panel of experts experienced in regulatory impact analysis at the federal level who explored in more depth the draft changes to Circular A-4.
Welcome and Introduction
Emily Hammond, GW Vice Provost for Faculty Affairs
Panel 1: Discussion with OIRA Administrators
Photos
Welcome and introduction by
Opening remarks from Richard Revesz, Administrator, Office of Information and Regulatory Affairs
Richard Revesz (Biden Admin)
Paul Ray (Trump Admin)
Boris Bershteyn (Obama Admin)
Susan Dudley (Bush Admin)
Sally Katzen (Clinton Admin)
Moderated by Bridget Dooling, former OIRA deputy branch chief
Panel 2: Expert Discussion on Circular A-4
Photos
Welcome and introduction by GW professor and RSC Co-Director Joseph Cordes
Howard Beales (former FTC bureau director)
Randy Lutter (former FDA chief economist)
Dominic Mancini (OIRA deputy administrator)
Sabeel Rahman (former Biden OIRA)
Shayna Strom (former Obama OIRA)
Moderated by Caroline Cecot (George Mason University professor)
Closing Remarks
Christopher Carrigan (George Washington University professor and RSC Co-Director)
Additional Resources
- Executive Order 12866 of September 30, 1993
- Executive Order 14094 of April 6, 2023
- Request for Comments on Guidance Implementing 12866 Meeting Request Provisions of EO 14094
- Request for Comments on Revisions to Circular A-4
- Request for Comments on Revisions to Circular A–94
- Request for Nominations of Experts to Peer-Review Draft Guidance on Conducting Analysis of Federal Regulations
- Susan E. Dudley for Regulation & Governance (July 2020): The Office of Information and Regulatory Affairs and the Durability of Regulatory Oversight in the United States
- White House Moves to Modernize Regulatory Review, Bridget Dooling for the Yale JREG Notice & Comment blog, April 6, 2023
- Modernizing Regulatory Review Actions, Susan Dudley, April 7, 2023
- Regulatory Review Revisited, Susan Dudley for Forbes, April 13, 2023
- Circular Reasoning? By Susan Dudley for Yale JREG Notice & Comment blog. May 25, 2023
- Public Interest Comment: Distributional Weights Should Be Dropped from the Draft Circular A-4, Mary Sullivan, May 31, 2023
- Public Interest Comment: OMB Draft Circular A4: Safeguarding Objective and Evidence-Based Principles for Regulatory Impact Analysis, Susan Dudley, June 14, 2023
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Weighing Regulatory Tradeoffs – And Keeping Thumbs Off The Scales! By Susan Dudley for Forbes.com. June 30, 2023
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OMB Guidance Needs More Humility. By Susan Dudley for Forbes.com. July 11, 2023
