Safeguarding Objective and Evidence-Based Principles for Regulatory Impact Analysis

GW Regulatory Studies Center Director Susan Dudley shares her perspectives on the OMB Draft Circular A4. Susan emphasizes the durability of regulatory impact analysis under the existing circular across administrations dating back nearly 30 years. Although the draft revisions contain some worthwhile updates, Susan explains that some aspects of the draft appear designed to steer analytical results to support this administration’s policy preferences, rather than present objective evidence and estimates to policy makers and the public. Safeguarding the objectivity and durability of regulatory analysis is key for the circular's value going forward.

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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• Request for Nominations of Experts to Peer-Review Draft Guidance on Conducting Analysis of Federal Regulations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