This comment offers two specific suggestions in response to issues that OMB sought comment on: Area 2 (Barrier and Burden Reduction) and Area 5 (Stakeholder and Community Engagement).
- Area 2 focuses on “[a]pproaches and methods for assessing and remedying barriers, burden, and inequities in public service delivery and access.” Updating OMB’s guidance or regulations implementing the Paperwork Reduction Act (PRA) is a concrete step that OMB could take to improve agency and public consideration of the way government paperwork burdens serve as barriers to the public.
- Area 5 calls for “[a]pproaches and methods for accessible and meaningful agency engagement with underserved communities.” Considering different forms of public engagement across the entire regulatory development timeline, and not just during the Administrative Procedure Act public comment period, could deliver equity and engagement improvements in both the process itself and resulting regulatory outcomes.
"The Office of Management and Budget should be commended for its initiative to seek public comments on the issues presented in the Equity RFI."
Bridget C.E. Dooling
GW Regulatory Studies Center