Commentary Archive

Interim Final Rules

Interim Final Rules Over Time: A Brief Empirical Analysis

September 25, 2014

Although there are well known benefits associated with public participation during the pre-promulgation stage, interim final rulemaking represents an important mechanism through which agencies can respond to exigent circumstances, such as natural disasters or impending statutory or judicial deadlines, much more expediently than would otherwise be possible. To evaluate whether IFRs have become more common in recent years or otherwise exhibit clear trends of interest, we examined OIRA’s executive order review data on all significant final rules published by executive branch agencies between 1994 and 2013. While there is no clear directional trend over time, on average, IFRs represent 20.3% of all significant final rules published during the period in question.

New Study by NAM

New study finds federal regulation costs over $2 trillion per year and disproportionately affects small businesses

September 10, 2014

The costs of regulation, both individually and in the aggregate, are notoriously hard to measure. Unlike the direct costs of government programs, which are tracked through the fiscal budget, there is no mechanism for keeping track of the off-budget costs imposed by regulation. Thus, to get a clearer picture of the impact of regulations, it is important to examine those impacts through different lenses using different measurement tools, even though none of those approaches is perfect.