I wonder if you have any other suggested reading on US regulatory analysis processes?
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Specifically: Having read circular A-4 I am somewhat confused by US regulatory analysis. Circular A-4 only covers various forms of cost benefit assessment. But where is all the rest of the regulatory analysis? Is that it? Like where is the assessment of quality of evidence, or the assessment of how easy it is to review and change, or the assessment of risk? Surely A-4 is not the complete regulatory analysis process? There must be something else right?
For example in the UK policy makers have access to guidance on a range of topics that A-4 doesn’t even touch on such as:
Analysis of things like “Strategic dimension: What is the case for change, including the rationale for intervention? What is the current situation? What is to be done? What outcomes are expected? How do these fit with wider government policies and objectives? Management dimension: Are there realistic and robust delivery plans? How can the proposal be delivered?” (here in the Green Book)
Analysis guidance includes at least some (minimal) advice on topics such as generating a long-list of option or adjusting the results to account for common biases of researchers
On the regulatory/executive side, there are several executive orders besides 12866 that contain analytical requirements. OMB has issued other guiding documents like this, and the GAO has its own Greenbook. And some agencies have adopted their own guidelines and requirements.
We chose to highlight A-4 because the most recent Executive Order calling for alterations to these processes specifically cited Circular A-4 as a potential target for alteration.
I wonder if you have any other suggested reading on US regulatory analysis processes?
– –
Specifically: Having read circular A-4 I am somewhat confused by US regulatory analysis. Circular A-4 only covers various forms of cost benefit assessment. But where is all the rest of the regulatory analysis? Is that it? Like where is the assessment of quality of evidence, or the assessment of how easy it is to review and change, or the assessment of risk? Surely A-4 is not the complete regulatory analysis process? There must be something else right?
For example in the UK policy makers have access to guidance on a range of topics that A-4 doesn’t even touch on such as:
Analysis of things like “Strategic dimension: What is the case for change, including the rationale for intervention? What is the current situation? What is to be done? What outcomes are expected? How do these fit with wider government policies and objectives? Management dimension: Are there realistic and robust delivery plans? How can the proposal be
delivered?” (here in the Green Book)
Analysis guidance includes at least some (minimal) advice on topics such as generating a long-list of option or adjusting the results to account for common biases of researchers
There is much more guidance on what good regulatory policy should look like to support good decisions making. Like the Regulators Code (and papers such as Regulation for the Fourth Industrial Revolution, the Regulatory Futures Review.)
Does anything similar exist in the US?
Thanks for this question as well. You’re right that other regulations, statutes, and advisory documents guide how regulatory analysis is conducted.
On the statutory side there is the Regulatory Flexibility Act, the Unfunded Mandates Reform Act, the Paperwork Reduction Act, and the Information Quality Act, to name a few.
On the regulatory/executive side, there are several executive orders besides 12866 that contain analytical requirements. OMB has issued other guiding documents like this, and the GAO has its own Greenbook. And some agencies have adopted their own guidelines and requirements.
We chose to highlight A-4 because the most recent Executive Order calling for alterations to these processes specifically cited Circular A-4 as a potential target for alteration.