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Does Process Matter
Regulatory Procedure and Regulatory Output in the States
Rulemaking in the states has become much more widespread than it was when many state legislatures began to pass their administrative procedures acts more than 40 years ago. A wide diversity of rulemaking procedures presents a natural laboratory in which to study several questions that have long interested scholars of the regulatory process. This paper finds that the level of rulemaking is more closely correlated to the lawmaking activity in the state rather than proceduralization which suggests no disrespect for the law, as Churchill argued, but rather that the lawmakers themselves have given rise to the thousands of regulations in the states.
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Can Cost-Benefit Analysis of Environmental Policy Go Global?
The use of cost-benefit analysis of environmental policy is spreading from the United States, where it has the longest tradition, to other parts of the globe. This paper discusses the challenges posed for cost-benefit analysis as it spreads, and how it can evolve to meet those challenges.
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Letter to HHS on Proposed Transparency Reporting Rule
Policy Integrity submitted a letter today to the Department of Health and Human Services on its upcoming Transparency Reporting rule, mandated by the Affordable Care Act of 2010. The rule would develop uniform disclosure standards for group health plans and health insurance issuers, requiring them to provide consumers with new, more detailed information on likely co-pays for particular plans or treatments; providers would also have to provide consumers with a document that summarizes benefits and explains coverage clearly in four pages or less.
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Comments on Preliminary Plans for Periodic Retrospective Reviews of Existing Regulations
In January, President Obama issued a call for all federal agencies to review their existing regulations, looking for rules that had grown outdated, ineffective, or insufficient over time. Back then, there was much discussion over whether the move was a gift to business or a robust defense of strong protections even in a downturned economy.
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Dr. Adam Finkel Gives Congresional Testimony on Regulations
Policy Integrity advisor Dr. Adam Finkel recently answered questions from Rep. Renee Ellmers (R-NC) on regulations and their effect on jobs and businesses as part of testimony given during a House Committee on Small Business hearing.
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Letter to HUD on Proposed Homeownership Education Counseling Standards
Policy Integrity submitted a letter today to the Department of Housing and Urban Development (HUD) on its proposal to adopt the National Industry Standards for Homeownership Education Counseling as mandatory, industry-wide requirements. The new regulations would primarily function as a government-certified labeling program, comparable in some respects to the USDA’s National Organic Program or EPA’s Energy Star program. The standards represent a significant effort on part of the homeownership counseling industry to ensure quality and consistency nationwide and, by using them as a template, HUD has a head start on crafting regulations that could provide significant benefits to individuals and families looking to navigate the complex process of buying and financing a home.
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Dr. Adam Finkel Gives Congressional Testimony on Regulation and Jobs
Policy Integrity advisor Dr. Adam Finkel recently answered questions from Rep. Renee Ellmers (R-NC) on regulations and their effect on jobs and businesses as part of testimony given during a House Commitee on Small Business hearing.
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Obama Administration’s Retrospective Review Plan
Yesterday, the Obama Administration announced the plans from thirty agencies to conduct retrospective review of regulations—a step towards following up on a presidential executive order issued in January.
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Petition to BOEMRE on Option Value
This morning, Policy Integrity petitioned the Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE) to reconsider its leasing policies, which may encourage over-drilling. The topic is the Outer Continental Shelf Lands Act’s (OCSLA) requirement of the Secretary of the Interior to develop five-year schedules that specify the timing for offshore leasing activity.
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Comments to Agencies on Retrospective Review
In addition to submissions to the Department of Energy and the Environmental Protection Agency, Policy Integrity also sent our recommendations on developing policies for conducting retrospective reviews to fourteen additional agencies this week, including the Department of the Interior (DOI), the Department of Justice (DOJ), the Small Business Administration (SBA), and the State Department.
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