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Comments to ACUS on its 56th Plenary Session

Policy Integrity submitted comments to ACUS (Administrative Conference of the United States) regarding various proposed recommendations to be considered at its 56th Plenary Session. As an independent federal agency that works to improve federal agency procedures, ACUS held its biannual assembly to discuss and vote on recommendations around issues such as regulatory analysis requirements, midnight rules, and coordination of multi-agency responsibilities.

Our comments on regulatory analysis requirements include suggestions on offering more concrete guidance on how to tailor requirements to reduce unnecessary burdens and improve efficiency. On midnight rules we urge that the practice of misclassifying significant rules as non-significant to avoid analytical or review requirements in the midnight period be guarded against. Such rules should undergo due consideration and analysis rather than being allowed to slip under the radar.

Finally, we also call upon ACUS to make it easier for the public to comment on its proposals. ACUS can do this by making it easier to find proposed recommendations and committee draft reports and making it clearer when the public should submit its comments.