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Comments to OIRA on their 2012 Annual Report

Today we submitted comments in response to OIRA’s annual report to Congress. Among the several specific suggestions is that the employment impacts of regulations be integrated into cost-benefit analysis in a balanced, transparent way. We recommend that OIRA should be careful to avoid any language that reinforces the mistaken belief that regulations inevitably lead to unemployment and that any analysis should do its best to model net employment impact, not just one region or sector.

Also among our recommendations is that OIRA should try to use retrospective review to pursue balanced, evidence-based, and data-driven decisionmaking—not just cost-cutting at the agencies. While regulatory look-backs is an opportunity to reduce paperwork burdens—that is just the lowest-hanging fruit. More can be done to expand rules where revision could increase efficiency, to evaluate areas of agency inaction, and to update estimates of costs and benefits. Currently, agency plans give little attention to these important goals.

Interagency coordination figured prominently into our comments as well. We suggest that OIRA work with other OMB Offices (like E-Government) to promote the collection, interoperability, and sharing of data, in addition to other ways agencies can more seamlessly collaborate. Sharing data and resources usually maximizes taxpayer dollars and improves the efficiency of government programs.