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What to Provide to OMB

What to Provide to OMB. History of the rule Problem to be addressed Quantitative and qualitative analysis “Significant Regulatory Action” under 12866(3)(f) Reason regulation is the best solution. What to Provide to OMB. Alternatives analysis Expected benefits Secondary benefits

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What to Provide to OMB

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  1. What to Provide to OMB • History of the rule • Problem to be addressed • Quantitative and qualitative analysis • “Significant Regulatory Action” under 12866(3)(f) • Reason regulation is the best solution

  2. What to Provide to OMB • Alternatives analysis • Expected benefits • Secondary benefits • Undesirable side-effects • Justification for chosen alternative

  3. What to Provide to OMB • Summary of comments received (when applicable) • Offer a briefing for complex or economically significant rulemakings

  4. Analytical Approach • Benefit-cost analysis (BCA) • Cost-effectiveness analysis (CEA) • Major rulemakings should be supported by both, when possible

  5. Analytical Approach • If quantified information on benefits is not available, present qualitative discussion of issues and evidence. • Base analysis on best scientific, technical, economic, or other information available.

  6. Analytical Approach • OMB does not require any specific measure of effectiveness • Explain: • measure selected • reason why • how implemented

  7. Things OMB Looks For ... • Consistency • with regulatory principles of E.O. 12866 • with administration policy • between rule and preamble • Compliance • with Administrative Procedures Act • with other requirements (Paperwork Reduction Act, etc.)

  8. Coordinated Review • Rules are shared with subject matter experts within OMB when necessary

  9. Preliminary issues to note: • Collects or disseminates information about individuals • Security or other IT related issues • Statistical standards • Information quality concerns • Risk assessment

  10. Tips to Remember • Rulemaking package should be complete and accurate • Seek and consider opinions of those affected or with special knowledge • Good analysis is transparent • Use easy to understand language

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