Increased OIRA Staffing is the Prerequisite for Real, Lasting Regulatory Reform

From: National Affairs

Regulation Beyond Structure and Process

Andrew Rudalevige


Reagan’s staff publicly downplayed its inheritance. But Jim Miller, the former CWPS analyst who became OIRA’s first chief, privately wrote to OMB deputy director Ed Harper that “[o]ur program will build on the successes of the accounting and paperwork reduction programs,” adding that it could now, “for the first time, make real changes in the substance” of regulations. If they found such success, it would be because “when Reagan issued the executive order, we had an infrastructure, which is very important,” as Tozzi later said: “[W]e had a system in place.” Indeed, despite OMB’s embrace of the Paperwork Reduction Act generally, the office viewed OIRA as unnecessary: Under Carter, the agency had already reorganized twice around regulatory and paperwork tasks, and by 1980 it boasted a 45-person Office of Regulatory and Information Policy.


Given the inevitability of political pressures, real, lasting regulatory reform will require long-term resources — including expert staff and complex internal procedures that provide autonomy, organizational leverage, and a reputation for using that leverage, all of which are necessary for institutionalizing regulatory review. Proponents of cost-effective government — both inside and outside of government — need to back not just reforms on paper, but the resources needed to implement reforms in practice.

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