1. Should the cumulative cost of regulations imposed by federal regulators be capped? Why or why not? What mechanism, if any, should be used to set such a cap on compliance costs?

2. Should OIRA’s regulatory review role be expanded to include independent agencies? Discuss the political, legal, and/or economic implications of such an expansion.

3. DOJ has informed the court that OIRA is the ultimate decision-maker on Requests for Correction filed pursuant to the Data Quality Act. What are the implications of this decision? Should the DOJ change its position that decisions made with respect to the Data Quality Act are not judicially reviewable?

4. The Administrative Procedure Act delineates the federal rulemaking process. Does an examination of its history demonstrate that it is a simple codification of the then existing rulemaking process or was it aimed at providing a shield to assaults on New Deal programs? If the latter, does such a finding argue for an expansion of OIRA’s role?

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Question-Specific References

Cumulative Cost of Regulations

OIRA Review of Independent Agency Regulations

OIRA: The Court of Last Resort for DQA Petitions

A History of the APA

General References

The OIRA Teaching Module

Restoring OIRA’s Entrepreneurial Roots

What is OIRA?

Mission of the OIRA Teaching Module

The Need for an OIRA Teaching Module

The Reg Map: Informal Rulemaking

ABA Rulemaking

 Overview of the Rulemaking Process

The Federal Rulemaking Process

A Brief Review of Rulemaking and Judicial Review

The Evolution of OIRA and Centralized Regulatory Review

The OMB Papers

The Courts

Justice Kagan

Judge  Ginsburg

Our Libraries

The OIRA Teaching Module

Global Search of All CRE Libraries