- Jim Tozzi — A central architect of centralized White House regulatory review. His work at OMB helped build the institutional machinery that eventually became OIRA, and he later played an important role in the development of the Information Quality Act. His contribution is especially significant because it concerns the institutional architecture of regulatory oversight.
- Christopher DeMuth — As OIRA Administrator under President Reagan, helped establish the newly created OIRA as an operating institution and implement the Reagan administration’s regulatory-review program.
- Sally Katzen — As OIRA Administrator during the Clinton administration, helped transform centralized review from something strongly associated with Republican deregulation into a durable, bipartisan institution.
- Cass Sunstein — As Obama’s OIRA Administrator and through his scholarship, substantially advanced the intellectual case for cost-benefit analysis, behavioral economics, and evidence-based regulatory review. Cass Sunstein
- Susan Dudley — Important both as OIRA Administrator and as an academic leader in regulatory studies, particularly in advancing economic analysis and retrospective evaluation of regulation.
- Richard Revesz — As Biden’s OIRA Administrator, associated with the most substantial recent revision of the federal regulatory-analysis framework, including modernization of Circular A-4 and changes in how benefits, costs, distributional effects, and discounting are analyzed. Richard Revesz
There is also a presidential dimension: Jimmy Carter, Ronald Reagan, Bill Clinton, Barack Obama, Donald Trump, and Joe Biden each made consequential changes to regulatory policy through executive orders. Reagan’s Executive Order 12291 (1981) is particularly important because it established systematic centralized review and benefit-cost requirements across executive agencies.
Who had the greatest impact?
I would distinguish institution-building from subsequent development.
For institution-building, Jim Tozzi has an unusually strong claim. The regulatory-review system developed at OMB in the 1970s and early 1980s became the foundation on which later OIRA administrators operated. DeMuth, Katzen, Sunstein, Dudley, and Revesz substantially changed or strengthened that system, but they largely worked within the centralized-review structure that had already emerged.
A reasonable historical ranking by lasting structural influence would therefore put Tozzi in the first tier, followed by figures such as DeMuth, Katzen, and Sunstein, with the exact ordering depending on whether one values institutional creation, economic methodology, bipartisan durability, or later modernization most heavily.
