From: American Action Forum

Dan Bosch, Dan Goldbeck



This past year was a net deregulatory one in terms of estimated costs, but across all final rules, estimated paperwork burdens increased by nearly 10 million hours. The primary reason for this disparity comes down to a single rule: The Department of Agriculture’s “National Bioengineered Food Disclosure Standard.” As seen above, this rule clocks in at number one in the “Costliest Rules” ranking with roughly $5.6 billion in present value costs. The 20.5 million hours of new paperwork requirements under the rule likely contributed heavily to this price tag. This rule is something of an outlier for the year, however, as the second most burdensome rule brings only 900,855 hours – a difference of roughly 19.6 million hours.

Looking more broadly, the year in paperwork was still rather deregulatory on the whole. If one were to exclude the bioengineered food rule, the various paperwork burden estimates in 2018 amount to approximately 10.6 million fewer hours. The rule that cut the most red tape was a Centers for Medicare & Medicaid Services (CMS) rule that cut more than 5.5 million hours. As AAF has noted before, CMS has been one of the more prodigious agencies in cutting paperwork as a part of otherwise mundane payment schedule rules. In fact, out of the top 10 rules in terms of paperwork cuts, six are CMS payment rules that collectively include nearly 11.6 million hours of paperwork reductions. Such a focus on this aspect of the administrative state likely contributed toward the Department of Health and Human Services (which houses CMS) claiming the title of “Biggest Saver” amongst agencies in fiscal year 2018.

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