What Kind of Analysis Does OIRA Conduct? [No. 86]
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What Kind of Analysis Does OIRA Conduct? [No. 86]

There’s a popular misconception that OIRA
does the cost-benefit analysis. That it prepares the regulatory impact analysis,
the RIA, which is the technical term for the document that accompanies the and Notice and
the final rule that assesses the costs and the benefits. In fact, it’s the agencies who are tasked
with developing the RIA with compiling the information for the cost-benefit analysis. OIRA reviews it. OIRA, which is staffed with a number of economists,
will check the assumptions, will look at the calculations, the methodology. I’ve often compared OIRA review at this stage
of that of a PhD professor who is supervising a doctoral candidate. It’s the candidate who comes up with the subject
matter. Here, the agency comes up with the subject
matter in the proposal. The agency then does the research. The professor doesn’t do the research, but
the professor can advise on the research. The professor can be aware of a body of research
somewhere else or look at the research and question whether it’s complete or not. The doctoral candidate is the one who writes
the chapters. OIRA doesn’t write the chapters like a doctoral
advisor or professor doesn’t write the document, but can read it and say, “The hypothesis in
Chapter 1 is different than the hypothesis in Chapter 3.” Or, “The solution that you’re proposing in
chapter 4 does not really meet the issue that you set up in Chapter 2.” It’s this kind of dispassionate review that
OIRA can provide as a professor can. I think OIRA review is important because I
think a dispassionate, objective second opinion is always salutary. An OIRA review is also, as I mentioned earlier,
in the executive office of the President and is closer, physically and psychologically,
to the President than any other agency and can provide that political perspective. Can provide the sensitivity and reflect the
priorities and preferences of the administration. This is appropriate in a democracy because
elections have consequences. You will have different presidents, with different
priorities, and they should be reflected in the work product of the agencys for which
he’s responsible. An OIRA review provides that type of dispassionate
but knowledgeable review.

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