2. Executive Office of the President · Minor
Separate OIRA advance-consultation staff from rule reviewers
Printed page 49 2. Executive Office of the President
“To preserve the integrity of OIRA review, the staff who consult at the beginning of a rulemaking should not handle its eventual review.”
What has happened
- Not started
OIRA has not separated the staff who consult early from the staff who review. Its most detailed statement of practice in the window, M-25-36, does the opposite: under the heading "Engaging in Early and Substantive Discussions with OIRA on Deregulatory Actions" it encourages agencies to "work with OMB, the public, and the interagency community to identify, preview, and develop deregulatory actions", and directs them to keep their OIRA desk officer informed of progress — the same desk officer who will handle the eventual review. No memorandum or notice in the window erects the firewall the Quote asks for.
Research log
What was searched, and what didn’t count as evidence
Research notes
Negative search. Read M-25-20, M-25-24 and M-25-36 in full; searched the OMB memoranda index M-25-10 to M-26-17. Searches of the federal records we keep and search for “desk officer” and “advance consultation” return nothing relevant. This is an internal staffing practice and might be adopted without publication, but the one document that discusses early consultation describes a single point of contact rather than two.
- Action
- other
- Object
- OIRA review staffing practice
- ID
- 50