June 6, 2023 — Comments

This coalition comment, led by the Leadership Conference on Civil and Human Rights, supports the Office of Information and Regulatory Affairs’ recent proposed revisions to the federal regulatory process (as announced in Circular A-4 and Circular A-94). The proposed revisions are much-needed updates that will help the government make policies that respond to the needs and realities of people in this country. Critically, the proposed revisions would:

  • Incorporate income-weighting into the assessment of costs and benefits of government actions. Doing so recognizes an obvious truth: that the gain or loss of one dollar has very different consequences for a low-income worker than it does for a millionaire.
  • Increase focus on distributional effects, so that the government fully understands who would pay the costs and who would receive the benefits of government actions and can guard against actions that may seem like a good idea on paper but would end up benefiting those who need them least and costing those who can least afford to pay.
  • Modernize the assessment of future costs and benefits by reducing the extent to which future benefits are discounted. Many important policies may require immediate investments but reap long-term benefits. For example, reforms related to education, affordable housing, health care, and the criminal justice system may impose costs now but pay tremendous benefits in the future.