Over at the GW Regulatory Studies Program, Mark Febrizio, Sarah Hay, and Zhoudan (Zoey) Xie have published a comparison of the draft and final Circular A-4 revisions, which were published last week. Here’s the description of the project:
Following a public comment period earlier this year, the Office of Information and Regulatory Affairs (OIRA) in the Office of Management and Budget (OMB) issued a final updated version of Circular A-4 on November 9, 2023, along with an Explanation and Response to Public Input. This new version updates the original Circular A-4 from 2003 pursuant to Executive Order 14094, “Modernizing Regulatory Review.” Starting March 1, 2024, the updated Circular A-4 will apply for all proposed rules, direct final rules, and interim final rules. It will apply to other final rules starting January 1, 2025.
We have compared the draft Circular A-4 from April 6, 2023 with the final Circular A-4. Both versions are similar in length, containing over 90 pages (or over 40,000 words) of guidance on various aspects of regulatory analysis. This Insight highlights the differences and similarities in each section between the April draft Circular A-4 and the November final version. For an in-depth comparison of the original Circular A-4 and the current material, please reference our initial comparison.
You can check out the full post and materials here.