by John D. Graham, James W. Broughel
June 13, 2014
U.S. federal regulatory agencies have been escaping oversight. They have engaged in regulatory-like actions while avoiding requirements outlined by the Administrative Procedure Act (APA) and regulatory oversight by the Office of Information and Regulatory Affairs (OIRA) of the U.S. Office of Management and Budget (OMB). The United States has built an impressive system of regulatory oversight procedures over the last sixty years. This system exists to ensure that the public is adequately represented by its government and that agencies act in the public interest. To ignore the procedures put in place over the last century is not just to ignore good public policy practices; it is to ignore the unfortunate lessons of history and to run the risk of repeating them.