The document, authored by Bridget C.E. Dooling and Susan E. Dudley for the Council on Government Relations, outlines the U.S. federal regulatory process and examines its implications for academic research. Beginning with an overview of the regulatory lifecycle—from congressional authorization, agency rule development, and public comment, through executive and judicial review—the document highlights the multiple layers of oversight, particularly the roles of the Office of Management and Budget (OMB) and the Office of Information and Regulatory Affairs (OIRA). Key executive orders, including EOs 12866, 13563, and more recent ones from the Trump administration (EOs 13771 and 13777), are discussed in terms of their requirements for cost-benefit analyses, deregulatory mandates, and formal coordination of regulatory and deregulatory actions.
The document notes several challenges in overseeing and reviewing regulations that impact academic research, such as difficulties in defining what constitutes a "rule" versus other binding terms, and the complexity of assessing and managing the entire stock of research-related regulations. It highlights that while OIRA reviews certain rules and guidance documents, many policy instruments affecting research escape centralized scrutiny, creating gaps in accountability and coherence. Despite these challenges, the authors identify potential opportunities for reform, including the establishment of a Research Policy Board, leveraging the Paperwork Reduction Act, and initiatives from governmental offices aimed at improving the regulatory framework for research. Proposals for further structural change, such as creating an ombudsman role, are also mentioned as ways to enhance the effectiveness of regulations while minimizing unnecessary burdens on academic institutions.
