OIRA reviews apply to all the executive branch agencies and that includes both the department, the cabinet agencies, like the Department of Human Health and Services, but also agencies like the Environmental Protection Agency, which is not part of the cabinet department but is a cabinet level executive branch agency. And let me just pause a minute to explain what that review looks like. Partly, it's an inter-agency review. It's an opportunity for other agencies in the government that may have information of an interest or be affected by one agency's regulation. It gives them an opportunity to weigh in and that helps make sure that there aren't duplicative or redundant or conflicting regulations. That doesn't mean we still don't find there are duplications in regulations because there are, but it helps try to reduce that. So that's one part of the review. Another part of the review is to make sure that the agency's supporting analysis. OIRA is a very small staff, but they have expertise in statistics and economics and law and policy analysis and they will review that regulatory impact analysis that agencies have developed. And then a third part of that review is that OIRA is part of the executive office of the president so it is a career staff that is within this executive office of the president that has a lot of policy officials, political officials. So the third aspect of that review is ensuring that the regulations meet the president's priority, are consistent with the president's priorities as well as being consistent with the law. OIRA review does not apply, at least as of yet, to independent regulatory agencies, so the Securities and Exchange Commission for example. It issues its regulations without going through that inter-agency review process and OIRA review and oversight over the analysis supporting it and scholars have demonstrated that the regulatory impact analysis that the independent agencies conduct when developing their regulations is not as robust as the executive branch agencies, which is what you'd expect because there isn't an entity that is holding them accountable for developing that regulatory analysis.

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