Revision of Circular A-4 Is Warranted to Reflect the Advances in Scholarship Relevant to Regulatory Analysis, but Some Caveats Are in Order
Joseph J. Cordes
What the paper says
Abstract This article is based on comments that I submitted to the Office of Management and Budget (OMB) as one of eight peer reviewers of OMB’s 2023 draft revisions to Circular A-4, “Regulatory Analysis.” Since that time, OMB issued a final version of Circular A-4, which was then rescinded in January 2025. This article summarizes some of my main comments on the 2023 draft version that I submitted as a peer reviewer, along with a “prologue” that summarizes some of the main issues raised in my peer review and an “epilogue” recognizing both the initial revision of Circular A-4 that was initially adopted, as well as the 2025 decision to rescind the revised version and return to the 2003 version of the circular. The 2003 Circular continues to provide useful guidance, but could have been improved by expanding the scope of regulatory impact analysis in ways discussed in my peer review comments.
Evidence weight
Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40
| F · citation impact | 0.50 × 0.4 = 0.20 |
| M · momentum | 0.50 × 0.15 = 0.07 |
| V · venue signal | 0.50 × 0.05 = 0.03 |
| R · text relevance † | 0.50 × 0.4 = 0.20 |
† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.