The Washington Report

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April 17, 2019

Legislative/Executive

Congress on Two-Week Recess
Congress left for April recess on April 11, 2019, and is scheduled to return the week of April 29.

OMB Requires Guidance Documents to Undergo Economic Impact Review
On April 11, 2019, the Office of Management and Budget (OMB) issued a memorandum in which it directs federal agencies to submit nonbinding guidance documents to it for review. According to the memorandum, the process of review set up under the Congressional Review Act (CRA) applies to more than just notice-and-comment rules and encompasses guidance documents, general statements of policy, and interpretive rules. In addition, the memorandum requires agencies to notify the OMB’s Office of Information and Regulatory Affairs (OIRA) of upcoming rules on a regular basis and to provide their analysis as to whether the upcoming rules are deemed to be major (including economic impact review). OIRA will then review each rule and the analysis provided and inform the agencies as to OIRA’s designation of the rule as major or not major. The memorandum also states that all agencies are subject to the CRA, with certain limited rule exceptions. The memorandum takes effect on May 11, 2019.

The OMB memorandum is available here.