Jennifer Nou on Internalizing Cost-Benefit Analysis

Internalizing Cost-Benefit Analysis
Jennifer Nou
Penn Regblog
February 18, 2014

Before an agency completes a cost-benefit analysis (CBA) subject to oversight by the White House Office of Information and Regulatory Affairs (OIRA), or by the courts if an agency decision is litigated, what forms of internal review of that analysis should the agency undertake on its own?

One increasingly common practice is for agencies to establish a centralized review office or officer charged with examining the internal cost-benefit figures developed by the agency’s rule-writing staff.  Examples of such offices include the Environmental Protection Agency’s(EPA) Office of Policy or the Bureau of Economic Analysis within theFederal Trade Commission (FTC).  These internal agency CBA reviewers are often trained economists who work closely with agency policymaking officials to evaluate internal CBAs before they ever