Federalism: Previous Initiatives Have Little Effect on Agency Rulemaking

Published by the Government Accountability Office on 1999-06-30.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                          United States General Accounting Office

GAO                       Testimony
                          Before the Subcommittee on National Economic Growth,
                          Natural Resources, and Regulatory Affairs, Committee on
                          Government Reform, House of Representatives

For Release on Delivery
Expected at
10:00 a.m., EST
on Wednesday
June 30, 1999

                          Previous Initiatives Have
                          Little Effect on Agency
                          Statement of L. Nye Stevens
                          Director, Federal Management and Workforce Issues
                          General Government Division


Federalism: Previous Initiatives Have Little
Effect on Agency Rulemaking

                           Mr. Chairman and Members of the Committee:

                           I am pleased to be here today to discuss H.R. 2245, the “Federalism Act of
                           1999.” The bill addresses a number of issues affecting intergovernmental
                           relations, including the use of federal grant funds, legislative requirements,
                           agency rulemaking requirements, and performance measurement for state-
                           administered federal grant programs. My comments are directed to the
                           agency rulemaking and performance measurement requirements.

                           I will focus most of my comments on two previous executive and
                           legislative branch initiatives that, like section 7 of the bill, were designed
                           to highlight the impact of federal rules on state and local governments. Our
                           past work showed the limited effect of those previous initiatives during the
                           period of our review, which suggests a need for this section of the
                           proposed legislation. I will also point out a few similarities and differences
                           between the bill and these regulatory reform initiatives. Finally, I will
                           briefly comment on the experience of one agency in cooperatively setting
                           the type of goals and performance measures with states in a federal grant
                           program that are contemplated in section 6 of the bill.

                           During the past 20 years, state, local, and tribal governments as well as
Executive Order and        businesses have expressed concerns about congressional and regulatory
UMRA Had Little            preemption of traditionally nonfederal functions and the costs of
Effect on Agencies’        complying with federal regulations. The executive and the legislative
                           branch have each attempted to respond to these concerns by issuing
Rulemaking Actions         executive orders and enacting statutes requiring rulemaking agencies to
                           take certain actions when they issue regulations with federalism or
                           intergovernmental relations effects. Two prime examples of these
                           responses are Executive Order 12612 (“Federalism”) and the Unfunded
                           Mandates Reform Act of 1995 (UMRA).

Few Federalism             Executive Order 12612, issued by President Reagan in 1987, established a
                           set of fundamental principles and criteria for executive departments and
Assessments Prepared       agencies to use when formulating and implementing policies that have
Under Executive Order      federalism implications. The executive order says that federal agencies
12612 Between April 1996   should refrain from establishing uniform, national standards for programs
and December 1998          with federalism implications, and when national standards are required,
                           they should consult with appropriate officials and organizations
                           representing the states in developing those standards. The order says that
                           regulations and other policies have federalism implications if they “have
                           substantial direct effects on the States, on the relationship between the
                           national government and the States, or on the distribution of power and
                           responsibilities among the various levels of government.”

                           Page 1                                                       GAO/T-GGD-99-131
Federalism: Previous Initiatives Have Little Effect on Agency Rulemaking

Executive Order 12612 also contains specific requirements for agencies.
For example, the order requires the head of each agency to designate an
official to be responsible for ensuring the implementation of the order.
That official is required to determine which proposed policies have
sufficient federalism implications to warrant preparation of a “federalism
assessment.” The assessment must contain certain elements (e.g., identify
the extent to which the policy imposes additional costs or burdens on the
states) and must accompany any proposed or final rule submitted to the
Office of Management and Budget (OMB) for review under Executive
Order 12866. OMB, in turn, is required to ensure that agencies’ rulemaking
actions are consistent with the policies, criteria, and requirements in the
federalism executive order.

In May 1998, President Clinton issued Executive Order 13083
(“Federalism”), which was intended to replace both Executive Order 12612
and Executive Order 12875 (“Enhancing the Intergovernmental
Partnership”). However, in August 1998, President Clinton suspended
Executive Order 13083 in response to concerns raised by state and local
government representatives and others about both the content of the order
and the nonconsultative manner in which it was developed. Therefore,
Executive Order 12612 remains in effect.

To determine how Executive Order 12612 had been implemented in recent
years, we reviewed (1) how often the preambles to covered agencies’ final
rules issued between April 1, 1996, and December 31, 1998, mentioned the
executive order and how often they indicated the agencies had conducted
federalism assessments under the order; (2) what selected agencies have
done to implement the requirements of the order; and (3) what OMB has
done to oversee federal agencies’ implementation of the order in the

 Executive Order 12612 actually refers to rulemaking procedures under Executive Order 12291, which
was revoked and replaced by Executive Order 12866 in 1993. Because only “significant” rules are
submitted to OMB for review under Executive Order 12866, federalism assessments for nonsignificant
rules are not required to be submitted to OMB. For a description of the review process under this
order, see Regulatory Reform: Implementation of the Regulatory Review Executive Order (GAO/T-96-
185, Sept. 25, 1996).
 Executive Order 12875, among other things, requires federal agencies to “develop an effective process
to permit elected officials of state, local, and tribal governments to provide meaningful and timely
input in the development of regulatory proposals containing significant unfunded mandates.”
 It is unclear whether Executive Order 12612 covers regulations and other policies issued by
independent regulatory agencies, such as the Federal Communications Commission and the Securities
and Exchange Commission. Therefore, we focused our review on executive departments and agencies
that are not independent regulatory agencies.

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                                Federalism: Previous Initiatives Have Little Effect on Agency Rulemaking

                                rulemaking process. We focused on the April 1996 through December 1998
                                time frame because we were able to use our database to identify which
                                rules were “major” under the Small Business Regulatory Enforcement
                                Fairness Act (SBREFA) (e.g., those that have a $100-million impact on the
                                economy). As a result, we cannot comment on rules issued outside of that
                                time frame. Although Executive Order 12612 does not require agencies to
                                mention the order in the preamble to their final rules or to note in those
                                preambles whether a federalism assessment was prepared, doing so is a
                                clear indication that the agency was aware of and considered the order’s
                                requirements. Also, if an agency prepared a federalism assessment for a
                                final rule, it would be logical for the agency to describe the assessment in
                                the preamble to the rule.

Agencies Prepared Few           Our work showed that Executive Order 12612 had relatively little visible
Federalism Assessments During   effect on federal agencies’ rulemaking actions during this time frame. To
Review Timeframe                summarize the nearly 3 years of data depicted in figure 1, agencies covered
                                by the order mentioned it in the preambles to about 26 percent of the
                                11,414 final rules they issued between April 1996 and December 1998.

                                Federalism: Implementation of Executive Order 12612 in the Rulemaking Process (GAO/T-GGD-99-93,
                                May 5, 1999).

                                Page 3                                                                     GAO/T-GGD-99-131
                                         Federalism: Previous Initiatives Have Little Effect on Agency Rulemaking

Figure 1: Agencies Indicated Only Five
Final Rules Issued Between April 1996
and December 1998 Had Federalism

                                         Note: The data for 1996 covers only those rules issued from April 1 to December 31.
                                         Source: Federal Register and GAO analysis.

                                         Five agencies issued the bulk of the final rules published during this
                                         period—the Departments of Agriculture (USDA), Commerce (DOC),
                                         Health and Human Services (HHS), and Transportation (DOT); and the
                                         Environmental Protection Agency (EPA). As figure 2 shows, these
                                         agencies varied substantially in the degree to which they mentioned the
                                         executive order. For example, DOT mentioned the order in nearly 60
                                         percent of its nearly 4,000 final rules, whereas EPA did not mention the
                                         order in any of the more than 1,900 rules it issued.

                                         Page 4                                                                         GAO/T-GGD-99-131
                                        Federalism: Previous Initiatives Have Little Effect on Agency Rulemaking

Figure 2: Agencies Differed In Degree
to Which They Mentioned Executive
Order 12612 in Final Rules Issued
Between April 1996 and December 1998

                                        Source: Federal Register and GAO analysis.

                                        However, mentioning the order in the preamble to a rule does not mean
                                        the agency took any substantive action. The agencies usually just stated
                                        that no federalism assessment was conducted because the rules did not
                                        have federalism implications. Nearly all of these statements were standard,
                                        “boilerplate” certifications with little or no discussion of why the rule did
                                        not trigger the executive order’s requirements.

                                        In fact, the preambles to only 5 of the 11,414 final rules that the agencies
                                        issued between April 1996 and December 1998 indicated that a federalism
                                        assessment had been done—2 in 1996 and 3 in 1997. Those five rules are
                                        listed in table 1.

                                        Page 5                                                                 GAO/T-GGD-99-131
                                        Federalism: Previous Initiatives Have Little Effect on Agency Rulemaking

Table 1: Preambles Indicated Four
Agencies Issued Five Final Rules With                                  Date final rule
Federalism Assessments Between April    Department or agency           was published Title
1996 and December 1998                  Department of Health and       Aug. 28, 1996 Regulations Restricting the Sale and
                                        Human Services                                 Distribution of Cigarettes and Smokeless
                                                                                       Tobacco to Protect Children and
                                        Department of                  Dec. 16, 1996
                                        Transportation                                 Roadway Worker Protection
                                        Department of Commerce         Jan. 30, 1997   Florida Keys National Marine Sanctuary
                                                                       Mar. 28, 1997   Hawaiian Islands Humpback Whale
                                                                                       National Marine Sanctuary
                                        Department of Labor            Mar. 31, 1997   (Hazard) Abatement Verification
                                        Source: Federal Register and GAO analysis.

                                        Many of the final rules that federal agencies issue are administrative or
                                        routine in nature, and therefore unlikely to have significant federalism
                                        implications. As a result, it is not particularly surprising that agencies
                                        would not prepare federalism assessments for many of those rules.
                                        However, rules that are “major” under SBREFA and that involve or affect
                                        state and local governments would seem more likely to have federalism
                                        implications that would warrant preparation of an assessment.

                                        However, that does not appear to have been the case. As figure 3 shows, of
                                        the 117 major final rules issued by covered agencies between April 1996
                                        and December 1998, the preambles indicated that only 1 had a federalism
                                        assessment. The agencies had previously indicated that 37 of these rules
                                        would affect state and local governments, and the preambles to 21 of the
                                        rules indicated that they would preempt state and local laws in the event of
                                        a conflict. At least one of the four state and local government organizations
                                        that we consulted during the review said that federal agencies should have
                                        done assessments for most of these 117 major rules. In response, the
                                        agencies said that their rules did not have sufficient federalism
                                        implications to trigger the executive order’s requirements.

                                        Page 6                                                                 GAO/T-GGD-99-131
                                       Federalism: Previous Initiatives Have Little Effect on Agency Rulemaking

Figure 3: Only One Major Rule Issued
Between April 1996 and December 1998
Had A Federalism Assessment

                                       Sources: Federal Register and GAO’s major rule database.

EPA Established High Threshold         All three of the agencies we visited during our review (USDA, HHS, and
for Federalism Assessments             EPA) had some kind of written guidance on the executive order and had
                                       designated an official or office responsible for ensuring its
                                       implementation. However, the criteria the agencies used to determine
                                       whether federalism assessments were needed varied among the agencies.
                                       USDA’s guidance did not establish any specific criteria, with agency
                                       attorneys making their own determinations regarding federalism
                                       implications in the context of each rulemaking. HHS’ guidance listed four
                                       threshold criteria that could be used to determine whether a federalism
                                       assessment was required, but said an assessment must be prepared if an

                                        The agencies we visited were those with the most major rules that state and local government
                                       representatives believed should have had a federalism assessment.

                                       Page 7                                                                          GAO/T-GGD-99-131
                                Federalism: Previous Initiatives Have Little Effect on Agency Rulemaking

                                action would directly create significant effects on states even if the action
                                was mandated by law or the department otherwise had no discretion.

                                The criteria in EPA’s guidance established a high threshold for what
                                constitutes “sufficient” federalism implications—perhaps explaining why
                                none of the agency’s more than 1,900 final rules issued during the April
                                1996 to December 1998 time frame had a federalism assessment. For
                                example, in order for an EPA rule to require an assessment, the agency’s
                                guidance said the rule must meet all four of the following criteria:

                              • have an “institutional” effect on the states, not just a financial effect
                                (regardless of magnitude);
                              • change significantly the relative roles of federal and state governments in a
                                particular program context, lead to federal control over traditional state
                                responsibilities, or decrease the ability of states to make policy decisions
                                with respect to their own functions;
                              • affect all or most of the states; and
                              • have a direct, causal effect on the states (i.e., not a side effect).

                                At least one of these criteria appeared to go beyond the executive order on
                                which it is based. Although EPA said a rule must affect all or most of the
                                states in order to have sufficient federalism implications to warrant
                                preparation of an assessment, Executive Order 12612 defines “state” to
                                “refer to the States of the United States of America, individually or
                                collectively.” (Emphasis added.) EPA’s guidance also said that, even if all
                                four of these criteria are met, a rule would not require a federalism
                                assessment if a statute mandates the action or the means to carry it out are
                                implied by statute. However, EPA’s actions appear to be allowable because
                                the executive order does not define what is meant by “sufficient”
                                federalism implications, leaving that determination up to the agencies.

OMB Has Taken Little Recent     OMB officials told us that they had taken little specific action to ensure
Action to Ensure                implementation of the executive order, but said the order is considered
Implementation of Executive     along with other requirements as part of the regulatory review process
Order 12612                     under Executive Order 12866. They said that agencies had rarely submitted
                                separate federalism assessments to OMB but have addressed federalism
                                considerations, when appropriate, as a part of the cost-benefit analysis and
                                other analytical requirements.

                                Commenting on the results of our review, the Acting Administrator of
                                OMB’s Office of Information and Regulatory Affairs said it was not
                                surprising that agencies were not focused on implementing Executive
                                Order 12612 during the covered time period because they knew that the

                                Page 8                                                                 GAO/T-GGD-99-131
                            Federalism: Previous Initiatives Have Little Effect on Agency Rulemaking

                            order was soon to be revised by Executive Order 13083. However, he also
                            said that Executive Order 12612 had not been implemented to any
                            significant extent by the Reagan Administration “or its successors,”
                            suggesting that the lack of implementation was unrelated to any pending
                            revision of the order. In addition, the Acting Administrator said that the
                            primary vehicles for improving federal-state consultation in the past 6
                            years have been Executive Order 12875 and UMRA. We have not examined
                            the implementation of Executive Order 12875. However, we have
                            examined the implementation of UMRA, and concluded that it has had
                            little effect on agencies’ rulemaking activities.

UMRA Had Little Effect on   Title II of UMRA is one of Congress’ primary efforts to address the effects
                            of federal agencies’ rules on state and local governments. Section 202 of
Agency Rulemaking           the act generally requires federal agencies (other than independent
                            regulatory agencies) to prepare “written statements” containing specific
                            information for any rule for which a notice of proposed rulemaking was
                            published that includes a federal mandate that may result in the
                            expenditure of $100 million or more in any 1 year by state, local, and tribal
                            governments, in the aggregate, or the private sector. UMRA defines a
                            “mandate” to be an “enforceable duty” that is not a condition of federal
                            assistance and does not arise from participation in a voluntary federal
                            program. For rules requiring a written statement, section 205 requires
                            agencies to consider a number of regulatory alternatives and select the one
                            that is the least costly, most cost-effective, or least burdensome and that
                            achieves the purpose of the rule. Other sections of the act focus even more
                            specifically on the interests of state and local representatives. For
                            example, section 203 states that agencies must develop plans to involve
                            small governments in the development of regulatory proposals that have a
                            significant or unique effect on those entities. Section 204 requires agencies
                            to develop processes to consult with representatives of state, local, and
                            tribal governments in the development of regulatory proposals containing
                            “significant [f]ederal intergovernmental mandates.”

                            Last year, we reported that these and other requirements in title II of
                            UMRA appeared to have had only limited direct impact on agencies’
                            rulemaking actions in the first 2 years of the act’s implementation. Most of
                            the economically significant rules promulgated during UMRA’s first 2 years
                            were not subject to the written statement requirements of title II. Some did
                            not have an associated notice of proposed rulemaking that triggered the
                            act’s requirements. Many did not impose an enforceable duty other than as

                             Unfunded Mandates: Reform Act Has Had Little Effect on Agencies’ Rulemaking Actions (GAO/GGD-
                            98-30, Feb. 4, 1998).

                            Page 9                                                                     GAO/T-GGD-99-131
                         Federalism: Previous Initiatives Have Little Effect on Agency Rulemaking

                         a condition of federal financial assistance or as a duty arising from
                         participation in a voluntary program. Other rules did not result in
                         “expenditures” of $100 million. Because no written statement was required
                         for these rules, the requirements in section 205 regarding the identification
                         and selection of regulatory alternatives were not applicable to these rules.
                         Also, title II of UMRA contains exemptions that allowed agencies not to
                         take certain actions if they determined the actions were duplicative or not
                         “reasonably feasible.”

                         Other provisions in title II also had little effect. During the first 2 years of
                         UMRA’s implementation, the requirement in section 204 that agencies
                         develop an intergovernmental consultation process appears to have
                         applied to no more than four EPA rules and no rules from other agencies.
                         EPA generally used a consultation process that was in place before UMRA
                         was enacted. Also, section 203 small government plans were not developed
                         for any of the 73 final rules promulgated during this 2-year period. Officials
                         in the four agencies that we contacted said none of their final rules had a
                         significant or unique effect on small governments.

                         Section 208 of UMRA requires the Director of OMB to submit an annual
                         report to Congress on agency compliance with UMRA. The fourth such
                         report is scheduled to be delivered within the next few weeks. In his third
                         UMRA report published in June 1998, the OMB Director noted that federal
                         agencies had identified only three rules in the more than 3 years since the
                         act was passed that affected the public sector enough to trigger the written
                         statement requirements. Nevertheless, he said federal agencies had
                         embraced the act’s “overall philosophy,” as evidenced by the range of
                         consultative activities the report described.

                         On its surface, H.R. 2245 contains several provisions that are similar to
Federalism Act Similar   requirements in both Executive Order 12612 and UMRA. For example,
to But Different From    section 7 of the bill would, if enacted, require agencies to publish
Previous Initiatives     “federalism impact assessments” that are somewhat similar in content to
                         the federalism assessments in the executive order and the written
                         statements required by UMRA. All of those assessments and statements
                         require agencies to develop estimates of the costs attendant to the
                         implementation of the regulation at issue. Also, both the bill and the
                         executive order require identification of regulatory provisions that
                         preempt state government authority or functions.

                         As introduced, the bill would require federalism impact assessments for all
                         proposed and final rules. We understand that the bill may be modified to
                         require, for each such rule, that agencies either certify that the rule does

                         Page 10                                                                GAO/T-GGD-99-131
                        Federalism: Previous Initiatives Have Little Effect on Agency Rulemaking

                        not have federalism implications or prepare a federalism impact
                        assessment. Neither Executive Order 12612 nor UMRA requires agencies
                        to declare whether each of their proposed and final rules has federalism
                        implications. As I noted previously, UMRA does not apply to most
                        economically significant rules, and the executive order does not require
                        agencies to publish the designated officials’ federalism determinations.

                        If the bill is modified in this manner, this requirement will be similar to a
                        provision in the Regulatory Flexibility Act of 1980 (RFA), which requires
                        agencies to state whether their rules have a “significant economic impact
                        on a substantial number of small entities.” Therefore, the implementation
                        of the RFA may prove instructive as to how this portion of the bill will be
                        implemented. For example, according to the Small Business
                        Administration’s (SBA) Office of Advocacy, a perennial problem with the
                        implementation of the RFA has been agencies’ use of “boilerplate”
                        certifications indicating that their rules do not have a significant economic
                        impact on a substantial number of small entities. Contributing to this
                        problem is the fact that the RFA does not define the terms “significant
                        economic impact” and “substantial number of small entities,” and no
                        federal agency is responsible or authorized to define the terms. As a
                        consequence, different agencies have different interpretations of the
                        statute. We have recommended that Congress consider giving SBA or
                        some other entity the responsibility or authority to define key terms in the
                        act. Therefore, applying the lessons of the RFA to the proposed
                        legislation, Congress may want to carefully define what it believes
                        constitutes “federalism implications” or assign that responsibility to some
                        other entity.

                        Finally, I would like to briefly comment on section 6 of H.R. 2245, which
Consultation Enhances   says that federal agencies may not include any agency activity that is a
Intergovernmental       state-administered federal grant program in its annual performance plans
Partnership             developed pursuant to the Government Performance and Results Act of
                        1993 (Results Act) “unless the performance measures for the activity are
                        determined in cooperation with public officials.” The bill defines “public
                        officials” as elected officials of state and local governments, including
                        certain organizations that represent those officials (e.g., the National
                        Governors’ Association and the United States Conference of Mayors).

                         Regulatory Flexibility Act: Inherent Weaknesses May Limit Its Usefulness for Small Governments
                        (GAO/HRD-91-16, Jan. 11, 1991).
                         Regulatory Reform: Implementation of the Small Business Advocacy Review Panel Requirements
                        (GAO/GGD-98-36, Mar. 18, 1998).

                        Page 11                                                                        GAO/T-GGD-99-131
Federalism: Previous Initiatives Have Little Effect on Agency Rulemaking

The Results Act already requires agencies developing their strategic plans
to “solicit and consider the views and suggestions of those entities
potentially affected by or interested in the plan.” The Senate Governmental
Affairs Committee report on the Results Act noted that the strategic plan
“is intended to be the principal means for obtaining and reflecting, as
appropriate, the views of Congress and those governmental and
nongovernmental entities potentially affected by or interested in the
agencies’ activities.”

In that regard, we believe that working with state and local governments or
their representative organizations to develop goals and performance
measures in federal grant-in-aid programs can strengthen the
intergovernmental partnerships embodied in those programs. For example,
in 1996, we reported on a joint goal and performance measure-setting
effort between the federal Office of Child Support Enforcement (OCSE)
and state governments. Initially, the federal-state relationship was not so
cooperative. In 1994, OCSE specified the performance levels that states
were expected to achieve in such areas as the establishment of paternity
and collections of child support. State program officials strongly objected
to this federal mandate because they did not have an opportunity to
participate in the planning process.

Following these initial planning efforts, OCSE sought to obtain wider
participation from program officials at the federal, state, and local
government levels. OCSE also established task forces consisting of federal,
state, and local officials to help focus management of the program on long-
term goals. During the planning process, participants agreed that the
national goals and objectives would be based on the collective suggestions
of the states and that the plan’s final approval would be reached through a
consensus. For each goal, the participants identified interim objectives
that, if achieved, would represent progress toward the stated goal. At the
time of our review, OCSE and the states were also developing performance
measures to identify progress toward the goals, and planned to develop
performance standards to judge the quality of state performance. They
created a Performance Measures Work Group to develop statistical
measures for assessing state progress toward achieving national goals and
objectives. OCSE also encouraged its regional staff to develop
performance agreements with states, specifying both general working
relationships between OCSE regional offices and state program officials
and performance goals for each state.

 Child Support Enforcement: Reorienting Management Toward Achieving Better Program Results
(GAO/HEHS/GGD-97-14, Oct. 25, 1996).

Page 12                                                                    GAO/T-GGD-99-131
Federalism: Previous Initiatives Have Little Effect on Agency Rulemaking

Overall, OCSE and most state officials that we contacted said the joint
planning process strengthened the federal/state partnership by enabling
them to help shape the national program’s long-term goals and objectives.
State and local government stakeholder involvement has also been
important in the development of practical and broadly accepted
performance measures in other federal programs, including some block
grants. We believe that these kinds of intergovernmental cooperation can
serve as models for the kinds of efforts that section 6 of the Federalism
Act of 1999 seeks to encourage.

Mr. Chairman, this completes my prepared statement. I would be pleased
to answer any questions.

Contacts and Acknowledgment
For future contacts regarding this testimony, please contact L. Nye Stevens
at (202) 512-8676 or Curtis Copeland at (202) 512-8101. Individuals making
key contributions to this testimony included Elizabeth Powell, Joseph
Santiago, and Alan Belkin.

 Managing for Results: Measuring Program Results That Are Under Limited Federal Control
(GAO/GGD-99-16, Dec. 11, 1998); Grant Programs: Design Features Shape Flexibility, Accountability,
and Performance Information (GAO/GGD-98-137, June 22, 1998).

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