Administration and Management

Recommendation 2016-1 – Consumer Complaint Databases encourages agencies that make consumer complaints publicly available through online databases or downloadable data sets to adopt and publish written policies governing the dissemination of such information to the public.

Recommendation 2011-3 – Government Contractor Ethics addresses the increasing use of contractors in government and asks the Federal Acquisition Regulation Council to adopt revisions regarding compliance standards for government contractor employees relating to personal conflicts of interest and use of certain non-public information.  In February 2013, the American Bar Association’s House of Delegates adopted a...

Statement #18 – Improving the Timeliness of OIRA Regulatory Review (Adopted December 6, 2013) highlights potential mechanisms for improving review times of rules under review by the Office of Information and Regulatory Affairs (OIRA), including promoting enhanced coordination between OIRA and agencies prior to the submission of rules, encouraging increased transparency concerning the reasons for delayed reviews, and...

Recommendation 2011-5 – Incorporation by Reference addresses ways in which agencies publish rules that refer to standards or other materials that have been published elsewhere.

Recommendation 2012-8 – Inflation Adjustment for Civil Penalties addresses agency adjustments to civil monetary penalties under the Federal Civil Penalties Inflation Adjustment Act (28 U.S.C. 2461 note). The recommendation urges Congress to change the current statutory framework by which agencies periodically adjust their penalties to address three provisions that result in penalty adjustments that may not track the...

Recommendation 2012-4 – Paperwork Reduction Act addresses a variety of issues that have arisen since the Act was last revised in 1995, including those arising from the emergence of new technologies. The proposal offers suggestions for improving public engagement in the review of information collection requests and for making the process more efficient for the agencies and OMB.