4 Comments

It would need be agency level and akin to the OIG or it'd be so inundated with requests. Also there would need to be tons of SMEs available because a small cadre wouldn't have the necessary context always.

But sure for big examples, this would be a positive step.

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Some myths are worth protecting, or rather, there is agency value in protecting them. Such a myth includes the hoary claim that OMB routinely blocks agency Information Collection Requests submitted under the PRA. Not so. OMB approves 4,000 to 5,000 ICRs per year, which means they spend on average maybe 30 seconds on each one. They disapprove a mere handful. But blaming OMB is a normal agency practice. This is why the optimal sample size is nine. (Ten triggers the PRA.)

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Not sure about those numbers. 4,000 would be 2 per hour (there are 2,000 working hours in the year--40 hours a week for 50 weeks). Did you mean to say 30 minutes rather than 30 seconds?

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1. That team could also collect and publish case studies that might demonstrate the context for the conservatism behind the broad scale cautions. The Tuskegee syphilis study is a US example, in research, that casts a long shadow.

2. the specifically general approach to law making, and the specific circumstances in which those general rules are intended to be applied. The Chevron decision in the US supreme court has sent a message of what is expected of the legislators. To the extent that work is not being done quickly enough - this team that you describe could create the industry body example of field-specific-acceptable standards that participants could pledge to uphold whilst the executive branch deals with its clarifications.

3. Australia's NHMRC once published its fundable, not funded outcomes (applications which would have been funded if the resources were available), This was a signal to industry/philanthropy to look at research that a panel of gov experts had assessed as credible. That got shut down. There is no extra effort involved in capturing this information. Withholding it imposes an extra costs on assessors from small, private teams, who don't have the breadth of bench that the gov can use in initial assessments. This is an example of a positive contribution which the gov could make (subject to consents etc) to foster engagement with the broader set of stakeholders.

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