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February 25, 2026Journal of Benefit-Cost AnalysisOpen Access

Revision of Circular A-4 Is Warranted to Reflect the Advances in Scholarship Relevant to Regulatory Analysis, but Some Caveats Are in Order

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Authors

JCJoseph J. Cordes

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Overview

Comments critique regulatory impact analysis in Circular A-4, highlighting necessary revisions and implications.

Key Points

  • The aim is to evaluate and recommend necessary updates to Circular A-4 based on recent scholarship and regulatory practices.
  • Provided peer review comments on OMB’s 2023 draft revisions
  • Summarized main issues from the initial draft and final rescinded version
  • Discussion of the 2003 Circular's guidance and areas for improvement
  • Identified that the 2023 draft had valuable insights that could enhance regulatory impact analysis
  • Highlighted the importance of adapting guidance to reflect current scholarship
  • Noted concerns over the decision to revert to the 2003 version of Circular A-4

Cite This Study

Joseph J. Cordes (2026) studied this question.

synapsesocial.com/papers/699e918df5123be5ed04f159https://doi.org/10.1017/bca.2025.10036
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