Journal Title
Title of Journal: Policy Sci
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Abbravation: Policy Sciences
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Authors: Stuart Shapiro
Publish Date: 2007/12/11
Volume: 41, Issue: 1, Pages: 33-49
Abstract
The notice and comment rulemaking process is a fundamental part of how agencies write regulations While this process is starting to receive more empirical attention the question of how the number of comments that an agency receives affects its decisionmaking process has received little examination This paper uses Boolean analysis to examine nine rules from two agencies at the Department of Health and Human Services and evaluates the impact of a high volume of comments on agency changes to proposed rules and the time an agency takes to finalize a proposed rule These nine cases suggest that agencies are most likely to change their proposals when they receive a high volume of comments on highly complex rules that are not very politically salient Highly complex rules are also likely to take a long time to finalize when there are many public comments however it is often other factors that cause a long delay between proposed and final rulesI would like to thank Anne Gowen and William West for commenting on earlier drafts of this paper I would also like to thank Mookhan Kim and Michael Schubert for valuable research assistance and officials at the Food and Drug Administration and the Administration for Children and Families for taking valuable time to discuss the regulations in this paper All errors are of course my responsibility
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