One mechanism that scholars have suggested for improving the quality of regulatory analysis is to increase the use of peer review. This analysis addresses some of the particular peer review procedures discussed in “OMB’s Proposed Bulletin on Peer Review and Information Quality.” In general, we think that the OMB bulletin makes some good points, but we also think peer review is not without its problems as a method for improving regulatory analysis.
We recommend that OMB develop a method for evaluating the effectiveness of efforts to implement this new peer review initiative. If, in cooperation with the regulatory agencies, it cannot develop a reasonable approach to evaluation, we recommend that it probably should not proceed with this effort. Finally, we suggest that a congressional office of regulatory assessment is more likely to improve regulatory analysis than the introduction of the kind of peer review contemplated here.