Unleashing Prosperity Through Deregulation

January 31, 2025

Presidential Actions

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Action Summary

Purpose: Reduce the significant economic and compliance burdens of federal regulations to promote economic growth, innovation, and national security by mandating a rigorous regulatory budgeting process.
Ten-for-One Principle: For each new regulation proposed, agencies must identify at least 10 existing regulations for elimination, ensuring that new regulatory costs are offset by reductions in current rules.
Fiscal Year 2025 Cap: Agencies must ensure that the total incremental regulatory costs for 2025 are significantly less than zero, as monitored by the Director of the Office of Management and Budget.
Annual Regulatory Submissions: Starting in fiscal year 2026, agencies will submit aggregated cost assessments, including offsets for new regulations, to the Director as part of the Unified Regulatory Agenda and Regulatory Plan.
Regulatory Definition and Exemptions: “Regulation” encompasses various types of agency actions (rules, memoranda, etc.), excluding measures related to military, national security, agency management, or those that impose minimal costs as exempted by the Director.
Implementation Guidance: The Director is tasked with developing guidance for standardizing cost measurements, identifying invalid rules, and ensuring compliance with both the Administrative Procedure Act and this order’s requirements.
Revisions to Existing Guidance: Revocation of OMB Circular No. A-4 from November 9, 2023, to reinstate the version from September 17, 2003, and reinstatement of the 2018 Treasury-OMB Memorandum on tax regulation review.
Legal and Operational Provisions: Contains severability clauses and ensures that the order does not impair existing statutory authorities, subject to applicable law and available appropriations.

Risks & Considerations

The Executive Order’s emphasis on deregulation could lead to significant changes in the regulatory environment, affecting compliance requirements for institutions like Vanderbilt University. This may necessitate adjustments in administrative processes to ensure compliance with fewer but potentially more impactful regulations.
The requirement to eliminate 10 existing regulations for every new one could result in the removal of regulations that currently benefit educational institutions, potentially impacting funding, research opportunities, and operational procedures.
The focus on reducing regulatory costs may lead to decreased federal oversight in areas such as research funding and educational standards, which could affect the university’s ability to secure grants and maintain high educational standards.
Vanderbilt University may need to closely monitor changes in the regulatory landscape to anticipate and adapt to shifts that could impact its strategic planning and resource allocation.

Impacted Programs

Office of Research at Vanderbilt may need to adjust its compliance strategies to align with new regulatory requirements and ensure continued eligibility for federal research funding.
Financial Aid and Grants Office might face changes in the availability and conditions of federal funding, requiring adjustments in financial planning and student support services.
The Legal and Compliance Office will play a crucial role in interpreting and implementing changes in regulations to ensure the university remains compliant with federal requirements.
Programs that rely heavily on federal funding or partnerships, such as those in the School of Engineering and Medical Center, may need to reassess their funding strategies and collaborative efforts.

Financial Impact

The reduction in regulatory burdens could potentially lower administrative costs for Vanderbilt University, allowing for reallocation of resources to other strategic initiatives.
However, the uncertainty surrounding which regulations will be repealed may pose financial risks, particularly if beneficial regulations are eliminated, affecting funding and operational stability.
Vanderbilt may need to invest in additional resources to track and adapt to regulatory changes, ensuring that the university remains compliant and competitive in securing federal funding.
Changes in the regulatory environment could also impact the university’s partnerships with federal agencies, necessitating adjustments in collaborative projects and funding agreements.

Relevance Score: 3 (The order presents moderate risks involving compliance and potential impacts on funding and operations.)

Key Actions

Vanderbilt’s Office of Federal Relations should monitor the implementation of the “ten-for-one” rule, which requires the elimination of ten existing regulations for each new one introduced. Understanding which regulations are being repealed could impact compliance and operational strategies at the university.
Vanderbilt’s Financial and Administrative Services should assess the potential financial implications of reduced regulatory costs. This could lead to cost savings or changes in funding allocations that may affect university operations.
Vanderbilt’s Research Administration should evaluate how changes in regulatory requirements might affect research funding and compliance. This includes understanding any new guidance from the Office of Management and Budget that could impact grant applications and reporting.
Vanderbilt’s Policy Studies Department should conduct research on the broader economic and social impacts of deregulation. This research can provide insights into how these changes might affect higher education and inform strategic planning.

Opportunities

The deregulation initiative presents an opportunity for Vanderbilt’s Business School to develop programs and courses focused on navigating a deregulated business environment. This could attract students interested in understanding the implications of regulatory changes on business operations.
Vanderbilt can leverage its expertise in policy analysis to engage with policymakers and contribute to discussions on the impacts of deregulation. Hosting forums and workshops on this topic can enhance the university’s role as a thought leader in policy and regulatory studies.
The emphasis on reducing regulatory burdens may open up new avenues for Vanderbilt’s Innovation Center to explore partnerships with industries affected by deregulation, fostering innovation and collaboration.

Relevance Score: 3 (Some adjustments are needed to processes or procedures to align with the new regulatory environment.)

Average Relevance Score: 2.8

Timeline for Implementation

Fiscal Year 2025: For the remainder of fiscal year 2025, agencies must apply the “ten-for-one” rule on all new regulations—ensuring that for every new regulation proposed, at least 10 existing regulations are identified for elimination and that the total incremental cost is significantly less than zero.
Fiscal Year 2026 and Beyond: Beginning with the Regulatory Plans for fiscal year 2026, and for each subsequent fiscal year, agencies are required to submit annual regulatory cost information to the Office of Management and Budget.

Shortest Timeline: Since the directive for fiscal year 2025 must be implemented before the close of that fiscal period, agencies effectively have over 180 days from the January 31, 2025 issuance date to comply.

Relevance Score: 1

Impacted Government Organizations

Office of Management and Budget (OMB): Charged with overseeing the regulatory budgeting process, providing guidance on costing and measurement of new and offsetting regulations, and revising regulatory analysis procedures.
Department of the Treasury: Tasked with reinstating the Memorandum of Agreement with OMB to review tax regulations and ensuring financial oversight in alignment with the deregulation directives.
All Executive Branch Departments and Agencies: Mandated to identify and eliminate at least 10 existing regulations for every new rule issued, thereby reducing regulatory burdens across the government.

Relevance Score: 2 (Three to five federal entities are directly affected by the executive order’s deregulatory requirements.)

Responsible Officials

Director of the Office of Management and Budget – Charged with implementing the order by providing guidance on the ten-for-one rule, determining incremental cost allowances for new and repealed regulations, and revoking/reinstating regulatory analysis guidelines.
Heads of All Agencies – Required to identify and eliminate at least 10 prior regulations for every new regulation, submit aggregated regulatory cost data, and comply with cost caps for fiscal year 2025 and beyond.
Secretary of the Treasury – Tasked, along with the Director, with reinstating the Memorandum of Agreement on the review of tax regulations.
Assistant to the President and Chief of Staff / Assistant to the President and Deputy Chief of Staff for Policy – Empowered to request exemptions for regulations that impose minimal costs or burdens on the private sector.

Relevance Score: 5 (Directives affect high-level executive and cabinet officials with broad regulatory oversight responsibilities.)