FEDERALISM

Implementation of

Executive Order 12612 in

the Rulemaking Process

Statement for the Record of L. Nye Stevens

Director, Federal Management and Workforce Issues

General Government Division

United States General Accounting Office

GAO Testimony

Before the Committee on Governmental Affairs

U.S. Senate

Not to be Released

Before 9:00 a.m. EDT

Wednesday

May 5, 1999

GAO/T-GGD-99-93

Statement

Federalism: Implementation of Executive

Order 12612 in the Rulemaking Process

Page 1 GAO/T-GGD-99-93

Mr. Chairman and Members of the Committee:

I am pleased to provide some preliminary results from our ongoing review

of the implementation of Executive Order 12612 on “Federalism,” which

was issued by President Reagan in 1987. Although the executive order

applies to all covered agencies’ policies that have federalism implications,1

you asked that we focus on agencies’ compliance with the order’s

requirements in the rulemaking process in recent years. Specifically, we

are examining (1) how often the preambles to covered agencies’ final rules

issued between April 1, 1996, and December 31, 1998, mentioned

Executive Order 12612 and how often they indicated that the agencies had

conducted federalism assessments under the order; (2) what selected

agencies have done to implement the requirements of Executive Order

12612; and (3) what the Office of Management and Budget (OMB) has done

to oversee federal agencies’ implementation of Executive Order 12612 in

the rulemaking process.

In brief, our preliminary results indicate that federal agencies covered by

Executive Order 12612 mentioned the order in about 27 percent of the

more than 11,000 final rules they issued between April 1996 and December

1998. The agencies indicated, however, that they had prepared federalism

assessments for only five of these rules. Of the 117 major rules issued by

these agencies during this period, the preambles indicated that only 1 had

a federalism assessment. State and local representatives that we consulted

said that certain federal agencies should have done assessments for more

of these major rules; however, the agencies said that their rules did not

have sufficient federalism implications to trigger the executive order’s

requirements. All three of the agencies we visited had some kind of

written guidance on the executive order and had designated an official or

office responsible for ensuring its implementation.2

 However, the methods

the agencies use to determine whether federalism assessments are needed

varied among the agencies. OMB officials told us that they have taken no

specific actions to implement the executive order, but said the order is

considered along with other requirements as part of their regulatory

review process under Executive Order 12866.

 

1

It is unclear whether Executive Order 12612 covers regulations and other policies issued by

independent regulatory agencies, such as the Federal Communications Commission and the Securities

and Exchange Commission. Therefore, we are focusing our review on executive departments and

agencies that are not independent regulatory agencies.

2

As discussed later in this statement, the agencies we visited were those with the most major rules that

state and local government representatives believed should have had a federalism assessment.
Statement

Federalism: Implementation of Executive Order 12612 in the Rulemaking Process

Page 2 GAO/T-GGD-99-93

Before discussing our preliminary findings in detail, it will be helpful to

review the key features of Executive Order 12612 and some recent

initiatives related to federalism. The executive order establishes a set of

fundamental principles and criteria that executive departments and

agencies should use when formulating and implementing policies that have

federalism implications. For example, the executive order says that

federal agencies should refrain to the maximum extent possible from

establishing uniform, national standards for programs with federalism

implications and that, when national standards are required, they should

consult with appropriate officials and organizations representing the states

in developing those standards. The order says that regulations and other

policies have federalism implications if they “have substantial direct

effects on the States, on the relationship between the national government

and the States, or on the distribution of power and responsibilities among

the various levels of government.”

Executive Order 12612 also contains specific requirements for agency

implementation and governmentwide coordination and review. For

example, the head of each executive department and agency is required to

designate an official to be responsible for ensuring the implementation of

the order, and for determining which proposed policies have sufficient

federalism implications to warrant preparation of a federalism assessment.

If an assessment is prepared, it must accompany any proposed or final rule

submitted to OMB for review under Executive Order 12866. 3 OMB, in turn,

is required to ensure that agencies’ rulemaking actions are consistent with

the policies, criteria, and requirements in the federalism executive order.

Although Executive Order 12612 has remained in effect since it was issued

in 1987, there have been several other initiatives that were, at least in part,

intended to improve the relationship between federal rulemaking agencies

and state and local governments. For example, in 1993 President Clinton

issued Executive Order 12875 on “Enhancing the Intergovernmental

Partnership,” which requires that agencies develop effective processes to

permit state and local officials to provide meaningful and timely input in

the development of regulatory proposals containing significant unfunded

mandates. In 1995, Congress enacted the Unfunded Mandates Reform Act

(UMRA), part of which requires agencies to take a number of analytical

 

3

Executive Order 12612 actually refers to rulemaking procedures under Executive Order 12291, which

was revoked and replaced by Executive Order 12866 in 1993. Because only “significant” rules are

submitted to OMB for review under Executive Order 12866, federalism assessments for nonsignificant

rules are not required to be submitted to OMB. For a description of the review process under this

order, see Regulatory Reform: Implementation of the Regulatory Review Executive Order (GAO/T-96-

185, Sept. 25, 1996).

Background
Statement

Federalism: Implementation of Executive Order 12612 in the Rulemaking Process

Page 3 GAO/T-GGD-99-93

and procedural steps during the rulemaking process for certain rules that

involve a mandate.

On May 14, 1998, President Clinton issued Executive Order 13083 on

“Federalism,” which was intended to replace both Executive Order 12612

and Executive Order 12875. The new executive order was to take effect in

mid-August 1998, and would have made a number of changes to the

specific requirements in Executive Order 12612. For example, agencies

would no longer have been required to designate an official to ensure

implementation of federalism requirements, and would not have been

required to prepare federalism assessments for regulations and other

policies with federalism implications. However, the President suspended

Executive Order 13083 before it became effective in response to concerns

raised by the National Governors’ Association and other interested

parties.4

 Many of the commentators objected to the new order because

they believed it expanded the federal government’s authority to make

national policies and standards. There was also criticism that the new

order was issued without consulting affected state and local government

representatives. With the suspension of Executive Order 13083, Executive

Order 12612 remains the primary presidential directive to federal agencies

on how they are to develop and implement regulations that have

federalism implications.

Executive Order 12612 does not require agencies to mention the order in

the preamble to their final rules or to note in those preambles whether a

federalism assessment was prepared. Therefore, our review of the rule

preambles does not show whether agencies considered the executive

order or whether the agencies prepared federalism assessments. However,

mentioning the executive order in the preamble to a final rule is a clear

indication that the agency was aware of and considered its requirements in

some way. Also, if an agency prepared a federalism assessment for a final

rule, the agency is likely to describe the assessment in the preamble to the

rule.

To determine how often agencies have mentioned Executive Order 12612

and federalism assessments in the preambles to their rules, we examined

all final rules issued by the covered agencies between April 1996 and

December 1998, and all rules issued during this period that were

considered “major” rules under the congressional review requirements in

the Small Business Regulatory Enforcement and Fairness Act (SBREFA).

We selected this time period because it allowed us to use our existing

 

4

Executive Order 13083 was suspended by Executive Order 13095 on August 5, 1998.

Few Rules Address

Executive Order 12612

Requirements
Statement

Federalism: Implementation of Executive Order 12612 in the Rulemaking Process

Page 4 GAO/T-GGD-99-93

database of major rules issued since the passage of the SBREFA. SBREFA

defines a rule as “major” if the Administrator of OMB’s Office of

Information and Regulatory Affairs concludes that the rule is likely to

result in (1) an annual effect on the economy of $100 million or more; (2)

an increase in costs or prices; or (3) significant adverse effects on (among

other things) competition, employment, investment, or productivity.

To summarize the 3 years of data depicted in figure 1, nonindependent

regulatory agencies published 11,414 final rules in the Federal Register

between April 1996 and December 1998. The agencies indicated in the

preambles that they had conducted federalism assessments for 5 of these

11,414 rules—2 in 1996 and 3 in 1997. In 3,016 rules (26 percent of the

total), the agencies stated that no federalism assessment was conducted

because the rules did not have federalism implications. Nearly all of these

statements were standard, “boilerplate” certifications with little or no

discussion of why the rule did not trigger the executive order’s

requirements. In the remaining 8,393 rules (74 percent), the agencies did

not mention Executive Order 12612.

Rule Preambles Frequently

Did Not Mention the Order,

and Reported Few

Federalism Assessments
Statement

Federalism: Implementation of Executive Order 12612 in the Rulemaking Process

Page 5 GAO/T-GGD-99-93

Note: The data for 1996 covers only those rules issued from April 1 to December 31.

Source: Federal Register and GAO analysis.

Five departments and agencies issued nearly 80 percent of all applicable

final rules during this period—the Departments of Transportation (DOT),

Agriculture (USDA), Commerce (DOC), and Health and Human Services

(HHS), and the Environmental Protection Agency (EPA). As figure 2

shows, these agencies differed substantially in the extent to which they

mentioned Executive Order 12612 in the preambles to their final rules. For

example, DOT mentioned the executive order in nearly 60 percent of its

final rules, whereas EPA did not mention the order in any of the 1,914 final

rules it issued between April 1996 and December 1998.

Figure 1: Agencies Indicated Only Five

Final Rules Issued Between April 1996

and December 1998 Had Federalism

Assessments
Statement

Federalism: Implementation of Executive Order 12612 in the Rulemaking Process

Page 6 GAO/T-GGD-99-93

Source: Federal Register and GAO analysis.

Subsection 6(c) of Executive Order 12612 says that a federalism

assessment should (1) contain the designated official’s certification that

the regulation or other policy has been assessed in light of the principles,

criteria, and requirements in sections 2 through 5 of the order; (2) identify

any provision or element of the policy that is inconsistent with those

principles, criteria, and requirements; (3) identify the extent to which the

policy imposes additional costs or burdens on the states; and (4) identify

the extent to which the policy would affect the states’ ability to discharge

traditional state governmental functions or other aspects of state

sovereignty. Of the five rules in which the preambles indicated that a

federalism assessment had been prepared, all five contained either these

four requirements or a statement indicating that the federalism assessment

(located elsewhere in the rulemaking docket) addressed these four

Figure 2: Agencies Differed In Degree to

Which They Mentioned Executive Order

12612 in Final Rules Issued Between

April 1996 and December 1998
Statement

Federalism: Implementation of Executive Order 12612 in the Rulemaking Process

Page 7 GAO/T-GGD-99-93

requirements. As table 1 shows, the five rules for which federalism

assessments were prepared were issued by four agencies (DOC, DOT,

HHS, and the Department of Labor) in either 1996 or 1997.

Department or agency

Date final rule

was published Title

Department of Health and

Human Services

Aug. 28, 1996

Regulations Restricting the Sale and

Distribution of Cigarettes and Smokeless

Tobacco to Protect Children and

Adolescents

Department of

Transportation Dec. 16, 1996 Roadway Worker Protection

Department of Commerce Jan. 30, 1997 Florida Keys National Marine Sanctuary

Mar. 28, 1997

Hawaiian Islands Humpback Whale

National Marine Sanctuary

Department of Labor Mar. 31, 1997 (Hazard) Abatement Verification

Source: Federal Register and GAO analysis.

Many of the final rules that federal agencies issue are administrative or

routine in nature, and are therefore unlikely to have significant federalism

implications. As a result, it is not particularly surprising that agencies

would not prepare federalism assessments for many of those rules.

However, rules that are “major” under SBREFA (e.g., those that have a

$100 million impact on the economy) and that involve or affect state and

local governments are more likely to have federalism implications that

would warrant preparation of an assessment.

Of the 11,414 final rules that nonindependent agencies issued between

April 1996 and December 1998, 117 of them were identified as “major”

rules by the agencies and OMB. The agencies issuing the rules indicated in

the Unified Agenda of Federal Regulatory and Deregulatory Actions5

 that

37 of them would affect state and local governments. The agencies

indicated in the preambles to 21 of the rules that the rules would take

precedence in the event they conflicted with state or local laws or

regulations.

As figure 3 shows, federal agencies covered by Executive Order 12612

mentioned the executive order in the preambles to 30 of the 117 major

 5

The Unified Agenda is issued twice each year by the Regulatory Information Service Center, and is a

compendium of executive and independent agencies’ regulatory activities that are being developed,

planned for the future, or completed.

Table 1: Four Agencies Issued Five Final

Rules With Federalism Assessments

Between April 1996 and December 1998

Only One Federalism

Assessment Reported for

Major Rules
Statement

Federalism: Implementation of Executive Order 12612 in the Rulemaking Process

Page 8 GAO/T-GGD-99-93

rules they issued between April 1996 and December 1998 (about 25 percent

of the total). However, only one of these preambles indicated that a

federalism assessment had been prepared for the rule—an HHS rule issued

in 1996 restricting the sale and distribution of cigarettes and smokeless

tobacco to protect children and adolescents. The other 29 rule preambles

that mentioned the executive order stated that the rules did not have

sufficient federalism implications to warrant the preparation of a

federalism assessment. Most of these statements were “boilerplate”

certifications with little or no explanation of why the executive order’s

requirements were not applicable to the rules.

Sources: Federal Register and GAO’s major rule database.

Four agencies issued 87 (75 percent) of the 116 major rules issued during

this period without federalism assessments—HHS (30 rules), EPA (21

rules), USDA (18 rules), and the Department of the Interior (18 rules). To

determine how affected parties viewed the agencies’ decisions, we asked

Figure 3: Only One Major Rule Issued

Between April 1996 and December 1998

Had a Federalism Assessment
Statement

Federalism: Implementation of Executive Order 12612 in the Rulemaking Process

Page 9 GAO/T-GGD-99-93

representatives from seven major state and local government interest

groups (known as the “Big Seven”) to review descriptions of the 116 rules

without federalism assessments and to indicate whether they believed any

of the rules should have had an assessment. Four of these organizations

provided us with comments on at least some of the rules.6

 At least one of

the four organizations indicated that 79 of the 116 rules should have had a

federalism assessment. The agencies with the largest number of rules that

the four organizations considered in need of assessments were HHS (26

rules), USDA (18 rules), and EPA (10 rules). Two or more of the

organizations indicated that 30 of the rules should have had an assessment.

We then contacted officials in each of these three agencies to determine

whether federalism assessments had been prepared for these rules (but

not mentioned in the preambles to the rules) or why they believed that no

assessment was needed. The agencies did not indicate that any other

assessments had been prepared, and generally said that their rules did not

have sufficient federalism implications to trigger the executive order’s

requirements. In some cases, the agencies indicated that they had

substantively complied with the executive order by taking other actions to

address intergovernmental concerns during the rulemaking process.

Federal departments and agencies are primarily responsible for

implementing Executive Order 12612. Section 6 of the executive order

delineates the agencies’ responsibilities, requiring them to (1) designate an

official to be responsible for ensuring implementation of the order, (2)

have the designated official determine which proposed regulations have

sufficient federalism implications to warrant the preparation of a

federalism assessment, and (3) send each federalism assessment to OMB

as a part of the regulatory review package sent pursuant to Executive

Order 12866. However, Executive Order 12612 provides the agencies with

broad discretion to determine how to meet these requirements.

Each of the three agencies we visited—EPA, HHS, and USDA—has some

kind of written guidance on how to implement Executive Order 12612. All

three of the agencies’ guidance documents identify a designated official or

office responsible for ensuring compliance with the executive order.

 

6

The National Conference of State Legislatures, the Council of State Governments, and the National

Association of Counties reviewed all of the rules. The National League of Cities reviewed all of the

rules except the EPA rules. The National Governors’ Association, the International City/County

Management Association, and the U.S. Conference of Mayors did not provide any assessments of the

rules.

Selected Agencies

Have Taken Some

Actions to Implement

Executive Order 12612

Agencies Have Written

Guidance and Designated

Officials or Offices
Statement

Federalism: Implementation of Executive Order 12612 in the Rulemaking Process

Page 10 GAO/T-GGD-99-93

EPA issued its “Guidelines for Implementing Executive Order 12612:

Federalism” in June 1988. The guidelines identified the Assistant

Administrator of the Office of Policy, Planning, and Evaluation as the

designated EPA official for federalism. However, in 1992, the EPA

Administrator made the agency’s General Counsel responsible for carrying

out the functions of the designated official. The General Counsel was

authorized to delegate the authority to the Deputy General Counsel, who

could redelegate it to the Associate General Counsel level. EPA officials

said that all agency regulations are to be reviewed by the General Counsel

before being submitted to OMB and published in the Federal Register.

USDA’s guidance on “Regulatory Decisionmaking Requirements” was last

updated in March 1997, and the requirements that are related to Executive

Order 12612 are part of that overall guidance. The guidance indicates that

the department’s Office of the General Counsel (OGC) is responsible for

carrying out the responsibilities of the designated official. For example, it

says that OGC will “[r]eview regulations and notices of proposed

rulemaking for compliance with Executive Order 12612...and determine

whether the preparation of a federalism assessment by an agency is

required.” All USDA regulations are to be reviewed centrally by the

department’s OGC before being submitted to OMB and published in the

Federal Register.

In March 1988, HHS’s Assistant Secretary for Planning and Evaluation

(ASPE) issued a memo on “Compliance with Executive Orders on The

Family and Federalism.” The memo indicated that the Secretary had

assigned the ASPE lead responsibility for guidance, compliance, and

technical assistance related to the executive order. HHS officials said that,

with the exception of certain delegated regulations issued by the Food and

Drug Administration (FDA), the ASPE is responsible for reviewing and

clearing all departmental regulations. One facet of the ASPE’s review is to

determine whether the rules comply with Executive Order 12612. Many

nonmajor FDA regulations (as determined by FDA) are issued directly by

the Commissioner without formal departmental review and clearance. For

these regulations, HHS officials said that the FDA Commissioner exercises

the responsibilities of the designated official under the executive order.

Section 6 of Executive Order 12612 says that the designated official “shall

determine which proposed policies have sufficient federalism implications

to warrant the preparation of a Federalism Assessment.” Two of the three

agencies we visited established explicit criteria in their written guidance

on Executive Order 12612 to determine whether a rule has significant

Criteria for Determining the

Need for Federalism

Assessments Vary Across

the Three Agencies
Statement

Federalism: Implementation of Executive Order 12612 in the Rulemaking Process

Page 11 GAO/T-GGD-99-93

federalism implications. At least one of the agencies’ criteria seems to

establish a high threshold for preparing an assessment.

USDA’s written guidance on Executive Order 12612 does not establish any

specific criteria that the department’s OGC should use to determine

whether a particular rule or other policy has sufficient federalism

implications to warrant the preparation of a federalism assessment.

Neither has USDA’s OGC established any written criteria to guide these

determinations. USDA officials said that OGC attorneys make their own

determinations regarding federalism implications in the context of each

rulemaking action.

The HHS guidance on the executive order lists “threshold criteria” that can

be used to determine whether a rule’s federalism effects are significant and

thus require a federalism assessment. The guidance indicates that a rule

should be considered to have significant federalism implications if it (1)

has a direct causal effect on the states; (2) primarily relates to the

structure and role of states (e.g., not just a reduction in funding of grant

programs); (3) has effects within a reasonably foreseeable time frame (e.g.,

within the next 5 years); and (4) has a significant incremental effect (e.g.,

requiring states to do something that they are not already doing). The

guidance also says that an assessment must be prepared if an action will

directly create significant effects on states even if the action is mandated

by law or the department otherwise has no discretion. Finally, it says that

rules and other policies with either a positive or negative significant effect

on the states require a federalism assessment.

The criteria in EPA’s guidance are similar to, but also somewhat different

from, the HHS criteria. For example, the guidance document says that,

even if an action might have substantial federalism effects, it will not

require a federalism assessment if a statute mandates the action or the

means to carry it out are implied by statute. The EPA guidance also

establishes the following four criteria, all of which must be met for the

agency to determine that a rule has “substantial federalism effects” and

therefore requires a federalism assessment:

• The rule must have an institutional effect on the states, not just a financial

effect. The guidance says that the fact “[t]hat an action has a financial

effect on States, regardless of magnitude, is not sufficient in itself to

trigger a federalism assessment.” It also says a rule must “affect the roles

and responsibilities of state government to have federalism implications.”

• The rule must “change significantly the relative roles of Federal and State

governments in a particular program context, lead to Federal control over
Statement

Federalism: Implementation of Executive Order 12612 in the Rulemaking Process

Page 12 GAO/T-GGD-99-93

traditional State responsibilities, or decrease the ability of States to make

policy decisions with respect to their own functions” in order to have a

“substantial” effect.

• The rule must affect all or most states, “not simply one state or a small

cluster of States.”

• The rule must have a “direct, causal effect” on the states. If a rule creates

federalism effects as a side effect, the guidance says the rule would not

trigger the requirement for a federalism assessment.

These criteria seem to establish a high threshold for what constitutes

“sufficient” federalism implications to require an assessment. For example,

the executive order defines “state” to “refer to the States of the United

States of America, individually or collectively.” (Emphasis added.) EPA’s

guidance, on the other hand, indicates that federalism assessment should

be prepared only if a regulation or other policy affects all or most states.

However, EPA’s actions appear to be allowable because the executive

order does not define what is meant by “sufficient” federalism

implications, leaving that determination up to the agencies.

Section 7 of Executive Order 12612 indicates that, in implementing

Executive Order 12866, OMB should, to the extent permitted by law, “take

action to ensure that the policies of Executive departments and agencies

are consistent with the principles, criteria, and requirements” of the

federalism executive order. As noted previously, the order requires

agencies to submit federalism assessments (if they were prepared) along

with any rules being submitted to OMB for review.

OMB officials told us that reviews of agencies’ actions in the federalism

area have been part of the standard regulatory reviews conducted by OMB

staff pursuant to Executive Order 12866. They said that agencies have

rarely submitted separate federalism assessments to OMB but have

addressed federalism considerations, when appropriate, as a part of the

cost-benefit analysis and other analytical requirements. These officials

also noted that there were few federalism assessments filed with OMB

during the Reagan and Bush administrations.

According to agency officials, OMB does not now have, nor did it

previously have, a separate oversight program for examining agencies’

adherence to the federalism executive order. OMB has not issued any

guidance to the agencies on the implementation of Executive Order 12612.

OMB does not maintain a list of the designated agency officials who are

responsible for implementation within their agencies. In fact, the White

OMB Has Taken Little

Specific Action to

Ensure

Implementation of

Executive Order 12612
Statement

Federalism: Implementation of Executive Order 12612 in the Rulemaking Process

Page 13 GAO/T-GGD-99-93

House web site indicates that Executive Order 13083 (the suspended

Clinton order), not 12612, is the applicable executive order on federalism.7

One OMB official told us that Executive Order 12612, Executive Order

12866, Executive Order 12875, and UMRA all substantively address the

same idea regarding federalism. They all require that, if a proposed rule is

likely to have a significant impact on other levels of government, the

impact should be considered in analyzing the costs and benefits of the rule

and the agency should consult with appropriate officials at the state and

local level.

Executive Order 12612 gives agencies substantial discretion to determine

which regulations and other policies have “sufficient” federalism

implications to warrant preparation of a federalism assessment. Using that

discretion, the agencies have prepared federalism assessments for very

few rules. One of the agencies we visited had no written criteria to make

those determinations. Although the other two agencies had written

criteria, they had prepared only one federalism assessment and had

mentioned the executive order in only 10 out of nearly 3,000 rules. The

two agencies’ criteria were also inconsistent regarding whether statutorily

mandated regulations required a federalism assessment. Also, other than

including federalism as part of its regulatory reviews, OMB has taken no

other specific actions to carry out its responsibility to ensure that agencies’

regulations and other policies are consistent with the executive order.

The fact that agencies have prepared federalism assessments for only 5 of

the more than 11,000 final rules issued in recent years suggests that the

agencies are not implementing the order as vigorously as they could. We

will be exploring the implications of this situation as we complete the

work on this issue that you have requested of us.

 

7

The OMB web site does not list executive orders. The White House web site lists only the executive

orders issued during the Clinton Administration. It also contains the executive order that suspended

Executive Order 13083, but to find it one must enter either the number of the order or the date on

which it was issued.

Conclusions
Page 14 GAO/T-GGD-99-93
Page 15 GAO/T-GGD-99-93
Page 16 GAO/T-GGD-99-93
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