May 25, 2010

Post-9/11 GI Bill

Proposed Rule
Summary

Score: 10 / 60

Additional details
Agency
Department of Veterans Affairs
Regulatory Identification Number
2900-AN10
Agency Name
Department of Veterans Affairs
Rule Publication Date
12/23/2008

RULE SUMMARY

Establishes new education benefits for active duty military serving after Sept. 10, 2001

METHODOLOGY

There are twelve criteria within our evaluation within three broad categories: Openness, Analysis and Use. For each criterion, the evaluators assign a score ranging from 0 (no useful content) to 5 (comprehensive analysis with potential best practices). Thus, each analysis has the opportunity to earn between 0 and 60 points.

Criterion Score

Openness

1. How easily were the RIA , the proposed rule, and any supplementary materials found online?
A general search on the Veterans Affairs website for "post-9/11 GI bill proposed rule" provides a link to a list of rulemakings, and a link to this proposed regulation is part of the list. It is also available on regulations.gov.
5/5
2. How verifiable are the data used in the analysis?
The very short RIA simply presents some cost numbers.
0/5
3. How verifiable are the models and assumptions used in the analysis?
There is no explanation of how the numbers were calculated.
0/5
4. Was the analysis comprehensible to an informed layperson?
The one-page regulatory analysis is readable but not very informative.
1/5

Analysis

5. How well does the analysis identify the desired outcomes and demonstrate that the regulation will achieve them?
1/5
Does the analysis clearly identify ultimate outcomes that affect citizens’ quality of life?
The RIA section says the need for the regulation is expressed in the preamble, but the preamble just says the regulation was issued because Congress passed a law. Benefits to veterans are perhaps intuitively obvious.
3/5
Does the analysis identify how these outcomes are to be measured?
The analysis does not address this topic.
0/5
Does the analysis provide a coherent and testable theory showing how the regulation will produce the desired outcomes?
The analysis does not address this topic.
0/5
Does the analysis present credible empirical support for the theory?
The analysis does not address this topic.
0/5
Does the analysis adequately assess uncertainty about the outcomes?
The analysis does not address this topic.
0/5
6. How well does the analysis identify and demonstrate the existence of a market failure or other systemic problem the regulation is supposed to solve?
0/5
Does the analysis identify a market failure or other systemic problem?
The best we can infer is that the systemic issue is veterans' compensation for serving the U.S. government as their employer.
1/5
Does the analysis outline a coherent and testable theory that explains why the problem (associated with the outcome above) is systemic rather than anecdotal?
The analysis does not address this topic.
0/5
Does the analysis present credible empirical support for the theory?
The analysis does not address this topic.
0/5
Does the analysis adequately assess uncertainty about the existence or size of the problem?
The analysis does not address this topic.
0/5
7. How well does the analysis assess the effectiveness of alternative approaches?
0/5
Does the analysis enumerate other alternatives to address the problem?
The analysis does not address this topic.
0/5
Is the range of alternatives considered narrow (e.g., some exemptions to a regulation) or broad (e.g., performance-based regulation vs. command and control, market mechanisms, nonbinding guidance, information disclosure, addressing any government failures that caused the original problem)?
The analysis does not address this topic.
0/5
Does the analysis evaluate how alternative approaches would affect the amount of the outcome achieved?
The analysis does not address this topic.
0/5
Does the analysis adequately address the baseline? That is, what the state of the world is likely to be in the absence of federal intervention not just now but in the future?
The analysis does not address this topic.
0/5
8. How well does the analysis assess costs and benefits?
1/5
Does the analysis identify and quantify incremental costs of all alternatives considered?
It quantifies two large costs to the federal government that change as a result of the law this regulation implements.
3/5
Does the analysis identify all expenditures likely to arise as a result of the regulation?
It identifies major federal expenditures.
3/5
Does the analysis identify how the regulation would likely affect the prices of goods and services?
The analysis does not address this topic.
0/5
Does the analysis examine costs that stem from changes in human behavior as consumers and producers respond to the regulation?
The analysis does not address this topic.
0/5
If costs are uncertain, does the analysis present a range of estimates and/or perform a sensitivity analysis?
The analysis does not address this topic.
0/5
Does the analysis identify the alternative that maximizes net benefits?
The analysis does not address this topic.
0/5
Does the analysis identify the cost-effectiveness of each alternative considered?
The analysis does not address this topic.
0/5
Does the analysis identify all parties who would bear costs and assess the incidence of costs?
It identifies federal expenditures.
2/5
Does the analysis identify all parties who would receive benefits and assess the incidence of benefits?
The analysis does not identify which veterans receive benefits nor does it address larger social welfare issues.
1/5

Use

9. Does the proposed rule or the RIA present evidence that the agency used the analysis?
The agency acknowledges the RIA exists, but there is no evidence it affected any decisions.
1/5
10. Did the agency maximize net benefits or explain why it chose another alternative?
Net benefits from these expendtirues could have been calculated but were not.
1/5
11. Does the proposed rule establish measures and goals that can be used to track the regulation's results in the future?
Since the RIA does not analyze benefits, there is no basis for establishing goals and measures.
0/5
12. Did the agency indicate what data it will use to assess the regulation's performance in the future and establish provisions for doing so?
Since the RIA does not analyze benefits, there is no discussion of data that could be used to track benefits.
0/5
 
Total 10 / 60