CRM firms have an opportunity to express their views directly to the federal government about the ACHP’s radical overhaul of the regulations that implement Section 106.
All proposed regulatory changes must be reviewed by the Office of Information and Regulatory Affairs (OIRA) before being published in the Federal Register. OIRA, which is part of the Office of Management and Budget (OMB), reviews drafts of proposed and final regulations to, among other things, ensure that federal agencies have assessed the benefits and costs of rules and determined that benefits justify the costs. OIRA can request that agencies amend their proposed rules to address issues they have failed to consider.
As part of that process, members of the public may request a 30-minute telephone meeting with OIRA to share their views on the proposed regulation, including about its potential impacts, whether the agency has considered all the proposal’s consequences, and any alternatives to the proposed rule that could achieve the same results in a better way.
ACRA has requested and scheduled a meeting with OIRA later this month. There, ACRA leaders will express our profound concerns about both the proposed changes and the flawed process by which the ACHP is pushing them forward. Of particular concern is the fact that the ACHP has claimed that the changes “would not, if finalized, have a significant economic impact on a substantial number of small entities,” and therefore opted not to conduct an analysis of these impacts as required by law.
Hearing from the national association for CRM firms about the negative consequences of these changes is important – but it is equally important for OIRA to hear from firms themselves.
That’s why we strongly encourage ACRA member firms to request meetings with OIRA to express their concerns about this proposal. The more members of the public that OIRA hears from, the more likely they will require the ACHP to amend their proposal.
Requesting an OIRA meeting is easy:
- Visit OIRA’s meeting request page.
- Enter “3010-AA10” where it asks for RIN (this is the ACHP’s proposed rulemaking’s regulatory information number)
- Follow the prompts to request a meeting and submit.
It may take 7-10 business days for OIRA to respond. If they grant your request for a meeting, they will propose a day and time. If you have a conflict, you can request a different time. Meetings with OIRA are by teleconference and will last 30 minutes. On the calls, OIRA and ACHP staff will be in “listening mode” and will not answer questions regarding the substance of the regulatory action. They may ask clarifying questions in response to information you provide, but generally will not offer feedback.
In the coming days, ACRA will provide firms with resources and tips on how to conduct effective OIRA meetings. But since the clock is ticking, we urge firms to request meetings as soon as possible.