SISNOSESignificant Economic Impact on a Substantial Number of Small Entities (US EPA)
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Both the Government Accountability Office and the Congressional Research Service have studied the failure of the RFA to quantify SISNOSE. In a 2007 report, the GAO found that "there was confusion among the agencies regarding the meaning of key terms such as [SISNOSE]." In addition, agencies reported that RFA "requirements" are less comprehensive than their discretionary reviews because they are limited to regulations with [SISNOSE]." It is clear that agency confusion about key terms do not benefit small businesses or increase regulatory accountability.
According to the Small Business Administration's "Guide for Government Agencies," only the Department of Health and Human Services has a quantifiable scale for determining SISNOSE: it considers a rule significant if it reduces revenues or raises costs of any affected entities by more than 3 to 5 percent within five years.
After four executive orders and countless memos to agencies, there is little stopping the White House from implementing a quantified SISNOSE standard for executive agencies.