First, Do No Harm: When Procedural Reforms Become Counterproductive

The useful part

The obvious and much needed response is to ask what reforms might help guard against future attacks on procedural and scientific integrity. That effort should begin with the long-standing medical principle: first, do no harm. This risk is demonstrated by the many cautionary examples of well-intentioned federal procedural requirements that in practice have tied up decisionmaking in red tape without meaningfully enhancing the process or outcomes.

How it works

• In practice, however, the primary impact is that written communication in these reviews is dramatically hampered.
• This provision exemplifies how even discrete, seemingly minor requirements can impose significant costs — and may not yield any meaningful benefit.
• The bill never passed the Senate, but its bipartisan progress highlights how broadly supported, apparently well-intentioned reform efforts can in practice advance counterproductive decisionmaking hurdles.
• Agencies have bypassed processes for public input, interfered with grant management, shuttered long-standing public data resources, and ignored well-established scientific findings when they contradicted...
• Agencies must already explain and make public their reasoning and justification, so this requirement would have merely created the extra process step of requiring an agency to upload all the studies to...

What to take from it

For example, comments on legal risks are typically conveyed orally, as government lawyers are understandably reluctant to publicly telegraph their concerns to legal opponents. But, in practice, the PRA as currently implemented is a major impediment to agency science and public engagement. Good Intentions That Have Yielded Red Tape Government action necessarily involves navigating applicable procedural requirements.

Example or evidence

• Four Questions Government Reformers Must Ask to Avoid Counterproductive Changes By Martha Roberts Published on September 24, 2026 Federal decisionmaking under the Trump administration has raised a host of...
• 29, 2026 Tal Feldman, Kevin Xiao and 1 more 1 2 3 2 3 Featured Articles:
• Others may merely be delay mechanisms designed by opponents of the underlying action.
• Regrettably, some are good faith efforts to strengthen decisionmaking that ultimately just slow it down and yield little benefit.

Details worth keeping

Four Questions Government Reformers Must Ask Just Security. only certain team members are sufficiently experienced to manage these reviews given the heightened process requirements, creating a staffing bottleneck. Meanwhile, the transparency value is minimal since many comments are orally conveyed.

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