Tag Archives: interpretive rules and guidance documents

OMB’s “Major” Move on Regs & Guidance

by Bridget C.E. Dooling — Monday, Apr. 15, 2019@BridgetDooling

The Office of Management and Budget issued a memo on Thursday describing its new approach to its implementation of the Congressional Review Act (CRA). Under the CRA, the Office of Information and Regulatory Affairs (OIRA) is required to determine whether agency “rules” are “major.” In this memo, OMB calls for information about economic impacts to inform its […]

SCOTUSblog Argument Preview: Azar v. Allina Health Services

by Bridget C.E. Dooling — Wednesday, Jan. 9, 2019@BridgetDooling

Over at SCOTUSblog, health law and admin law dynamos Abbe R. Gluck and Anne Joseph O’Connell joined forces to write a helpful argument preview for a case that will be argued at the Supreme Court next week. Azar v. Allina Health Services is both a Medicare case and an interpretive rule case; a complexity two-fer, if […]

When Chevron Meets the Hobbs Act: PDR Network v. Carlton & Harris Chiropractic, Inc. (Part I)

by Bernard Bell — Monday, Nov. 26, 2018

  “When Chevron meets Hobbs, consideration of the merits must yield to jurisdictional constraints.” Carlton & Harris Chiropractic, Inc. v. PDR Network, 883 F.3d 459 (4th Cir. 2018) The Supreme Court recently granted certiorari in PDR Network, LLC v. Carlton & Harris Chiropractic, Inc., Dkt No. 17-1705, (Order List Nov. 13, 2018).  The Court framed […]