Our Mission & Structure

We believe academics frequently have insights that can inform the rulemaking process and help ensure that new rules reflect rigorous theoretical and empirical research. We also believe, however, that these views are often not put before agencies because of a collective action problem. Identifying academic experts with compatible views, drafting language that reflects their consensus, coordinating comments and edits, and meeting the agency’s deadlines and technical requirements are essentially administrative tasks that an individual professor is often reluctant to take on. Yet this work is crucial to the regulatory process. 

The Institute intends to help solve this collective action problem. Our staff and board members receive compensation for their work. As a nonprofit organization, we receive donations from individual and corporate entities, some of which may have a financial interest in a given rulemaking. However, the comment letters we produce will reflect the views of the academic signatories, who will not receive compensation for signing or participating in the drafting and editing of the letters. We will encourage all signatories to follow sound academic practice by disclosing any affiliations or financial interests relevant to assessing the signatory’s impartiality. 

We note that professors’ amicus briefs in litigation are often produced through a similar process. A law firm takes the laboring oar, but the substance of the brief reflects the disinterested opinion of its academic signatories. Given the frequency with which judicial opinions incorporate ideas contained in amicus briefs, it appears that judges find them useful. We hope and expect that the same will be true of the Institute’s work product. We will maintain a strict separation between comment letters that reflect solely the views of academic signatories and those that reflect our own observations and concerns.