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“Of course, even the administration recognizes that the employer mandate will impose significant costs, which is one reason why it delayed the regulation twice,” the study said. “However, the text of the rule declined to admit that new mandates would impose paperwork.”

The group said there are “profound implications” for Congress, which uses the CRA as an oversight tool.

“The fault for these eight missing regulatory actions does not rest entirely on independent agencies or GAO; the OIRA Administrator has the responsibility to determine major rule status,” the study said. “It seems likely that these missing rules are the responsibility of the administration, although agencies themselves have omitted analyses under the CRA.”