Comment on OMB-2026-0034-0001

Summary: The Institute for Policy Integrity at New York University School of Law argues that the proposed rule violates the Paperwork Reduction Act (PRA) because it modifies information collection requirements without the necessary justifications or public comment periods. They contend that the agency's claim that the rule merely "streamlines" requirements is incorrect and that the rule must be reproposed with proper PRA information or a stand-alone approval process.