According to the guidance, materials submitted to OMB in
this context should include a first-year cost estimate and
if possible, five and ten-year cost estimates provided by
the agency’s chief actuary, or if not available, the budget
or policy officer.
Further, agencies must explain discrepancies between cost
estimates for an action as submitted for review and as
assumed in the most recent projection in the budget or
mid-session review, the memo said.
It said if OMB determines that a proposed offset is
inappropriate, it may request the agency to propose
alternative offsets — and that changes in baseline
estimates due to economic or technical reasons rather
than policy actions, are not to be considered offsets.
An agency head may request exceptions to the requirements,
which would be granted “only when the OMB Director
determines that the exception is appropriate in light
of extraordinary need or other compelling circumstances.”
“We have asked the Congress to live by pay-as-you-go
rules for mandatory-spending legislation, and we should
observe a similar discipline,” wrote OMB Director
Joshua Bolten.
