OMB has issued a memo to agencies stressing its role in reviewing legislative proposals, letters, testimony, and other communications to Congress. Memo M-17-19 calls attention to OMB Circular A-19, saying that:
All draft legislation that executive branch agencies wish to transmit to the Congress must be sent to OMB for clearance. OMB circulates the draft bills, along with any other supporting documents, to affected agencies and appropriate EOP [Executive Office of the President] offices.
Congressional committees often invite agency officials to testify on pending legislation on behalf of the administration, or request that agencies submit their views through a letter. Agencies may also choose to submit a letter on pending legislation without a congressional request. Such testimonies and letters must be submitted to OMB for clearance.
All transmittals to Congress communicating legislative views or recommendations must be submitted to OMB for clearance. In addition to testimonies and letters, an agency may communicate in another form, such as submitting talking points to convey comments (often informally) on a bill under consideration by Congress, or responding to questions for the record following a congressional hearing. Also, agencies have numerous requirements to submit certain reports to Congress, and reports that contain any legislative views or recommendations must be submitted to OMB for clearance.”
The clearance process “requires sufficient time to review and coordinate with all relevant agencies, and offices in the Executive Office of the President,” it adds.
The memo also notes that OMB coordinates agency input into statements of administration policy on bills ready for a vote by the full House or Senate, as well as bills presented for signature.