Only One-Third of Reviewed COVID Rules Described Economic Effects—60 Points Below Other Years

The disclosure rate collapsed during the emergency

GAO reviewed major interim rules issued without a prior proposal. Thirty-eight of 41 pre-COVID rules described economic effects, compared with 18 of 55 COVID-response rules and 14 of 15 post-COVID rules.

That is 92.9% for the two comparison periods combined versus 32.7% during the COVID group—a 60.1 percentage-point gap. The calculation describes the presence of an explanation, not whether every analysis was complete or correct.

PPP rules dominate the missing explanations

Thirty-seven COVID rules lacked the descriptions. Thirty-one were issued by the Small Business Administration, and 30 of those implemented the Paycheck Protection Program. PPP rules therefore account for 81.1% of the COVID-period gap.

Emergency speed and repeated statutory changes provide important context. The concentration also means the result should not be generalized to every agency’s pandemic rulemaking.

Comments arrived, but later final rules often did not

Across 116 major interim rules issued without proposals, 115 requested public comments after publication and 109 received them. Only 52 were followed by a subsequent final rule during GAO’s review period; 49 of those documented consideration of comments.

Sixty-four had no later final rule in the period. That does not prove agencies ignored every comment, but it limits the public record showing how temporary or immediately effective choices were reconsidered.

Method and limits

This newsroom recomputed period rates, the 60.1-point gap and PPP concentration from GAO’s tables. The review is a documentation study of selected major interim rules—not a finding that undisclosed effects necessarily occurred or that a particular loan rule caused harm.