Why Interagency Policy Coordination Efforts Frequently Fail (And How To Fix Them)
One of the great innovations of the American experiment is the federation of the organization of government at scale. For all the advantages to science and technology governance that federalism has promoted, the decentralization of responsibilities within the federal government makes speaking with one voice difficult. While differences between government agencies has been a source of strength for the U.S. federal research and development (R&D) ecosystem, those differences can also manifest as tribalism in the governance of programs administered and regulations promulgated by those agencies.
We firmly believe that it’s possible to “stack the deck” in such a way that produces better governing outcomes with stronger public impact while maintaining the strength inherent in interagency deliberative processes. To do that, this memo hopes to demystify the way that decisions are made inside agency bodies while providing a roadmap that can help decisionmakers and their advisors achieve those better outcomes. Our recommendations encourage senior policymakers and policy influencers, alike, to maintain a strong teleological focus, to embrace economic impact assessment, and adequate resourcing and troubleshooting gumption to deliver tangible policy outcomes.
Differences in R&D priority implementation between agencies can be subtle, such as a discrepancy in legal interpretation over a federal statute, or they can be overt, such as one agency taking a position seemingly at odds with another, or procedural such as when two agencies require redundant paperwork to collect information. This lack of cohesion can ultimately lead to significantly increased administrative burden for stakeholders, slower deployment of Administration priorities, and increased costs for the R&D ecosystem. To address this, R&D stakeholders frequently ask for more harmonized rulemaking between agencies. Unfortunately, the incentive structures supporting institutional autonomy frustrate harmonization and simplification efforts, further slowing the work of the government and (in some cases) magnifying the administrative burden experienced by stakeholder organizations.
Challenge and Opportunity
Coordination among federal science agencies is essential to ensure government-wide alignment on R&D investment priorities and policy agendas. However, the federal R&D enterprise suffers from some of the most egregious siloization of process and procedure in the administrative state.
To give one specific example, non-governmental space activities are covered by multiple agencies, with the Federal Aviation Administration covering launch and reentry, the Federal Communications Commission and Department of Commerce covering spectrum-related issues, the Office of Space Commerce covering remote sensing technologies, and the Federal Communications Commission (strangely) covering orbital debris. If a company wishes to engage in remote sensing activities, they need to engage each of these licensing processes, separately, which may operate on different timelines and with different levels of priority. Both the Trump administration’s executive order on commercial spaceflight and the Biden-Harris administration’s novel space activities proposal maintain the separation of licensing processes between crewed and uncrewed space activities, protecting the equities of both the Department of Transportation and Department of Commerce rather than resulting in regulatory rationalization and placing them at odds with with Congress’ proposals.
Disharmony in the regulatory system may result in differentiation of federal grant, contract, and cooperative agreement requirements that organizations need to navigate; oftentimes requiring multiple and substantially different layers of expertise and government-service provider relationships that organizations have to manage. When the government does coordinate, interagency bodies frequently develop recommendations that maximize the flexibility of the government institutions, but may avoid addressing fundamental ethical issues or the concerns of impacted communities.
To address these complaints and ensure alignment, both formal and informal interagency deliberative bodies are often formed within the Executive Branch. These may take the form of committees, subcommittees, and working groups of Congressionally mandated interagency fora, such as the National Science and Technology Council or the Interagency Council on Statistical Policy. Or, they may arise from the convening power of components in the Executive Office of the President, in what are known as, policy coordination committees in the current administration.
Less often, they form organically through recognition for the need of coordination by the agencies themselves, such as Commerce, Energy, NASA, Defense Information Managers Group (CENDI). These bodies, and other ad-hoc working groups, are almost always formed by enterprising individuals in more junior government roles when there are clear mission requirements which need to be addressed. Such groups can be incredibly effective, especially if organically-formed groups are well-acquainted with legal and funding constraints, but can also be relatively limited in overall ambition.
To navigate thorny issues and resolve interagency disagreements, senior staff, members of Congress, and even members of federal advisory committees often turn to these bodies, or seek their creation. Take the recent example of the National Academy of Science, Engineering and Medicine report “Simplifying Research Regulations and Policies”, whose recommendations focus primarily on increasing regulatory harmony between government agencies rather than actually removing or changing government requirements.
Incentive Structures Favor the Status Quo
Agencies have enormous incentives to protect their turf – particularly their legal authorities – under these coordination bodies. Given the uncertainty of funding and legislation, and the risk that dedicating work toward a particular task might result in a reallocation of resources from something that agencies are already assigned to do, the most common output created by these interagency bodies is a line of best fit that deftly navigates the specific interests of each federal agency, sometimes with compromises that water down Executive or Legislative intent.
Worse, agencies in question might not have available time or resources for officers to dedicate the type of high-level attention needed to actually implementing an ideal solution. As a result, the chair for these committees often takes the lead in developing a work plan, which is usually heavily-shaped by individual experiences within a single government agency or even single industry. If there is significant political support or pressure for the interagency organization to produce a product, like a proposed regulation or report, other government departments and agencies might not even weigh in substantively to maintain plausible deniability. Instead, such agencies may seek to minimize the number of new requirements or dilute requirements to avoid affecting agency operations.
In an extreme example of the consequences of understaffing an interagency coordination body while concentrating one agency’s perspective in a single individual with little actual authority, the Department of Health and Human Services (HHS) unwound nearly eight years of bilateral negotiations between the United States and the European Union during the Biden administration because their subject matter expert unexpectedly and unfortunately passed away during the negotiation’s final stages. Ironically, this was a topic of great HHS interest – improving the ability for US and EU researchers to share human health-related data across the Atlantic. HHS’ failure to appoint a new champion effectively ended the negotiation, fueled by the agency’s claims that appropriate vetting of the final policy could not be prioritized given staffing demands and a lack of expertise. The impacts of this non-decision were not localized to government laboratories, but also stakeholders across industry and the biomedical research ecosystem.
The products of these coordination committees generally favor the experience of the chair, moderated primarily by the government’s ability to respond to a new (usually unfunded) demand within existing resources. This seldom answers the mail requested by the Executive Office of the President, Congress, or the recommendations offered by outside advisory groups, and can place costly new requirements on the rest of the ecosystem.
Thou Shalt Not Suggest Future Financial Commitments are Needed
One of the perennial challenges that interagency coordination groups face is the fact that recommendations for action may conflict with the annual President’s Budget Discretionary Request (PBR). This is based on the expectation that the Executive Branch speaks on budget issues with one voice. Likewise, the Anti-Lobbying Act is generally understood within the Executive Branch to prohibit agencies from seeking additional funding or appropriations. Responses to Congressional requests are often vetted by the Office of Management and Budget.
This is complicated by the fact that when Congress asks an agency for a proposal on how to do something, there is a general expectation that the Executive Branch provide a clear and comprehensive answer that will allow legislators to act expeditiously on resolving the problem, particularly with respect to how Congress can help. This also happens when agencies respond to crises, when political appointees seek to open new lines of effort, or when international partners come to the U.S. government with a proposal that is generally favorable to the President. Even if the President favors acting on the proposal, it can be difficult for agencies to support action that is not accounted for in the PBR.
Because these requests generally lack funding information that would place the recommendations outside the scope of the PBR, there are four possible outcomes:
The interagency group will often:
- Develop a recommendation that places resource burdens on entities that are not a part of the federal government (e.g., through the establishment of additional unfunded mandates placed on organizations seeking federal grants, contracts, or cooperative agreements);
- Provide with a “zero cost solution” that minimizes the resource expenditure required of the government institution but may not actually solve the problem;
- Remain silent or blame Congress (or the White House Office of Management and Budget (OMB)) for not providing sufficient funding to achieve a particular objective, sometimes forcing committee staff to seek outside advice on what implementing recommendations might cost. Such efforts could represent a de facto information collection, increasing the burden placed on the affected stakeholders; or
- Fail to answer the request after the interagency coordination effort breaks down or loses its champion.
Obviously, these results inherently mask the true cost of the government’s activities and minimizes the work undertaken by the executive agencies. One specific example that we encountered in our time in government involved a suggestion that the interagency group explicitly state that individuals stranded in space or on other planets on commercial space missions would not be rescued because the government had not and would not request funding for such an eventuality. The interagency group ended up not releasing their product.
Former staff who served in the current administration have offered their solution to the coordination issue: only request input from agencies when their perceived equities are in play. The problem with such an assumption is that other government agencies frequently have equities that are not immediately visible to the Executive Office of the President or other government bodies, creating a probability that the exclusion of that agency could result in them becoming a process spoiler sometime in the future. Sometimes agencies use this as a tactic to kill or stall an initiative by intentionally falling to staff participation on an interagency body and then complaining at the 11th hour that they weren’t consulted on the group’s policy product. When rulemakings are in play, the interagency deliberative processes defined by Executive Order 12866 are supposed to be followed to prevent this type of skullduggery. However, even then OMB’s Office of Information and Regulatory Affairs (OIRA), which coordinates and enforces the process, often provides agencies (and even external organizations) with a great deal of latitude to effect their delay tactics.
Agency Staff Feels the Need to Protect their Decisionmaking Authorities
In the words of one of our former coworkers, “agencies will do anything to protect their ability to make an independent decision.” Coordination bodies frequently are expected to set priorities that could tie the hands of a government agency (or the Presidency) at a future date. This is particularly acute in science, when the funding cycle and normal life of a scientific project usually doesn’t align with the political calendars of Congress or the Presidency. As a result, agency staff and their political leadership are disincentivized to make recommendations that would limit their ability to make a different decision at some point in the future, or encouraged to non-concur to protect the ability of current staff to interject. Some agencies, particularly the Department of Health and Human Services and the Department of Defense, are particularly aggressive in using these tactics given their substantial resources and long-mission timelines which may be vulnerable to future political disruption.
Ultimately, the aspiration for a unified federal vision often founders on the jagged rocks of agency tribalism. When agencies prioritize the preservation of their legal, administrative, or cultural turf and discretionary autonomy over the broader implementation of top-down mandates, interagency coordination transforms from a tool of progress into a performative exercise in risk mitigation. This protectionism creates a gravity well of inertia, where the resulting vector rarely points toward innovation or rationalization, but instead toward a diluted status quo that safeguards agency equities at the expense of (potentially) good governance. Until the incentive structures of the administrative state are realigned to reward cross-cutting outcomes over parochial independence, even the most robust top-level policies will continue to be slowly hollowed out by the very departments tasked with their implementation.
Plan of Action
Governing is hard. It forces organizations to make difficult decisions, accounting for tradeoffs and mitigating internal and external organizational risks. When Congress or the President ask an organization to provide recommendations on how to solve a problem, ideally the result should include a credible solution. Here, we recommend a path forward that protects the benefits of a federated system (strategic redundancy, checks-and-balances, etc) while minimizing tribalism that works against efficiencies of interagency coordination and implementation of policies.
Recommendation 1. Formal advisory committees to the government should be limited from deferring actions within their scope to interagency deliberative bodies.
This could be achieved simply through a White House-level policy memorandum, though it could also be accomplished in agency practice through charge letters to advisory groups, updates to policy for the National Academies and DC think tanks, or instructions in Congressional charging legislation.
When advisory groups like the National Academies of Sciences, Engineering, and Medicine produce recommendations or reports for the executive branch, the advisory committees formed to do the work will frequently recommend that an interagency body coordinate, develop strategies, or produce recommendations aimed at resolving a high level policy objective. For instance, the 2022 report “Protecting U.S. Technological Advantage” produced four recommendations that requested the creation of six new government processes to create new definitions, assess vulnerabilities, identify essential elements, develop a national strategy, and develop a new policy framework. By doing so, the advisory committee delegates its responsibility to recommend action and sets up a cascade of additional administrative burden that flows to the federal agencies (if they accept the challenge in the first place).
In the case of the “Protecting U.S. Technological Advantage” report, the end product implicated multiple government organizations that were not involved in the creation of the report (including numerous White House components) making it less likely that the recommendations would be adopted. Recommendations focusing on the outcome members of the Committee wanted from the government, in addition to the authorities or processes required to effectuate the outcome, would have made it easier for individuals in the government to support the recommendations and seek Congressional support.
Similarly, recommendations that suggest stronger interagency coordination, for instance to harmonize interagency policy and practice to reduce administrative burden, tend to ignore the factors cited earlier about the various factors that pull against successful policy coordination efforts. Instead, recommendations that weigh the tradeoffs associated with specific policy options and suggest answers to hard decisions are more likely to provide the information sought by policymakers and lawmakers, alike.
Decadal surveys, on the other hand, tend to provide science agencies and congress with relatively straightforward lists of priorities under different budget scenarios that are easily understood by budget officials and appropriators. While these recommendations are seldom followed in total by government agencies, they are proven delivery tools for program and policy implementation.
The government already takes similar measures in multilateral international activities. “Instruction cables” provided to members of U.S. delegations to international working groups contain express instructions to limit the creation of new working groups or bodies under the international organization to limit the proliferation of such mechanisms in international fora. Charge letters from agencies, language in Congressional authorizing legislation for National Academies studies, and other directives limiting the proliferation of new working groups and committees could include similar language.
Recommendation 2. Recommendations from interagency bodies that invoke new agency or impacted entity actions should include economic impact assessments.
Congress should require that interagency bodies identify and publicly disclose the costs to implement the group’s recommendations, including any expected costs to non-government organizations when those recommendations involve any changes to agency or impacted entity behavior. Interagency reports often set ambitious goals without accounting for the unfunded mandates they create for agencies and the private sector. The National Science and Technology Council’s October 2022 National Strategy for Advanced Manufacturing outlined sweeping goals for industrial decarbonization and supply chain restructuring, yet it lacked a granular economic impact assessment regarding the capital expenditures required by small to medium enterprises to comply with suggested standards. Without this data, recommendations risk becoming aspirational documents rather than actionable blueprints because the entities responsible for execution are left to discover the true costs only after the policy momentum has already shifted. Moreover, this leads to further fragmentation, redundancy, and increased burden across regulated sectors as any resulting rulemaking acting on these recommendations would have to engage its own separate cost analysis.
The consequences of omitting economic analysis are evident in recommendations regarding cybersecurity protocols often generated by Policy Coordination Committees. For example, the interagency implementation plans following Executive Order 14306 on Sustaining Select Efforts To Strengthen the Nation’s Cybersecurity often encourage agencies to adopt stringent data sharing frameworks without quantifying the compliance drag on regulated entities in the energy and telecommunications sectors. When recommendations do not account for the labor hours or hardware upgrades necessary for implementation, they can lead to significant market friction and cost surprise. By requiring an assessment at the outset, Congress can prevent the adoption of technically sound, but economically disruptive, policies that may stifle the innovation they aim to protect. Congress did enact the Unfunded Mandates Reform Act of 1995 to limit the impact of these types of interventions, but the application of the act is limited to state, local, and tribal governments (as opposed to industry or academic sectors).
Conversely, when interagency bodies integrate economic assessments, the resulting policy is more resilient and credible. The Interagency Working Group (IWG) on Social Cost of Greenhouse Gases serves as a primary example of a body that centers its output on economic modeling, as seen in its February 2021 Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide. By providing a quantified value for the social cost of carbon, the IWG ensured that any subsequent agency actions are grounded in a rigorous benefit-cost framework. Similarly, certain Federal Advisory Committee Act committees such as those advising the Department of Transportation frequently include economic subcommittees to vet recommendations. These examples show that when the economic price tag is transparent, stakeholders can provide more meaningful feedback and agencies can prioritize actions that offer the highest return on investment.Integrating economic impact assessments into the interagency process aligns these high-level recommendations with the gold standard of federal regulatory governance found in Executive Order 12866 and the Office of Information and Regulatory Affairs review process. Currently, a significant gap exists where a policy may be developed in an interagency report without the rigorous economic and regulatory impact analyses required during rulemaking. By requiring these assessments earlier in the deliberative stage, this recommendation ensures that the logic of balancing societal benefits against compliance costs is present from the moment of inception. This prevents regulatory path dependency where an agency feels compelled to codify a recommendation that has not yet faced the scrutiny of economic trade-offs, which enhances both transparency and fiscal responsibility.
Recommendation 3. Congress should fund its reporting demands on the interagency, particularly to ensure adequate staffing and to avoid diverting resources away from mission-focused activities.
Congress should appropriate resources when it makes reporting mandates, including to already-established reporting programs and interagency deliberative bodies. This would ensure the project actually happens and can be carried through to completion. This also frequently means that staff are diverted from their core duties to produce these reports, creating an additional drain on agency resources.
This challenge is particularly acute for White House components like OSTP, which are not budgeted to fulfill the number of recommendations and reporting obligations placed on the organization by Congress. Such reports are often left to the initiative of short-term detailees and Intergovernmental Personnel Act (IPA) appointees who may be unable to thoroughly answer the reporting requirements relevant to their portfolio while they are also satisfying Administration demands. As a result, reports connected to immediate political demand signals are generally prioritized over longer-term planning exercises and strategic assessments, leaving much work – including work tasked by Congress by law – frequently incomplete.
Recommendation 4. “Center of government” organizations, like OMB, OSTP, and the National Security Council (NSC) should actively seek and provide funding and direction to support Administration goals and objectives.
Such efforts should be supported by champions, both at the senior level in the center of government organization as well as champions within the interagency who have the authority to clear bottlenecks and sufficient top cover to seek necessary funding and other resources.
It is an oft-stated maxim in government “show me your budget and I’ll show you your strategy.” When agencies are asked to do something based on a top down directive, political resources should be aligned with ensuring that the effort succeeds. Frequently this is not the case.
In international affairs, the visit of a high-level foreign official will frequently trigger requests, most often from the NSC and the U.S. Ambassador to a country for projects or programs that can be offered to demonstrate to the foreign partner the value of the bilateral relationship between the two countries. There is just one problem–with the exception of defense and some security programs, government agencies almost never have dedicated resources to support such requests. The situation becomes worse when you realize that there are literally hundreds, if not thousands of visits to the United States over the course of an Administration. Interagency officials responsible for a priority administration program or working on headline-grabbing material are likely to be sequestered by these requests, diverting attention away from the execution of their programs. During our time in government, we would frequently find ourselves fending off such requests from other White House components or the State Department in the interest of protecting the time and resources of agencies in our respective domains. The urgency to provide something usually results in low-effort or empty commitments that are easily placed in contrast with those of foreign governments like the European Union or People’s Republic of China.
While we certainly understand the demand that administrations be able to produce examples of how they are delivering on the President’s priorities, it is important that such requests be properly staffed and resourced. When there are obstacles, the “center of government” organizations should provide sufficient support from champions to overcome those obstacles in order to ensure their successful completion. A good press release is seldom a substitute for the delivery of an actual result.
Conclusion
The persistent failure of interagency coordination is a systemic result of an administrative state that structurally prioritizes parochial autonomy of specific agency equities over collective efficacy. As demonstrated by the fragmented governance of space activities and the “zero-cost” compromises of underfunded committees, the current coordination framework incentivizes performative alignment rather than meaningful reform. These failures place an undue administrative burden on the public and stifle innovation and good governance.
To bridge the gap between policy aspiration and implementation, the federal government must push back against tribalism that currently defines interagency coordination. By barring advisory committees from delegating their responsibilities to the interagency, mandating rigorous economic transparency for new proposals, and ensuring that Congress provides the specific resources required for coordination, the Executive Branch can finally coordinate policy priorities. We’ve proposed that the federal interagency deliberative process requires a fundamental realignment of incentives, ensuring that the Government speaks with “one voice,” expressed through decisive action rather than just diluted reports, unfunded and unimplementable mandates, and perennially delayed policymaking. Such reforms will provide solid ground on which policy recommendations can be more safely landed.
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