Central Repository for Agency Guidance

Full Title:
GOOD Act

Summary#

This bill would require federal agencies to publish their nonbinding guidance documents in one public place online. The main change is a new, single website (set by the Director of the Office of Management and Budget) where agencies must post new guidance when issued and upload existing guidance within 180 days. The stated goal is to increase public access to agency guidance.

  • Main change: Agencies must post guidance documents on a single internet site designated by the OMB Director and link to that site from the agency’s own website.
  • Timing: New guidance must be posted when issued. Existing guidance must be posted within 180 days of the law. The Director must pick the website within 90 days.
  • Scope: “Guidance document” is defined very broadly and can include memos, notices, letters, blog posts, speeches, no-action letters, and similar items that do not have the force of law.
  • Rescinded guidance: When an agency rescinds guidance, it must keep the old document online and clearly mark it as rescinded, give the rescission date, and, if applicable, show the court case number that led to rescission.
  • FOIA protection: Documents or information that are exempt from release under the Freedom of Information Act (FOIA) do not have to be posted.

What it means for you#

  • Agencies and federal staff

    • Must upload all non‑FOIA‑exempt guidance to the designated central website.
    • Must add a prominent link on the agency website to the central location.
    • Must label and keep rescinded guidance available with date and court case number if applicable.
  • Businesses, nonprofits, and regulated parties

    • Could find federal guidance more quickly in one place instead of searching many agency sites.
    • May need to check the central repository more often to track agency interpretations that affect compliance.
  • Lawyers, compliance officers, and researchers

    • Will likely have easier access to a wider range of agency statements and historical guidance, including rescinded items.
  • Members of the public and journalists

    • Should have a single, searchable place to read agency guidance, unless the material is FOIA‑exempt (for example, classified or certain internal deliberations).

Expenses#

No publicly available information.

  • The bill does not include a fiscal note in the provided material.
  • Likely administrative costs (inferred): building and running the central website; categorizing, uploading, and tagging large numbers of documents; ongoing maintenance.
  • Agencies may need staff time, IT resources, or contracts to comply.
  • The bill does not set penalties or funding to cover these costs.

Proponents' View#

  • The bill appears intended to increase transparency by making agency guidance easier to find in one place.
  • This could be seen as helping regulated parties understand agency expectations.
  • Keeping rescinded guidance visible with clear labels could improve record‑keeping and public understanding of changes in policy.
  • A central repository may reduce time spent searching across many agency websites.

Opponents' View#

  • One concern is that the bill’s definition of “guidance document” is very broad (includes speeches and blog posts). This may create a large workload for agencies to collect and post many items.
  • It is unclear how much this will cost agencies and who will pay for website building and ongoing maintenance.
  • The bill does not set enforcement rules or penalties for agencies that do not comply.
  • Maintaining rescinded guidance online could cause confusion if a user does not notice the “rescinded” label.
  • FOIA exemptions remain, so some important guidance could still be withheld; it is not clear how frequently agencies will invoke those exemptions.