Death by Regulation : How Regulations Can Increase Mortality Risk

This paper updates the cost-per-life-saved cutoff, which is a cost-effectiveness threshold for life- saving regulations, whereby regulations costing more per life saved than this threshold level are expected to increase mortality risk on net. Two competing methods of deriving the cutoff exist: a direct approach based on empirical observation and an indirect approach grounded in economic theory. Both methods build from the assumption that changes in income lead to changes in mortality risk. The likely mechanisms driving this relationship are discussed, with support from recent empirical studies. The indirect approach is preferable in that it avoids the problems of endogeneity of health status and income found with the direct approach. The cost-per-life-saved cutoff value at which regulations increase mortality risk is estimated to have a lower bound value of $75.4 million and an upper bound value of $123.2 million, with a midpoint value of $99.3 million. This cutoff value range is compared with cost-effectiveness estimates for a series of recent policies, including several state expansions of the Medicaid public insurance program in the first few years of the 21st century, an early version of the “travel ban” executive order that restricted refugee admissions into the United States, and nine recent air pollution regulations from the Environmental Protection Agency. The paper concludes that the mortality risk test is an important and underutilized tool in the policy analyst's toolkit, both as an overall test of regulatory efficacy and as an integral component of calculations of net risk effects of policies