Her parents, Zerin and Jehangir Narioshang Rao, were Parsi physicians from India who immigrated to the United States in 1972.

[5] After high school, Rao studied ethics, politics & economics, and philosophy at Yale University, graduating in 1995 with a Bachelor of Arts, cum laude.

She was legal counsel to the U.S. Senate Judiciary Committee from 2000 to 2001, then clerked for Justice Clarence Thomas of the U.S. Supreme Court from 2001 to 2002.

Former OIRA Administrator Susan Dudley, who served under President George W. Bush, described Rao as "an excellent choice to lead OIRA...In addition to a sharp legal mind, she brings an openness to different perspectives and an ability to manage the competing demands of regulatory policy.

"[2] Opposition to Rao came from groups such as the League of Conservation Voters (LCV), who said she has "led efforts to roll back fundamental environmental protections" and has "misuse[d] the regulatory review process for partisan political purposes.

[17] Rao's nomination attracted opposition due to articles that she wrote on race, sexual assault, feminism, and individuals with disabilities.

"[22] Democrats expressed concern that rules Rao worked to repeal in her role as administrator of the White House Office of Information and Regulatory Affairs could face legal challenges and wind up before the D.C.

"[22] Republican Senator Josh Hawley questioned whether she was sufficiently socially conservative regarding abortion rights but ultimately voted for her confirmation.

"[41] The author of that article argued that Rao's contributions to the administrative law field have been built on a declinist vision of Congress.

The author suggests that Rao's "Americana Administrative Law" is a pitch for an aggrandized judiciary that can protect Congress from its own systemic decline.