The State of American Federalism
2017–2018: Unilateral Executive Action,
Regulatory Rollback, and State Resistance
Shanna Rose* and Greg Goelzhauser†
*Claremont McKenna College
†Utah State University; [email protected]
The state of American federalism in 2017^2018 is characterized by federal policy reversals, as the
Trump administration and congressional Republicans continue to undo many of the Obama
administration’s policies. Two themes are highlighted in this essay. First, major policy changes
continue to be undertaken primarily through unilateral executive action, even with Republicans
holding the presidency and both the House and Senate. Ideological divisions within the
Republican Party prevented Congress from enacting major legislation, save for a tax reform
measure, and resulted in policy changes on health care, immigration, and the environment being
made through executive and administrative action. Another prominent feature of governance in
the early part of theTrump administration has been state resistance to federal directives, taking the
form primarily but not exclusively of state attorney general (AG) lawsuits. Democratic AGs filed
lawsuits challengingTrump administration actions on immigration and clean energy in particular.
Democratic governors and state legislators also took a variety of other actions to resist Trump
administration policies. The federal courts also continue to play an active role in shaping and
adjudicating controversies impacting federalism.
The state of American federalism in 2017–2018 is characterized by federal policy
reversals, as the Trump administration and congressional Republicans continue to
undo many of the Obama administration’s major policies ranging from the
Affordable Care Act (ACA) to the Clean Power Plan. This development reflects the
continuation of trends that emerged in the first few months of the Trump
administration, when “the arrival of a new administration with radically different
priorities” ushered in “broad policy reversals in arenas such as health care,
immigration, and the environment, with potentially important implications for
federalism and intergovernmental relations” (Goelzhauser and Rose 2017).
Two additional themes emerged in 2017–2018. First, unilateral executive action
continued to play a prominent role in policymaking at the federal level despite
unified Republican control of the federal government. With the exception of the
Publius:TheJournal of Federalism volume 48 number 3, pp. 319^344
doi:10.1093/publius/pjy016
AdvanceAccess publication May 24, 2018
� TheAuthor(s) 2018. Published by Oxford University Press on behalf of CSFAssociates: Publius, Inc.
All rights reserved. For permissions, please email: [email protected]
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/publius/article-abstract/48/3/319/5003360 by 81225740 user on 07 January 2019
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Tax Cuts and Jobs Act that passed in December 2017, widening ideological
division.
Protiviti Flash report details key developments from the first 100 days of the Trump administration, from a business perspective. For more information, go to http://ow.ly/NDPm30bjnfB
Republicans are more likely to weaken the Affordable Care Act through indirect means rather than outright repeal. They have previously undermined social and environmental policies by cutting funding, appointing unsupportive officials, and weakening enforcement. Republicans will likely use similar tactics against the healthcare law, such as reducing funding that is necessary for implementation, conducting hearings to expose perceived flaws, and allowing states to weaken consumer protections. The greatest challenge for the healthcare program may be this strategy of gradual weakening through indirect attacks rather than constitutional challenges.
The document provides updates on state and local policy and politics issues. Key points include:
- A study found the Senate tax plan would increase GDP, wages, and jobs over the long term. Vice President Pence promoted tax reform to governors. The plan puts some vulnerable House Republicans in a difficult position.
- Changes to state and local tax deductions in the tax plans could impact budgets in high-tax states like New York and California. Some states are looking to weigh in on reforms to state and local tax deductions.
- Other topics covered include infrastructure provisions in the tax bills, rising state spending, medical marijuana policies, trade deals like NAFTA and TPP, and climate accord commitments despite the US withdrawal from the Paris
Politics and the Affordable Care Act.docxstudywriters
Feldstein's cost-benefit analysis influenced Republican efforts to repeal the Affordable Care Act. Legislators aim to maximize reelection chances by gaining voter support. Republicans wanted to repeal the ACA, but the 2018 elections showed voters prioritized healthcare and felt Democrats better addressed the issue. This made Republicans pause their repeal attempts for two years. Similarly, Feldstein's analysis may impact legislators' positions on policies like Medicaid and Medicare cuts, as supporting such legislation could aid reelection. While campaigning in 2016, Trump pledged not to cut these programs to attract voters, but his 2020 budget proposed major spending reductions.
Running Head ROLE OF EXECUTIVE ORDER IN ACARole of Executiv.docxtodd521
Running Head: ROLE OF EXECUTIVE ORDER IN ACA
Role of Executive Order in ACA
2
Role of Executive Order in ACA
By: Ameki Lee
Dr. White
MPA6501 SU01 State and Local Government and Intergovernmental Relations
Role of Executive Order in ACA
Affordable Act Care has been a significant issue in Texas State for the past seven years. Texas governor, Greg Abbott has been on the frontline in fighting the implementation of the Act in Texas and America. The governor's office claims that the penalties related to avoiding the Act are unconstitutional and not democratic (Toussaint, 2017). Furthermore, the Governor argues that the Affordable Care Act should be put on halt while the cause is being liquidated. However, the governor does not concentrate on improving the policy rather than doing away with it. Greg Abbott believes the pre-existing conditions are the major barriers for the effectiveness of the act. The Affordable Care Act allows people to purchase the policy even with pre-existing conditions. In favor of the governor, the act should limit the purchase of the act during such conditions with the aim of reducing the cost as well as the rates of insurance. Therefore, an appeal can be made based on the governors value since most Americans are complaining about the same issue (Toussaint, 2017).
Affordable Act Care was implemented under the executive administrative policy. In America, an executive order is directed by the president on the managers of various federal governments with the aim of forcing policy to law. In 2013, former president of America Barack Hussein Obama issued a directive on the implementation of the Affordable Care Act (Rovner, 2018). The current President, Donald Trump began fighting the Act by attacking the executive committee and even dismantling it. An executive order is written, signed and published by the president's office and directed to various federal departments. The Executive order directed all agencies responsible under the Affordable Care Act provision that will provide a regulatory and fiscal burden on entities that will be reluctant on adopting a policy. Also, the Executive Order directs the same agencies to offer greater flexibilities and collaboration on implementing such healthcare policies.
Since the implementation of the Affordable Care Act in 2010, the policy has suffered various criticisms in its debate. For those who believed that the primary goal of the Act was to make insurance more affordable didn’t achieve their purpose. However, the policy has caused more Americans to have access to medical insurance hence fostering a healthy nation. Since the Act is applicable in improving the public health of all Americans, it includes various resources in healthcare like materials, funds, personnel and other things that can be utilized in the provision of healthcare service. The act is also responsible for ensuring all medical care institutions have the necessary resource for effective operations (Ba.
PADM-02 You did this before add 5 for the comments below .TyComm.docxgerardkortney
PADM-02 You did this before add 5 for the comments below .Ty
Comments for below discussions: Yes, women have expanded their presence in many fields in the workplace. I always find the 80% number interesting. I wonder if they are including part-time or just full-time and whether they are comparing the exact same job, education, and experience or lumping everything together. That would be a good thing to know. Did your source say? I don’t know and I just wonder.
Forces shaping the implementation of the Act
Today, ladies make up about half the portion of the U.S. labor force and more ladies than any time in recent history are the providers in their families. More ladies are likewise working in positions and fields that have been customarily possessed by men. However in 2015, the normal lady working all day all year in the United States earned just 80 percent of what the run of the mill man earned working all day all year. The compensation crevice is much more prominent for African American and Latina ladies, with African American ladies gaining 63 pennies and Latina ladies acquiring 54 pennies for each dollar earned by a white non-Hispanic man. The gender wage gap keeps on being an undeniable and determined issue that proceeds to dupe American ladies and their families (National Research Council, 2011).
Secondly, disparities in the wages earned for the two genders was found to infringe on the rights of the employees and their economic rights. Unfair wages to women depress their income and consequently their living standards. The employees are forced sub-standard healthcare services and live in houses that are very uncomfortable. To the organization, denial of equal pay hinders optimum utilization of labor. Workers in such discrimination industries feel unappreciated and even worse not paid that which they deserve. They, therefore, limit their input at work thus affecting production and efficiency. The segregation of women to Pink Color jobs is the leading cause of labor disputed in organization. The representation of their grievances and with consideration of the negative impacts all fueled the legislation of the Equal Pay Act.
Theories of Politics
National elites empower organizations to implement policies efficient for the realization of equal pay. Elite bargaining is a political strategy for implementing policies where the two bodies negotiate on policies to attain a middle ground for favorable implementation. National elites and economic organizations work in coordination to support the legislation and implementation the Equal Pay Act as this was also a matter of national concern. Rational choice also had a part to play in the formulation and implementation of the policy. The rational policy stands to ensure that a logical and reasonable policy and providences are reached at. Ideally, a policy such as the Equal Act policy should aim at striking harmony in the wages of the labor force without a.
Types of Public PolicyRegulatory PolicyRegulatory policy is desi.docxouldparis
Types of Public Policy
Regulatory PolicyRegulatory policy is designed to limit the actions of persons or groups so as to protect the general public or a substantial portion of the public. For example, people are prohibited from selling certain drugs, polluting the air and water, and engaging in monopolistic business practices. One form of regulation simply focuses on illegal criminal activity; it is a crime to do certain things. State and local governments have special responsibilities in this area, and certain federal agencies, such as the Drug Enforcement Administration, are active here as well. Another form of regulation focuses on American business and seeks to ensure fair and competitive practices. Indeed, the first major regulatory effort in this country came in 1887, when the federal government created the Interstate Commerce Commission to regulate the railroads. Similar regulatory agencies today monitor securities (Securities and Exchange Commission), commodity exchanges (Commodity Futures Trading Commission), and labor relations (National Labor Relations Board), among others.
A modern regulatory area is concerned with access to certain goods available to the public generally, such as the airwaves (regulated by the Federal Communications Commission) or clean air and water (regulated by the Environmental Protection Agency). Other regulatory bodies focus on protecting health and safety in such areas as consumer protection (Consumer Product Safety Commission), air travel (Federal Aviation Administration), food (Food and Drug Administration), and workplace safety (the Occupational Safety and Health Administration).
Although federal regulation of economic activities has seen several waves of growth through the past century (Ripley & Franklin, 1987), the last two decades have seen somewhat of a movement in the opposite direction. Late in the Carter administration and extending through the Reagan administration, there were several efforts to deregulate certain industries. The Civil Aviation Board was disbanded in 1984, and over the following decade significant areas of transportation, telecommunications, and banking were deregulated. Moreover, regulations were eliminated or enforcement slowed down in areas such as workplace, auto, and consumer products safety.
During the 1990s, however, as many federal agencies relaxed their regulatory grip, a few attempted to expand their authority. The Environmental Protection Agency sought to set standards for pesticide and cancer risk, while the Occupational Safety and Health Administration created guidelines for reducing violent crime in retail locations open at night (Niskanen, 2001). The Food and Drug Administration attempted to expand its jurisdiction to the tobacco industry by establishing nicotine as a drug, which would have given federal regulators the power to control tobacco products. This move, however, was challenged by the tobacco companies, and in 2000 the Supreme Court ruled against the fed ...
Protiviti Flash report details key developments from the first 100 days of the Trump administration, from a business perspective. For more information, go to http://ow.ly/NDPm30bjnfB
Republicans are more likely to weaken the Affordable Care Act through indirect means rather than outright repeal. They have previously undermined social and environmental policies by cutting funding, appointing unsupportive officials, and weakening enforcement. Republicans will likely use similar tactics against the healthcare law, such as reducing funding that is necessary for implementation, conducting hearings to expose perceived flaws, and allowing states to weaken consumer protections. The greatest challenge for the healthcare program may be this strategy of gradual weakening through indirect attacks rather than constitutional challenges.
The document provides updates on state and local policy and politics issues. Key points include:
- A study found the Senate tax plan would increase GDP, wages, and jobs over the long term. Vice President Pence promoted tax reform to governors. The plan puts some vulnerable House Republicans in a difficult position.
- Changes to state and local tax deductions in the tax plans could impact budgets in high-tax states like New York and California. Some states are looking to weigh in on reforms to state and local tax deductions.
- Other topics covered include infrastructure provisions in the tax bills, rising state spending, medical marijuana policies, trade deals like NAFTA and TPP, and climate accord commitments despite the US withdrawal from the Paris
Politics and the Affordable Care Act.docxstudywriters
Feldstein's cost-benefit analysis influenced Republican efforts to repeal the Affordable Care Act. Legislators aim to maximize reelection chances by gaining voter support. Republicans wanted to repeal the ACA, but the 2018 elections showed voters prioritized healthcare and felt Democrats better addressed the issue. This made Republicans pause their repeal attempts for two years. Similarly, Feldstein's analysis may impact legislators' positions on policies like Medicaid and Medicare cuts, as supporting such legislation could aid reelection. While campaigning in 2016, Trump pledged not to cut these programs to attract voters, but his 2020 budget proposed major spending reductions.
Running Head ROLE OF EXECUTIVE ORDER IN ACARole of Executiv.docxtodd521
Running Head: ROLE OF EXECUTIVE ORDER IN ACA
Role of Executive Order in ACA
2
Role of Executive Order in ACA
By: Ameki Lee
Dr. White
MPA6501 SU01 State and Local Government and Intergovernmental Relations
Role of Executive Order in ACA
Affordable Act Care has been a significant issue in Texas State for the past seven years. Texas governor, Greg Abbott has been on the frontline in fighting the implementation of the Act in Texas and America. The governor's office claims that the penalties related to avoiding the Act are unconstitutional and not democratic (Toussaint, 2017). Furthermore, the Governor argues that the Affordable Care Act should be put on halt while the cause is being liquidated. However, the governor does not concentrate on improving the policy rather than doing away with it. Greg Abbott believes the pre-existing conditions are the major barriers for the effectiveness of the act. The Affordable Care Act allows people to purchase the policy even with pre-existing conditions. In favor of the governor, the act should limit the purchase of the act during such conditions with the aim of reducing the cost as well as the rates of insurance. Therefore, an appeal can be made based on the governors value since most Americans are complaining about the same issue (Toussaint, 2017).
Affordable Act Care was implemented under the executive administrative policy. In America, an executive order is directed by the president on the managers of various federal governments with the aim of forcing policy to law. In 2013, former president of America Barack Hussein Obama issued a directive on the implementation of the Affordable Care Act (Rovner, 2018). The current President, Donald Trump began fighting the Act by attacking the executive committee and even dismantling it. An executive order is written, signed and published by the president's office and directed to various federal departments. The Executive order directed all agencies responsible under the Affordable Care Act provision that will provide a regulatory and fiscal burden on entities that will be reluctant on adopting a policy. Also, the Executive Order directs the same agencies to offer greater flexibilities and collaboration on implementing such healthcare policies.
Since the implementation of the Affordable Care Act in 2010, the policy has suffered various criticisms in its debate. For those who believed that the primary goal of the Act was to make insurance more affordable didn’t achieve their purpose. However, the policy has caused more Americans to have access to medical insurance hence fostering a healthy nation. Since the Act is applicable in improving the public health of all Americans, it includes various resources in healthcare like materials, funds, personnel and other things that can be utilized in the provision of healthcare service. The act is also responsible for ensuring all medical care institutions have the necessary resource for effective operations (Ba.
PADM-02 You did this before add 5 for the comments below .TyComm.docxgerardkortney
PADM-02 You did this before add 5 for the comments below .Ty
Comments for below discussions: Yes, women have expanded their presence in many fields in the workplace. I always find the 80% number interesting. I wonder if they are including part-time or just full-time and whether they are comparing the exact same job, education, and experience or lumping everything together. That would be a good thing to know. Did your source say? I don’t know and I just wonder.
Forces shaping the implementation of the Act
Today, ladies make up about half the portion of the U.S. labor force and more ladies than any time in recent history are the providers in their families. More ladies are likewise working in positions and fields that have been customarily possessed by men. However in 2015, the normal lady working all day all year in the United States earned just 80 percent of what the run of the mill man earned working all day all year. The compensation crevice is much more prominent for African American and Latina ladies, with African American ladies gaining 63 pennies and Latina ladies acquiring 54 pennies for each dollar earned by a white non-Hispanic man. The gender wage gap keeps on being an undeniable and determined issue that proceeds to dupe American ladies and their families (National Research Council, 2011).
Secondly, disparities in the wages earned for the two genders was found to infringe on the rights of the employees and their economic rights. Unfair wages to women depress their income and consequently their living standards. The employees are forced sub-standard healthcare services and live in houses that are very uncomfortable. To the organization, denial of equal pay hinders optimum utilization of labor. Workers in such discrimination industries feel unappreciated and even worse not paid that which they deserve. They, therefore, limit their input at work thus affecting production and efficiency. The segregation of women to Pink Color jobs is the leading cause of labor disputed in organization. The representation of their grievances and with consideration of the negative impacts all fueled the legislation of the Equal Pay Act.
Theories of Politics
National elites empower organizations to implement policies efficient for the realization of equal pay. Elite bargaining is a political strategy for implementing policies where the two bodies negotiate on policies to attain a middle ground for favorable implementation. National elites and economic organizations work in coordination to support the legislation and implementation the Equal Pay Act as this was also a matter of national concern. Rational choice also had a part to play in the formulation and implementation of the policy. The rational policy stands to ensure that a logical and reasonable policy and providences are reached at. Ideally, a policy such as the Equal Act policy should aim at striking harmony in the wages of the labor force without a.
Types of Public PolicyRegulatory PolicyRegulatory policy is desi.docxouldparis
Types of Public Policy
Regulatory PolicyRegulatory policy is designed to limit the actions of persons or groups so as to protect the general public or a substantial portion of the public. For example, people are prohibited from selling certain drugs, polluting the air and water, and engaging in monopolistic business practices. One form of regulation simply focuses on illegal criminal activity; it is a crime to do certain things. State and local governments have special responsibilities in this area, and certain federal agencies, such as the Drug Enforcement Administration, are active here as well. Another form of regulation focuses on American business and seeks to ensure fair and competitive practices. Indeed, the first major regulatory effort in this country came in 1887, when the federal government created the Interstate Commerce Commission to regulate the railroads. Similar regulatory agencies today monitor securities (Securities and Exchange Commission), commodity exchanges (Commodity Futures Trading Commission), and labor relations (National Labor Relations Board), among others.
A modern regulatory area is concerned with access to certain goods available to the public generally, such as the airwaves (regulated by the Federal Communications Commission) or clean air and water (regulated by the Environmental Protection Agency). Other regulatory bodies focus on protecting health and safety in such areas as consumer protection (Consumer Product Safety Commission), air travel (Federal Aviation Administration), food (Food and Drug Administration), and workplace safety (the Occupational Safety and Health Administration).
Although federal regulation of economic activities has seen several waves of growth through the past century (Ripley & Franklin, 1987), the last two decades have seen somewhat of a movement in the opposite direction. Late in the Carter administration and extending through the Reagan administration, there were several efforts to deregulate certain industries. The Civil Aviation Board was disbanded in 1984, and over the following decade significant areas of transportation, telecommunications, and banking were deregulated. Moreover, regulations were eliminated or enforcement slowed down in areas such as workplace, auto, and consumer products safety.
During the 1990s, however, as many federal agencies relaxed their regulatory grip, a few attempted to expand their authority. The Environmental Protection Agency sought to set standards for pesticide and cancer risk, while the Occupational Safety and Health Administration created guidelines for reducing violent crime in retail locations open at night (Niskanen, 2001). The Food and Drug Administration attempted to expand its jurisdiction to the tobacco industry by establishing nicotine as a drug, which would have given federal regulators the power to control tobacco products. This move, however, was challenged by the tobacco companies, and in 2000 the Supreme Court ruled against the fed ...
The Obama administration took climate change seriously and implemented several initiatives to combat it. The 2013 Climate Action Plan aimed to cut carbon pollution, prepare for climate change impacts, and engage in international cooperation. Through the plan, Obama intended to spur business innovation, create jobs, modernize energy infrastructure, and reduce energy consumption and costs. Congress initially supported environmental protection but became more partisan, hindering climate policy. Public opinion also divided along party lines, though many Americans now accept climate change realities. The administration drew attention to climate issues and influenced policy through executive orders and the federal bureaucracy, but still required cooperation from Congress and the courts to fully implement changes.
Politics and the Patient Protection and Affordable Care Act.docxstudywriters
The document discusses the politics surrounding the Affordable Care Act (ACA) and efforts to repeal and replace it. It notes that while the ACA achieved its goal of expanding health insurance coverage, there were many in Congress who wanted to repeal it. Repeal efforts intensified under the Trump administration but were unsuccessful. Legislators are influenced by reelection concerns, so the fact that millions gained coverage through the ACA made voters want to keep it, affecting legislators' votes.
Running head HOW FLORIDA STATE IS ENACTED THE AFFORTABLE CARE ACT.docxwlynn1
Running head: HOW FLORIDA STATE IS ENACTED THE AFFORTABLE CARE ACT 1
HOW FLORIDA STATE IS ENACTING THE AFFORTABLE CARE ACT 2
How Florida State Is Enacting the Affordable Care Act (ACA)
Rose Sejour
Purdue Global University
06/17/2019
The Strengths of the Affordable Care Act in Florida
There has been an introduction of subsidies in healthcare in Florida, and this is courtesy of the Affordable Care Act. Subsidies in the field basically makes buying of health insurance less expensive for people who live in Florida who are eligible for the subsidies. (The United States Supreme Court also ordered for the implementation of 80/20 rule in all the states, including Florida. The ruling implies the 80 percent of the premium dollars and individual from Florida spend on healthcare instead of spending on the administrative costs. Another strength of Obamacare is that Medicaid is at the moment more inclusive for many citizens in the state. Medicaid coverage currently comprises of uninsured Americans under 138% of the poverty level.) NEED CITATION SINCE YOU ARE USING FACT. Comment by McLean, Terry: Read carefully to find errors such as this field Comment by McLean, Terry: You can write out numbers over 10 as numerals
The state has also made it easier for the dependents to stay longer under their parents’ healthcare plan. Some of the youths may be under the medical cover of their parents up to the age of 26 years old. Lastly, Florida state has also implemented the act such that there are no preexisting denials or surprise cancellations of a plan in the healthcare system. Insurance firms lacks the mandate of cancelling the policy due to an applicant’s mistake during the application process (Rozensky, 2014).
The Weaknesses of the Affordable Care Act in Florida
Despite the fact that the Affordable Care Act has had a lot of strengths in Florida, there are also some weaknesses experienced. The healthcare cost has not decreased for every individual. A number of private plans had to be cancelled since they did not comply with the requirements of Obamacare in the state (Barakat et al., 2017). Those individuals that were negatively affected (from this mess were (The tone is not academic) forced to stop and adopt a new health insurance making them to pay more for a plan which includes benefits like maternity care that may not be their preference. Secondly, shopping for coverage might be complicated to some level. With some confusion that surrounds the rollout of the Obamacare and the market place, more alternatives to decide on, difficulties with the websites and limited enrollment periods, shopping for health coverage may be complicated to some level. Comment by McLean, Terry: The tone is not academic.
Moreover, those citizens who are not insured might be faced with huge tax penalties. It is quite unfortunate that Florida dwellers are only able to see these huge amounts of tax .
The US government has shutdown due to Congress failing to agree on a budget by the September 30th deadline. This has resulted in nearly 1 million government employees and contractors being furloughed without pay. The main issue causing the shutdown is disagreement over the Affordable Care Act (Obamacare) between Republicans, who want to defund it, and Democrats, who want to allow it to continue as is for now. If a resolution is not reached soon, Republicans may use an upcoming vote on raising the debt ceiling as another opportunity to oppose Obamacare.
The document analyzes Twitter activity from various political actors to test theories of issue ownership and agenda setting. It finds that politicians emphasize issues they are believed to be competent in handling. During election years, parties prioritize consensus issues to support or attack the incumbent. Peaks in Twitter activity also correlate with current legislation, disasters, and the president highlighting an issue in a speech. The analysis reveals politicians focus consensus issues to promote their own agendas and specialties.
Comparing Magazine or Online Nutrition Information with Published.docxbartholomeocoombs
Comparing Magazine or Online Nutrition Information* with Published Research.
Scientific research sometimes contraindicates nutrition information in Health and Fitness magazines or from retail supplement stores. The information may not be completely false, but the information could be exaggerated, embellished, or simply not based on research. However, the information could be very accurate.
1. Select an article about a specific nutrition recommendation or a specific nutrition supplement from a Health and Fitness magazine or website. Most Health and Fitness magazines and websites now hire a Nutrition and/or Fitness professional to write their nutrition related articles. Thus, instead of an article, you can choose information from a retail website, an online advertisement, or information listed on a supplement container.
Please note: supplements that are very new (so new that research has not yet been conducted) would not be a good choice for this assignment. Also, do not select Creatine, as its proposed benefits are well documented.
2. Research the same nutrition recommendation or supplement using sources such as published research, scientific journals, textbooks, or reliable websites (commonly ending with .edu, .gov, or .org).
Instructions
1. List your selected Nutrition Recommendation or Supplement.
2. List the exact source of the claims or proposed benefits (magazine, website, advertisement, actual supplement container, etc.). If possible, provide a web link. If using a print advertisement or supplement container, submit a picture or photo.
3. List the exact claims and/or proposed benefits from your selected magazine article, website, advertisement, commercial, or supplement container.
4. Using reputable sources, summarize actual research results of the claims or benefits from #3. Two paragraphs minimum.
5. Provide at least 2 references. Our textbook can be used for 1 of the 2 references. Use APA style and format when listing and citing your references. See the Week 2 folder for information on APA style.
6. Compare the information from #3 and #4. One paragraph minimum.
This Assignment must be typed, and please number the various parts of your submitted assignment (as noted in the Instructions above: 1, 2, and so on).
APA Format
Due Friday April 5, 2019
Running head: HEALTHCARE POLICY ASSESSMENT
1
HEALTHCARE POLICY ASSESSMENT
2
Healthcare Policy Assessment
Dr. Timothy Smith
Darrin Clanton
PAD 510: Introduction to Public Policy Analysis
January 18, 2019
Healthcare Policy Assessment
Introduction
A presidential administration often works towards the improvement of the society. This is done through the implementation of different federal policies which act as facilitators towards specific objectives. In America, it is possible to trace specific social challenges that have existed since time immemorial. The phenomenon has led to different presidential administrations instituting the same federal policy as an effort to r.
Comparing Magazine or Online Nutrition Information with Published.docxannette228280
Comparing Magazine or Online Nutrition Information* with Published Research.
Scientific research sometimes contraindicates nutrition information in Health and Fitness magazines or from retail supplement stores. The information may not be completely false, but the information could be exaggerated, embellished, or simply not based on research. However, the information could be very accurate.
1. Select an article about a specific nutrition recommendation or a specific nutrition supplement from a Health and Fitness magazine or website. Most Health and Fitness magazines and websites now hire a Nutrition and/or Fitness professional to write their nutrition related articles. Thus, instead of an article, you can choose information from a retail website, an online advertisement, or information listed on a supplement container.
Please note: supplements that are very new (so new that research has not yet been conducted) would not be a good choice for this assignment. Also, do not select Creatine, as its proposed benefits are well documented.
2. Research the same nutrition recommendation or supplement using sources such as published research, scientific journals, textbooks, or reliable websites (commonly ending with .edu, .gov, or .org).
Instructions
1. List your selected Nutrition Recommendation or Supplement.
2. List the exact source of the claims or proposed benefits (magazine, website, advertisement, actual supplement container, etc.). If possible, provide a web link. If using a print advertisement or supplement container, submit a picture or photo.
3. List the exact claims and/or proposed benefits from your selected magazine article, website, advertisement, commercial, or supplement container.
4. Using reputable sources, summarize actual research results of the claims or benefits from #3. Two paragraphs minimum.
5. Provide at least 2 references. Our textbook can be used for 1 of the 2 references. Use APA style and format when listing and citing your references. See the Week 2 folder for information on APA style.
6. Compare the information from #3 and #4. One paragraph minimum.
This Assignment must be typed, and please number the various parts of your submitted assignment (as noted in the Instructions above: 1, 2, and so on).
APA Format
Due Friday April 5, 2019
Running head: HEALTHCARE POLICY ASSESSMENT
1
HEALTHCARE POLICY ASSESSMENT
2
Healthcare Policy Assessment
Dr. Timothy Smith
Darrin Clanton
PAD 510: Introduction to Public Policy Analysis
January 18, 2019
Healthcare Policy Assessment
Introduction
A presidential administration often works towards the improvement of the society. This is done through the implementation of different federal policies which act as facilitators towards specific objectives. In America, it is possible to trace specific social challenges that have existed since time immemorial. The phenomenon has led to different presidential administrations instituting the same federal policy as an effort to r.
This document discusses different models of federalism in the United States and debates which level of government should have more control over certain issues. It outlines that the national government is responsible for issues like national defense and foreign policy, while states handle elections and public safety. It also describes different forms of federalism over time, from cooperative to new and coercive federalism. The document argues that some issues like immigration are best handled at the national level due to cross-state impacts, while others like minimum wage may be better left to state regulation to avoid large economic fluctuations. Overall, it conveys that federalism has adapted over history and both national and state governments rely on each other.
1) Several state attorneys general, led by New York's Schneiderman, oppose an HHS rule expanding religious exemptions to contraceptive coverage, arguing it violates civil rights laws and will burden states financially.
2) Republican governors met with Pence to express concerns over proposed NAFTA changes that could affect manufacturing jobs in their states.
3) States are looking for ways to address workforce skills gaps and the lack of qualified job applicants, such as through apprenticeship programs and improving K-12 education.
Get your quality homework help now and stand out.Our professional writers are committed to excellence. We have trained the best scholars in different fields of study.Contact us now at premiumessays.net and place your order at affordable price done within set deadlines.We always have someone online ready to answer all your queries and take your requests.
Problem 17.4 Consider the following financial statements for Be.docxsleeperharwell
Problem 17.4
Consider the following financial statements for BestCare HMO, a not-for-profit managed care
plan:
BestCare HMO
Statement of Operations and Change in Net Assets
Year Ended June 30, 2011
(in thousands)
Revenue:
Premiums earned $26,682
Co-insurance 1,689
Interest and other income 242
Total revenue $28,613
Expenses:
Salaries and benefits $15,154
Medical supplies and drugs 7,507
Insurance 3,963
Provision for bad debts 19
Depreciation 367
Interest 385
Total expenses $27,395
Net income $1,218
Net assets, beginning of year $900
Net assets, end of year $2,118
BestCare HMO
Balance Sheet
June 30, 2011
(in thousands)
Assets
Cash and cash equivalents $ 2,737
Net premiums receivable 821
Supplies 387
Total current assets $3,945
Net property and equipment $5,924
Total assets $9,869
Liabilities and Net Assets
Accounts payable–medical services $2,145
Accrued expenses 929
Notes payable 141
Current portion of long-term debt 241
Total current liabilities $3,456
Long-term debt $4,295
Total liabilities $7,751
Net assets (equity) .
Agenda Comparison Grid Template
Agenda Comparison Grid and Fact Sheet or Talking Points Brief Assignment Template for Part 1 and Part 2
Part 1: Agenda Comparison Grid
Use this Agenda Comparison Grid to document information about the population health/healthcare issue your selected and the presidential agendas. By completing this grid, you will develop a more in depth understanding of your selected issue and how you might position it politically based on the presidential agendas.
You will use the information in the Part 1: Agenda Comparison Grid to complete the remaining Part 2 and Part 3 of your Assignment.
Identify the Population Health concern you selected.
Mental Health Issue (Depression)
Describe the Population Health concern you selected and the factors that contribute to it.
Depression is the foremost cause leading young population to death in the USA. According to Cockerham, depression is a mental disorder, which is caused by psychological, persistent social and biological pain. This leads to disinterest of social life and committing suicide. Yet, if depression is not treated, it may lead to dementia, stroke and heart attack. In the past six to ten years, researchers such as Disease Control and Prevention found that youngsters at the age of 18 to 24 years, experience depression and going through suicidal thoughts. Unlike citizens 45 to 65 years of age, reports have reported that deaths among these particular group have been significantly rising. Mental health illnesses have brought many US presidents attention, which most of them have taken various steps allowing easy access to treatments and medicines.
Administration (President Name)
(Current President)
Donald Trump
(Previous President)
Barack Obama
(Previous President)
George W. Bush
Describe the administrative agenda focus related to this issue for the current and two previous presidents.
- To renovate the Patient Protection and Affordable Care Act, president Donald Trump came up with a different strategy, a new healthcare bill.
- Diminishing the amount of Medicaid is one of the undertaken steps of Donald Trump’s administration. This way, insurance plan will only cover substance use and mental issues meanwhile majority of them depend on low income.
- Obama signed an act, the Patient Protection and Affordable Care Act. It is also known to be Obamacare, allowing the extension of federal mental parity to Medicaid.
- The purpose of the act is to support people with mental illnesses and people who are disable. In 2010, president Obama signed the Frank Melville Supportive Housing Investment Act.
- In 2002, George W Bush shaped a commission, which involved experts in the mental health field.
- President George W Bush wanted to bring the anguishes undergone by mentally ill citizens to an end. President George W Bush signed the Pete Domenici Mental Health Parity and Addictions Equity Act in 2008. An all-inclusive law that covers health insurance. The act states .
The document discusses key provisions of the Affordable Care Act that benefit the Latino community, such as allowing young adults to stay on their parents' insurance until age 26 and eliminating lifetime limits on benefits. It also discusses efforts in Congress to repeal the healthcare law and the implications this could have. Additionally, it covers Democracia's work with other organizations to educate the Latino community about clean air issues and their lawsuit against the governor of Florida over redistricting reforms.
TennisonJ_Interdisciplinary Research Paper_Climate Change 13 Mar 16 (Autosaved)Jonathan Tennison
This paper explores climate change from an interdisciplinary perspective using political science, natural science, and economics. While politicians often deny climate change due to funding from fossil fuel industries, the natural science evidence for human-caused climate change is overwhelming. Economics is driving the transition to renewable energy as major banks invest in green technology. An integrated approach is needed to balance economic and social concerns with mitigating climate change.
Civics - Unit Summative EssayEssay PromptHow can state .docxrichardnorman90310
Civics - Unit Summative Essay
Essay Prompt:
How can state governments/political parties use the system of federalism to their advantage when it comes to preserving their rights from the desires of federal rulings?
(You will demonstrate how shared power between the Federal Government and the States have either helped or hurt political groups)
Writing is just like math, you need to have a FORMULA!
·
Although X, However A+B= ____. Therefore, Y.
·
X is your Counter Argument.
·
A/B is your main points→ Claims
·
Y is your Assertion
Example:
Although a strong central government______________________________________________.
( X = Counter Argument)
Federalism has enabled the states to _____________________and ______________________
(A = Claim one) (B= Claim two)
when dealing with issues like___________________________________.
(Topic)
Therefore,___________________________________________________________________.
(Y = Assertion)
Format of Essay:
Thesis/Contextualization of Argument
Claim #1
Claim #2
Counterclaim
Conclusion
‹#›
Essay Requirements:
2 Pages– Double Spaced
Times New Roman– 12 Point Font
Title Page (Should include title of Paper, Name, Teacher’s Names, Period, and Date)
Works Cited of Souces (At the end of the Essay)
‹#›
image1.jpg
How liberals learned to love federalism
The left was skeptical of giving power to the states. Until the Trump era.
Perspective by Ilya Somin
Ilya Somin, a law professor at George Mason University, is the author of "Free to Move: Foot Voting, Migration and Political Freedom."
July 12, 2019 at 4:56 p.m. EDT
(Jess Rotter/for
The Washington Post)
The partisan division often shaped policy: Liberals championed national environmental rules (restricting even activities with purely local effects), the creation of new federal crimes (such as under the Gun-Free School Zones Act) and the steady expansion of civil rights laws, and the right pushed back, arguing that states deserved more autonomy in these areas. For many liberals, the ideal of state and local independence was permanently tainted by Southern states’ “massive resistance” to federal attempts to remedy racial discrimination in the 1950s and ’60s. “If one disapproves of racism, one should disapprove of federalism,” political scientist William Riker categorically asserted in 1964.
But in the Trump era, many progressives are rediscovering the merits of federalism. They are finding that state and local governments can serve as an importa.
The document discusses the second anniversary of the Affordable Care Act and analyzes both its achievements and challenges. It notes that while the law expanded coverage to millions, the final version passed was reduced in scope from initial plans. Additionally, Republicans strongly oppose the law and have launched legal challenges against it. The Supreme Court will hear arguments on these challenges next week in a key case that could impact the presidential election. For Latinos who have high uninsured rates, parts of the law already in place provide important new protections.
Big Business, Big Issues: The Winners and Losers from the U.S. Midterm ElectionsBrunswick Group
The U.S. midterm elections have dealt a new setback to President Obama. As was widely expected, voters have given Republicans control of both chambers of Congress, weakening the president’s already diminished influence in his last two years in office.
But there’s another set of winners and losers in this this election: the sectors, issues and interest groups that have a stake in the outcome.
Brunswick Group’s take on what the 2014 midterm elections mean for your companies, industries and interest groups.
For more information please contact our Washington, DC office: http://www.brunswickgroup.com/contact-us/washington-dc/
American politics scholars study various aspects of the US political system including institutions, public opinion, and connections between politics and behavior. Currently, the US is facing a significant debt crisis as government spending exceeds tax revenue, requiring borrowing. Failure to raise the debt ceiling could result in default, which would have catastrophic economic effects in the US and globally. While politicians frequently debate solutions, effectively addressing the debt crisis requires both spending cuts and tax increases. The 2020 presidential election revealed deep divisions among Americans on many issues, and the emergence of "woke" politics has added further divisiveness.
The document summarizes discussions from a House-Senate conference on the Comprehensive Addiction and Recovery Act (CARA) legislation to address the opioid epidemic. Democrats pushed for funding to be included but Republicans highlighted recent funding increases. Amendments were considered and some passed both chambers while others only passed the Senate. Democrats' amendments to add funding were not accepted. The final conference report was signed by Republican conferees and will address efforts to curb the growing opioid crisis.
A subtle but perceptible shift in the United States’ political orientation took place in November measurable by the success of several ballot proposals from states as far apart as Maine and Colorado. Here and in Washington, voters approved constitutional amendments for the legalisation of recreational marijuana for the first time in the country’s history.
The subject of technology, particularly social media, is controversi.docxsarah98765
The subject of technology, particularly social media, is controversial to say the least. What are your thoughts about technology/social media in your organization or one you have worked in before? Were people united about what social media should be used for professionally/personally? What policies existed? Were there opposing viewpoints? Explain.
Jones, G. R. (2013).
Organizational theory, design, and change
(7th ed.). Upper Saddle River, NJ: Prentice Hall.
.
The subject Cloud Security and ComplianceEach student needs.docxsarah98765
The subject: Cloud Security and Compliance
Each student needs to submit the first page of every publication that he/she finds including “Abstract” and information related to where and when each article/paper was published
Once the project topic and research material is reviewed and approved by the instructor, students can proceed to conduct further research and complete their respective project
Deliverable: Complete paper should be submitted as typed papers, not to exceed ten pages (typed double space and must include title, name and references).
Important: When choosing articles/papers related to the chosen topics, students must pay attention to selecting articles that include new information for them. Each term paper will be evaluated based on originality and individual increased learnings directly related to the project.
- We need to use these 2 references (you may add other sources)
Mather, T., Kumaraswamy, S., & Latif, S. (2009).
Cloud security and privacy: An enterprise perspective on risk and compliance
. Beijing: O'Reilly.
Kalaiprasath, R., Elankavi, R., & Udayakumar, R. (1970, January 01). Cloud Securıty And Complıance - A Semantıc Approach In End To End Securıty. Retrieved January 23, 2021, from https://core.ac.uk/display/192811513
The term paper must be 8 pages and ppt is also required for the paper.
On Thursday(02/04) a progress report is needed.
.
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The Obama administration took climate change seriously and implemented several initiatives to combat it. The 2013 Climate Action Plan aimed to cut carbon pollution, prepare for climate change impacts, and engage in international cooperation. Through the plan, Obama intended to spur business innovation, create jobs, modernize energy infrastructure, and reduce energy consumption and costs. Congress initially supported environmental protection but became more partisan, hindering climate policy. Public opinion also divided along party lines, though many Americans now accept climate change realities. The administration drew attention to climate issues and influenced policy through executive orders and the federal bureaucracy, but still required cooperation from Congress and the courts to fully implement changes.
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Running head HOW FLORIDA STATE IS ENACTED THE AFFORTABLE CARE ACT.docxwlynn1
Running head: HOW FLORIDA STATE IS ENACTED THE AFFORTABLE CARE ACT 1
HOW FLORIDA STATE IS ENACTING THE AFFORTABLE CARE ACT 2
How Florida State Is Enacting the Affordable Care Act (ACA)
Rose Sejour
Purdue Global University
06/17/2019
The Strengths of the Affordable Care Act in Florida
There has been an introduction of subsidies in healthcare in Florida, and this is courtesy of the Affordable Care Act. Subsidies in the field basically makes buying of health insurance less expensive for people who live in Florida who are eligible for the subsidies. (The United States Supreme Court also ordered for the implementation of 80/20 rule in all the states, including Florida. The ruling implies the 80 percent of the premium dollars and individual from Florida spend on healthcare instead of spending on the administrative costs. Another strength of Obamacare is that Medicaid is at the moment more inclusive for many citizens in the state. Medicaid coverage currently comprises of uninsured Americans under 138% of the poverty level.) NEED CITATION SINCE YOU ARE USING FACT. Comment by McLean, Terry: Read carefully to find errors such as this field Comment by McLean, Terry: You can write out numbers over 10 as numerals
The state has also made it easier for the dependents to stay longer under their parents’ healthcare plan. Some of the youths may be under the medical cover of their parents up to the age of 26 years old. Lastly, Florida state has also implemented the act such that there are no preexisting denials or surprise cancellations of a plan in the healthcare system. Insurance firms lacks the mandate of cancelling the policy due to an applicant’s mistake during the application process (Rozensky, 2014).
The Weaknesses of the Affordable Care Act in Florida
Despite the fact that the Affordable Care Act has had a lot of strengths in Florida, there are also some weaknesses experienced. The healthcare cost has not decreased for every individual. A number of private plans had to be cancelled since they did not comply with the requirements of Obamacare in the state (Barakat et al., 2017). Those individuals that were negatively affected (from this mess were (The tone is not academic) forced to stop and adopt a new health insurance making them to pay more for a plan which includes benefits like maternity care that may not be their preference. Secondly, shopping for coverage might be complicated to some level. With some confusion that surrounds the rollout of the Obamacare and the market place, more alternatives to decide on, difficulties with the websites and limited enrollment periods, shopping for health coverage may be complicated to some level. Comment by McLean, Terry: The tone is not academic.
Moreover, those citizens who are not insured might be faced with huge tax penalties. It is quite unfortunate that Florida dwellers are only able to see these huge amounts of tax .
The US government has shutdown due to Congress failing to agree on a budget by the September 30th deadline. This has resulted in nearly 1 million government employees and contractors being furloughed without pay. The main issue causing the shutdown is disagreement over the Affordable Care Act (Obamacare) between Republicans, who want to defund it, and Democrats, who want to allow it to continue as is for now. If a resolution is not reached soon, Republicans may use an upcoming vote on raising the debt ceiling as another opportunity to oppose Obamacare.
The document analyzes Twitter activity from various political actors to test theories of issue ownership and agenda setting. It finds that politicians emphasize issues they are believed to be competent in handling. During election years, parties prioritize consensus issues to support or attack the incumbent. Peaks in Twitter activity also correlate with current legislation, disasters, and the president highlighting an issue in a speech. The analysis reveals politicians focus consensus issues to promote their own agendas and specialties.
Comparing Magazine or Online Nutrition Information with Published.docxbartholomeocoombs
Comparing Magazine or Online Nutrition Information* with Published Research.
Scientific research sometimes contraindicates nutrition information in Health and Fitness magazines or from retail supplement stores. The information may not be completely false, but the information could be exaggerated, embellished, or simply not based on research. However, the information could be very accurate.
1. Select an article about a specific nutrition recommendation or a specific nutrition supplement from a Health and Fitness magazine or website. Most Health and Fitness magazines and websites now hire a Nutrition and/or Fitness professional to write their nutrition related articles. Thus, instead of an article, you can choose information from a retail website, an online advertisement, or information listed on a supplement container.
Please note: supplements that are very new (so new that research has not yet been conducted) would not be a good choice for this assignment. Also, do not select Creatine, as its proposed benefits are well documented.
2. Research the same nutrition recommendation or supplement using sources such as published research, scientific journals, textbooks, or reliable websites (commonly ending with .edu, .gov, or .org).
Instructions
1. List your selected Nutrition Recommendation or Supplement.
2. List the exact source of the claims or proposed benefits (magazine, website, advertisement, actual supplement container, etc.). If possible, provide a web link. If using a print advertisement or supplement container, submit a picture or photo.
3. List the exact claims and/or proposed benefits from your selected magazine article, website, advertisement, commercial, or supplement container.
4. Using reputable sources, summarize actual research results of the claims or benefits from #3. Two paragraphs minimum.
5. Provide at least 2 references. Our textbook can be used for 1 of the 2 references. Use APA style and format when listing and citing your references. See the Week 2 folder for information on APA style.
6. Compare the information from #3 and #4. One paragraph minimum.
This Assignment must be typed, and please number the various parts of your submitted assignment (as noted in the Instructions above: 1, 2, and so on).
APA Format
Due Friday April 5, 2019
Running head: HEALTHCARE POLICY ASSESSMENT
1
HEALTHCARE POLICY ASSESSMENT
2
Healthcare Policy Assessment
Dr. Timothy Smith
Darrin Clanton
PAD 510: Introduction to Public Policy Analysis
January 18, 2019
Healthcare Policy Assessment
Introduction
A presidential administration often works towards the improvement of the society. This is done through the implementation of different federal policies which act as facilitators towards specific objectives. In America, it is possible to trace specific social challenges that have existed since time immemorial. The phenomenon has led to different presidential administrations instituting the same federal policy as an effort to r.
Comparing Magazine or Online Nutrition Information with Published.docxannette228280
Comparing Magazine or Online Nutrition Information* with Published Research.
Scientific research sometimes contraindicates nutrition information in Health and Fitness magazines or from retail supplement stores. The information may not be completely false, but the information could be exaggerated, embellished, or simply not based on research. However, the information could be very accurate.
1. Select an article about a specific nutrition recommendation or a specific nutrition supplement from a Health and Fitness magazine or website. Most Health and Fitness magazines and websites now hire a Nutrition and/or Fitness professional to write their nutrition related articles. Thus, instead of an article, you can choose information from a retail website, an online advertisement, or information listed on a supplement container.
Please note: supplements that are very new (so new that research has not yet been conducted) would not be a good choice for this assignment. Also, do not select Creatine, as its proposed benefits are well documented.
2. Research the same nutrition recommendation or supplement using sources such as published research, scientific journals, textbooks, or reliable websites (commonly ending with .edu, .gov, or .org).
Instructions
1. List your selected Nutrition Recommendation or Supplement.
2. List the exact source of the claims or proposed benefits (magazine, website, advertisement, actual supplement container, etc.). If possible, provide a web link. If using a print advertisement or supplement container, submit a picture or photo.
3. List the exact claims and/or proposed benefits from your selected magazine article, website, advertisement, commercial, or supplement container.
4. Using reputable sources, summarize actual research results of the claims or benefits from #3. Two paragraphs minimum.
5. Provide at least 2 references. Our textbook can be used for 1 of the 2 references. Use APA style and format when listing and citing your references. See the Week 2 folder for information on APA style.
6. Compare the information from #3 and #4. One paragraph minimum.
This Assignment must be typed, and please number the various parts of your submitted assignment (as noted in the Instructions above: 1, 2, and so on).
APA Format
Due Friday April 5, 2019
Running head: HEALTHCARE POLICY ASSESSMENT
1
HEALTHCARE POLICY ASSESSMENT
2
Healthcare Policy Assessment
Dr. Timothy Smith
Darrin Clanton
PAD 510: Introduction to Public Policy Analysis
January 18, 2019
Healthcare Policy Assessment
Introduction
A presidential administration often works towards the improvement of the society. This is done through the implementation of different federal policies which act as facilitators towards specific objectives. In America, it is possible to trace specific social challenges that have existed since time immemorial. The phenomenon has led to different presidential administrations instituting the same federal policy as an effort to r.
This document discusses different models of federalism in the United States and debates which level of government should have more control over certain issues. It outlines that the national government is responsible for issues like national defense and foreign policy, while states handle elections and public safety. It also describes different forms of federalism over time, from cooperative to new and coercive federalism. The document argues that some issues like immigration are best handled at the national level due to cross-state impacts, while others like minimum wage may be better left to state regulation to avoid large economic fluctuations. Overall, it conveys that federalism has adapted over history and both national and state governments rely on each other.
1) Several state attorneys general, led by New York's Schneiderman, oppose an HHS rule expanding religious exemptions to contraceptive coverage, arguing it violates civil rights laws and will burden states financially.
2) Republican governors met with Pence to express concerns over proposed NAFTA changes that could affect manufacturing jobs in their states.
3) States are looking for ways to address workforce skills gaps and the lack of qualified job applicants, such as through apprenticeship programs and improving K-12 education.
Get your quality homework help now and stand out.Our professional writers are committed to excellence. We have trained the best scholars in different fields of study.Contact us now at premiumessays.net and place your order at affordable price done within set deadlines.We always have someone online ready to answer all your queries and take your requests.
Problem 17.4 Consider the following financial statements for Be.docxsleeperharwell
Problem 17.4
Consider the following financial statements for BestCare HMO, a not-for-profit managed care
plan:
BestCare HMO
Statement of Operations and Change in Net Assets
Year Ended June 30, 2011
(in thousands)
Revenue:
Premiums earned $26,682
Co-insurance 1,689
Interest and other income 242
Total revenue $28,613
Expenses:
Salaries and benefits $15,154
Medical supplies and drugs 7,507
Insurance 3,963
Provision for bad debts 19
Depreciation 367
Interest 385
Total expenses $27,395
Net income $1,218
Net assets, beginning of year $900
Net assets, end of year $2,118
BestCare HMO
Balance Sheet
June 30, 2011
(in thousands)
Assets
Cash and cash equivalents $ 2,737
Net premiums receivable 821
Supplies 387
Total current assets $3,945
Net property and equipment $5,924
Total assets $9,869
Liabilities and Net Assets
Accounts payable–medical services $2,145
Accrued expenses 929
Notes payable 141
Current portion of long-term debt 241
Total current liabilities $3,456
Long-term debt $4,295
Total liabilities $7,751
Net assets (equity) .
Agenda Comparison Grid Template
Agenda Comparison Grid and Fact Sheet or Talking Points Brief Assignment Template for Part 1 and Part 2
Part 1: Agenda Comparison Grid
Use this Agenda Comparison Grid to document information about the population health/healthcare issue your selected and the presidential agendas. By completing this grid, you will develop a more in depth understanding of your selected issue and how you might position it politically based on the presidential agendas.
You will use the information in the Part 1: Agenda Comparison Grid to complete the remaining Part 2 and Part 3 of your Assignment.
Identify the Population Health concern you selected.
Mental Health Issue (Depression)
Describe the Population Health concern you selected and the factors that contribute to it.
Depression is the foremost cause leading young population to death in the USA. According to Cockerham, depression is a mental disorder, which is caused by psychological, persistent social and biological pain. This leads to disinterest of social life and committing suicide. Yet, if depression is not treated, it may lead to dementia, stroke and heart attack. In the past six to ten years, researchers such as Disease Control and Prevention found that youngsters at the age of 18 to 24 years, experience depression and going through suicidal thoughts. Unlike citizens 45 to 65 years of age, reports have reported that deaths among these particular group have been significantly rising. Mental health illnesses have brought many US presidents attention, which most of them have taken various steps allowing easy access to treatments and medicines.
Administration (President Name)
(Current President)
Donald Trump
(Previous President)
Barack Obama
(Previous President)
George W. Bush
Describe the administrative agenda focus related to this issue for the current and two previous presidents.
- To renovate the Patient Protection and Affordable Care Act, president Donald Trump came up with a different strategy, a new healthcare bill.
- Diminishing the amount of Medicaid is one of the undertaken steps of Donald Trump’s administration. This way, insurance plan will only cover substance use and mental issues meanwhile majority of them depend on low income.
- Obama signed an act, the Patient Protection and Affordable Care Act. It is also known to be Obamacare, allowing the extension of federal mental parity to Medicaid.
- The purpose of the act is to support people with mental illnesses and people who are disable. In 2010, president Obama signed the Frank Melville Supportive Housing Investment Act.
- In 2002, George W Bush shaped a commission, which involved experts in the mental health field.
- President George W Bush wanted to bring the anguishes undergone by mentally ill citizens to an end. President George W Bush signed the Pete Domenici Mental Health Parity and Addictions Equity Act in 2008. An all-inclusive law that covers health insurance. The act states .
The document discusses key provisions of the Affordable Care Act that benefit the Latino community, such as allowing young adults to stay on their parents' insurance until age 26 and eliminating lifetime limits on benefits. It also discusses efforts in Congress to repeal the healthcare law and the implications this could have. Additionally, it covers Democracia's work with other organizations to educate the Latino community about clean air issues and their lawsuit against the governor of Florida over redistricting reforms.
TennisonJ_Interdisciplinary Research Paper_Climate Change 13 Mar 16 (Autosaved)Jonathan Tennison
This paper explores climate change from an interdisciplinary perspective using political science, natural science, and economics. While politicians often deny climate change due to funding from fossil fuel industries, the natural science evidence for human-caused climate change is overwhelming. Economics is driving the transition to renewable energy as major banks invest in green technology. An integrated approach is needed to balance economic and social concerns with mitigating climate change.
Civics - Unit Summative EssayEssay PromptHow can state .docxrichardnorman90310
Civics - Unit Summative Essay
Essay Prompt:
How can state governments/political parties use the system of federalism to their advantage when it comes to preserving their rights from the desires of federal rulings?
(You will demonstrate how shared power between the Federal Government and the States have either helped or hurt political groups)
Writing is just like math, you need to have a FORMULA!
·
Although X, However A+B= ____. Therefore, Y.
·
X is your Counter Argument.
·
A/B is your main points→ Claims
·
Y is your Assertion
Example:
Although a strong central government______________________________________________.
( X = Counter Argument)
Federalism has enabled the states to _____________________and ______________________
(A = Claim one) (B= Claim two)
when dealing with issues like___________________________________.
(Topic)
Therefore,___________________________________________________________________.
(Y = Assertion)
Format of Essay:
Thesis/Contextualization of Argument
Claim #1
Claim #2
Counterclaim
Conclusion
‹#›
Essay Requirements:
2 Pages– Double Spaced
Times New Roman– 12 Point Font
Title Page (Should include title of Paper, Name, Teacher’s Names, Period, and Date)
Works Cited of Souces (At the end of the Essay)
‹#›
image1.jpg
How liberals learned to love federalism
The left was skeptical of giving power to the states. Until the Trump era.
Perspective by Ilya Somin
Ilya Somin, a law professor at George Mason University, is the author of "Free to Move: Foot Voting, Migration and Political Freedom."
July 12, 2019 at 4:56 p.m. EDT
(Jess Rotter/for
The Washington Post)
The partisan division often shaped policy: Liberals championed national environmental rules (restricting even activities with purely local effects), the creation of new federal crimes (such as under the Gun-Free School Zones Act) and the steady expansion of civil rights laws, and the right pushed back, arguing that states deserved more autonomy in these areas. For many liberals, the ideal of state and local independence was permanently tainted by Southern states’ “massive resistance” to federal attempts to remedy racial discrimination in the 1950s and ’60s. “If one disapproves of racism, one should disapprove of federalism,” political scientist William Riker categorically asserted in 1964.
But in the Trump era, many progressives are rediscovering the merits of federalism. They are finding that state and local governments can serve as an importa.
The document discusses the second anniversary of the Affordable Care Act and analyzes both its achievements and challenges. It notes that while the law expanded coverage to millions, the final version passed was reduced in scope from initial plans. Additionally, Republicans strongly oppose the law and have launched legal challenges against it. The Supreme Court will hear arguments on these challenges next week in a key case that could impact the presidential election. For Latinos who have high uninsured rates, parts of the law already in place provide important new protections.
Big Business, Big Issues: The Winners and Losers from the U.S. Midterm ElectionsBrunswick Group
The U.S. midterm elections have dealt a new setback to President Obama. As was widely expected, voters have given Republicans control of both chambers of Congress, weakening the president’s already diminished influence in his last two years in office.
But there’s another set of winners and losers in this this election: the sectors, issues and interest groups that have a stake in the outcome.
Brunswick Group’s take on what the 2014 midterm elections mean for your companies, industries and interest groups.
For more information please contact our Washington, DC office: http://www.brunswickgroup.com/contact-us/washington-dc/
American politics scholars study various aspects of the US political system including institutions, public opinion, and connections between politics and behavior. Currently, the US is facing a significant debt crisis as government spending exceeds tax revenue, requiring borrowing. Failure to raise the debt ceiling could result in default, which would have catastrophic economic effects in the US and globally. While politicians frequently debate solutions, effectively addressing the debt crisis requires both spending cuts and tax increases. The 2020 presidential election revealed deep divisions among Americans on many issues, and the emergence of "woke" politics has added further divisiveness.
The document summarizes discussions from a House-Senate conference on the Comprehensive Addiction and Recovery Act (CARA) legislation to address the opioid epidemic. Democrats pushed for funding to be included but Republicans highlighted recent funding increases. Amendments were considered and some passed both chambers while others only passed the Senate. Democrats' amendments to add funding were not accepted. The final conference report was signed by Republican conferees and will address efforts to curb the growing opioid crisis.
A subtle but perceptible shift in the United States’ political orientation took place in November measurable by the success of several ballot proposals from states as far apart as Maine and Colorado. Here and in Washington, voters approved constitutional amendments for the legalisation of recreational marijuana for the first time in the country’s history.
Similar to The State of American Federalism2017–2018 Unilateral Execut.docx (20)
The subject of technology, particularly social media, is controversi.docxsarah98765
The subject of technology, particularly social media, is controversial to say the least. What are your thoughts about technology/social media in your organization or one you have worked in before? Were people united about what social media should be used for professionally/personally? What policies existed? Were there opposing viewpoints? Explain.
Jones, G. R. (2013).
Organizational theory, design, and change
(7th ed.). Upper Saddle River, NJ: Prentice Hall.
.
The subject Cloud Security and ComplianceEach student needs.docxsarah98765
The subject: Cloud Security and Compliance
Each student needs to submit the first page of every publication that he/she finds including “Abstract” and information related to where and when each article/paper was published
Once the project topic and research material is reviewed and approved by the instructor, students can proceed to conduct further research and complete their respective project
Deliverable: Complete paper should be submitted as typed papers, not to exceed ten pages (typed double space and must include title, name and references).
Important: When choosing articles/papers related to the chosen topics, students must pay attention to selecting articles that include new information for them. Each term paper will be evaluated based on originality and individual increased learnings directly related to the project.
- We need to use these 2 references (you may add other sources)
Mather, T., Kumaraswamy, S., & Latif, S. (2009).
Cloud security and privacy: An enterprise perspective on risk and compliance
. Beijing: O'Reilly.
Kalaiprasath, R., Elankavi, R., & Udayakumar, R. (1970, January 01). Cloud Securıty And Complıance - A Semantıc Approach In End To End Securıty. Retrieved January 23, 2021, from https://core.ac.uk/display/192811513
The term paper must be 8 pages and ppt is also required for the paper.
On Thursday(02/04) a progress report is needed.
.
The subject of divorce has been the topic of multiple research s.docxsarah98765
The subject of divorce has been the topic of multiple research studies over the course of many years. Take a look at this model for relationship breakdowns.
Do you think this Vulnerability-Stress-
Adaptation
model has merit? Why or why not?
SCIENCE BRIEFS
Keeping Marriages Healthy, and Why It’s So Difficult
4
By Benjamin R. Karney
0210karneyBenjamin Karney is an Associate Professor of Social Psychology and co-director of the Relationship Institute at the University of California, Los Angeles. His research focuses on how marriages change or remain stable over time, and in particular how relationship maintenance is constrained or enhanced by the contexts in which it takes place. Currently this includes research on marriages in the military, funded by the Department of Defense, and marriages in low-income populations, funded by the National Institute on Child Health and Human Development.
He received the Gerald R. Miller Award for Early Career Achievement from the International Association for Relationship Research in 2004 and has twice been the recipient of the National Council on Family Relation’s Reuben Hill Research and Theory Award for outstanding contributions to family science. His textbook, Intimate Relationships (coauthored with Thomas Bradbury), will be published by W. W. Norton in January, 2010.
People rarely change their minds about subjects that are important to them. Those who favor gun control today are likely to favor gun control ten years from now, and those who vote for Democratic candidates today are likely to do so throughout their lives.
Yet intimate relationships, and marriages in particular, are the exception to this rule. After two people stand before everyone important to them in the world and publicly declare that they love each other and intend to remain together for the rest of their lives, everything social psychology has learned about the stability of publicly declared opinions suggests that these will be the most stable opinions of all (Festinger, 1957). Yet of course they aren’t. Despite the almost uniform happiness and optimism of newlyweds, most first marriages will end in divorce or permanent separation (Bramlett & Mosher, 2002), and the rate of dissolution http://bestofassignment.com for remarriages is even higher (Cherlin, 1992).
In most cases, this represents a drastic and unwanted change in a highly valued belief, a change that is emotionally and financially costly to both members of the couple. Even in marriages that remain intact, newlyweds’ initially high levels of marital satisfaction tend to decline over time (VanLaningham, Johnson, & Amato, 2001). How can we account for this change? How is it that marital satisfaction declines so frequently, despite our best efforts to hold on to the positive feelings that motivate marriage in the first place? And what is it those couples that maintain their initial happiness are doing right?
What couples that stay happy are doing right
Understandi.
The subject is companies lawEssay 800-1000 wordsDue da.docxsarah98765
The subject is companies law
Essay
800-1000 words
Due date 15/4
Avoid plagiarism
6$
1-Write down and explain the advantages and disadvantages for shareholders in the control group.
2- Illustrate the different types of mergers in details, mentioning how- when - why it occurs?
3- Explain in details the two types of corporate litigation. And illustrate the nature of the derivative suit.
4- Explain in details the different types of acquisitions.
.
The subject is Legalization of Marijuana in AmericaWhen you .docxsarah98765
The subject is "Legalization of Marijuana in America"
When you write an informative essay that presents two sides of an issue without revealing bias, there are three primary organizational tactics that can be used:
Present all the major arguments on one side of the issue, and then present all the major arguments of the opposing viewpoint.
Present one of the major issues relating to the overarching topic, and in the same paragraph, discuss the viewpoints of both sides on this particular issue.
In one paragraph, present one of the viewpoints on one major aspect of the controversy, and then follow that paragraph with another paragraph presenting the opposing views’ arguments related to the same aspect of the controversy. You then repeat that pattern one to three more times.
For this assignment:
Use the outline template and one of the strategies listed above to organize the materials for your paper.
Use specific quotes or cited evidence in APA style format for your supporting details.
Develop a concise thesis statement that clearly and accurately presents the main idea you will develop in your paper.
.
the subject is a kitchen remodel1.4 Work Breakdown S.docxsarah98765
the subject is a kitchen remodel
1.4 Work Breakdown Structure (WBS): Provide a WBS for the project, including all key deliverables and work packages.
1.4.1 Task Description Documentation
1.4.2 Organization Breakdown Structure (OBS): Include all cost accounts across cooperating departments in the organization.
1.5 Responsibility Assignment Matrix (RAM): Include a copy of a RAM for the project that identifies all team members by WBS task code, including tasks for which they assume responsibility, notification, support, or approval upon completion.
1.6 Work Authorization: Describe contract terms and conditions. Include all penalty clauses and specific events that will trigger execution of penalties. Include all notification information, including members of the organization to be notified of changes in contract terms.
1.7 Project Charter
This assignment should be a minimum of two pages in length, not counting the title page and reference page. Be sure to use proper APA formatting. Citations are not required; however, if outside sources are used, make certain to provide in-text citations and references in APA format.
.
THe subject is children living in norfolk va with cancer.Research .docxsarah98765
THe subject is children living in norfolk va with cancer.
Research Project
In preparation for this semester long research project, students are to select a community for this assignment. Students should select a community for which they wish to locate resources. The semester long project must have approval from the instructor. Once approval has been gained from the instructor, the student may begin collecting data regarding the community. The textbook by authors Crimando and Riggar (2005) and Sharma and Romas (2012) are to be used as a reference for this research project. Because this is a semester-long project, the minimum length is seven (7) typed pages for undergraduate students. A potential ten (10) points may be deducted from projects that are not a minimum of 7 pages of text plus a cover page, a reference page, a graphic map, a graphic of the model, a table of contents, and a table of demographic information or other content, all properly formatted according to APA. An abstract page is required for this project. The paper should be double-spaced, using a traditional font such as Times New Roman or Arial with a 12 point font.
The selected community will need to be assessed not only for community resources, but also for health promotion needs. Students must have prior approval from the instructor for this assignment. Students will post in Blackboard the selected community and will receive feedback from the instructor for modification until final approval is provided. The APA style manual is to be used, therefore, students are encouraged to purchase the manual and not rely on the internet provided renderings. Ten (10) points will be deducted if the research project does follow the APA style manual requirements. The cover page is to include the student’s name, UIN, course title, Honor Pledge and Professor’s name. Students are encouraged to retain a copy of all work submitted; be mindful that the semester paper will not be returned to you.
In preparing the semester-long research project, students are encouraged to add supplemental materials to accompany the paper and powerpoint. If a pamphlet or a brochure of types is to be included, it can be scanned and submitted electronically with the project as an Appendix or they may be mailed to the instructor from the assigned distance learning site. If the student is assigned to the main campus of Old Dominion University, please either hand deliver or use the inter-campus mailing system at the Gornto Mail Distribution Center for mailing items.
The research project will be submitted via Blackboard. There will be a link for this assignment, Community Research Project, for electronic submission of this assignment. Only those assignments uploaded in BlackBoard will be acknowledged and graded. Be mindful not to send assignments via email to the instructor.
Research Project Outline
Students, in preparing the Research Project, the following should be considered and incorporated as subtitles for the .
The subdivision that I chose is Florida Re-Entry Subdivision (aka Re.docxsarah98765
The subdivision that I chose is Florida Re-Entry Subdivision (aka Recovery, Treatment, and Rehabilitation).
Different departments work together to reach their mission statement. By understanding organizational structure, you can assess whether an organization is fulfilling its mission statement.
To complete this assignment, review the following documents:
LOOK AT MILESTONE ONE FOR THE INSTRUCTION.
2- PAGES IS FINE NOT INCLUDING THE TITLE AND REFERENCE.
.
The study of the philosophy of friendship provides us with an o.docxsarah98765
The study of the philosophy of friendship provides us with an opportunity to explore the concept of dissimulation and its vital role in friendship.
Novelist Marcel Proust believed that friendship was only bearable if we wear masks of good manners. This makes a deep and honest friendship very challenging. He believed that the greatest honesty meant acknowledging that real friendship could never really be fully given or received. Similarly, Immanuel Kant noted:
"For everyone has his weaknesses, and these must be kept hidden even from our friends… so that humanity should not be offended thereby. Even to our best friend, we must not discover ourselves as we naturally are and know ourselves to be, for that would be a nasty business" (p. 85).
Yet, some philosophers believe that when we do experience those powerful moments of truth and honesty between close friends, and completely let our guards down, it is a moment of great clarity and insight. In those honest moments, a friend becomes another self. One may feel as close to a friend as one does to oneself. Most philosophers recognize this phenomenon, including the French writer Michel de Montaigne, who described this friendship as becoming ”one soul in two bodies.”
Aristotle took it further to mean that only in friendship can we truly discover ourselves. Similarly, philosopher Giorgio Agamben shares, “The friend is not another I, but an otherness immanent in self-ness, a becoming other of the self.” Vernon adds: “It’s implying that a close friend is another part of you and that you can only fully become who you are in who they are too” (p. 87).
In this week’s reading material, the following philosophers discuss their views on this topic: Aristotle, Kant, Montaigne, Nietzsche, and Schopenhauer. Make sure to incorporate their views as you answer each discussion question. Think about how their views may be similar or different from your own.
With two seemingly dichotomous understandings of the nature of friendship, how exactly can both conceptions be true?
Is a certain amount of feigning actually necessary in order to achieve a meaningful connection in a friendship?
What are the ethical implications of such behavior in friendship?
.
The Tea Party movement that started in 2010 is considered by some po.docxsarah98765
The Tea Party movement started in 2010 as a grassroots initiative by citizens frustrated with national policy, while the Occupy Wall Street movement emerged in 2011 and also sought to influence policy but specifically targeted Wall Street and income inequality. As an analyst for the Miami-Dade Police Department, I was tasked with analyzing these movements for the upcoming DRNC event and providing policy recommendations.
The TCP, UDP, and IP were designed to provide best-effort service wi.docxsarah98765
The TCP, UDP, and IP were designed to provide best-effort service without quality of service (QoS) guarantees. Today’s multimedia applications are implemented using these protocols. How do these applications meet the demands for a high-quality user experience for streaming stored audio and video, conversational voice and video over IP, and streaming live audio and video? Are there hard limits to what can be accomplished?
.
The student will•Apply critical thinking through participat.docxsarah98765
The student will:
•Apply critical thinking through participation of selected topics
•Engage in thoughtful discourse with peers
•Incorporate topic discussion into clinical judgment and decision making within the setting
Scenario: Abuse
• Mr. CO is a 75, year old male. He was admitted to your unit with Pulmonary Fibrosis. As you are walking towards his room to administer medications you hear his son say to him in a nasty tone of voice: “Stop being so stubborn. I need you to give me access to your bank accounts. You’re going to die alone unless you start cooperating”. As you enter he room, the son leaves quickly and you notice the patient has tears in his eyes. You ask “Is everything okay?” Mr. CO shakes his head yes, but remains nonverbal and does not make eye contact. You administer his medications and leave the room.
Directions:
Part 1:
•The original post must be at least
200 – 300 words
in length
•What types of elder abuse did you notice in the scenario? (
give examples and explain
)
•What signs, (
in the scenario
) if any suggest that the nurse should ask some follow up questions?
•As a nurse in this scenario what is your next action?
•How can older adults protect themselves from ever becoming victims of abuse or mistreatment?
Part 2:
•Post one response to the original post of any classmate
•Your response should be
50+ words
•Posting should ask for clarification, challenge respectfully ideas, or describe a situation that illustrates the points being made. Simply agreeing or disagreeing with a post is
NOT
adequate.
.
The tasks You are assumed to be one of the software consultants .docxsarah98765
The tasks
You are assumed to be one of the software consultants appointed to shoulder the system analysis responsibilities in, the project outlined in, the case study. You will plan and manage the project as well as investigate and document its system requirements. You will produce a report that discusses this project based on your understanding of it and the related investigation results through the tasks below.
Task 1:
Approaches to Systems Development • How would you go about developing Hospital Information System? Compare different Software Development approaches to consider the best suited for developing HIS. • Justify the choice of your selected approach to systems development.
Task 2: Systems Requirements • What are the primary functional requirements for the system in the case study? List and discuss
Length: 2000 words
these requirements. • What are the non-functional requirements for the system in the case study? List and discuss these non-functional requirements. Justify the choice of your non-functional requirements
Task 3: Project Cost Benefit Analysis • Discuss your project Cost Benefit Analysis (CBA). CBA should focus the following two main points: a. To determine if an investment (or decision) is sound, ascertaining if – and by how much – its benefits outweigh its costs; and b. To provide a basis for comparing investments (or decisions), comparing the total expected cost of each option with its total expected benefits. • Provide an excel spread sheet with details in a Project Cost Benefit Analysis.
Task 4:) Project Schedule • Show a work breakdown structure and a project schedule as a Gantt Chart. Explain both of them and discuss how they relate to each other.
• Given the system goals, requirements, and scope as they are currently understood, is the project schedule reasonable? Why or why not?
Task 5: System Information Requirement Investigation Techniques • Who are the stakeholders involved? • Explain your choice of the 3 most useful investigation techniques. • Justify the usefulness of these 3 investigation techniques.
Information Systems Analysis and Design
Assessment - Systems Development
Lecturer: Lecturer Name
Tutor: Tutor Name
Prepared by:
Student Name
Student Number
Table of Contents (TOC)
Insert a word generated table of contents here
How to create a table of contents in Microsoft Word
1. Apply the built-in Heading styles to the headings in your text.
2. In Word 2007 and Word 2010: References > Table of Contents > choose an option from the menu.
1. Introduction
Add your contents here.
Note: In this section, you provide a clear definition of the aims of this report. You also identify the project objectives. Explain all findings in the reporting document.
2. Approach to Systems Development
Please add your contents here. There are many approaches to Systems development such as Water fall SDLC, Agile, RAD JAD. etc. You need to clearly explain which .
The Task Your assignment is to create a seven page multiple so.docxsarah98765
The Task
Your assignment is to create a seven page multiple source essay comparing the following papers:
Elizabeth J. Tisdell’s
Spiritual Development and Commitments to Emancipatory Education in Women Adult Educators for Social Change
Sharan B. Merriam’s
How Cultural Values Shape Learning in Older Adulthood: The Case of Malaysia
Both papers are available in the forum. The analysis should present the limitations, divergences, and main points of consensus between the papers regarding their
methodologies, purposes and goals of the studies, data collection,
and
how the authors reported their findings
. The final section of your paper should reveal the common structure shared by both papers and how the structure supported both studies.
Essay Requirements
The analysis requires the additional components:
One nameless/anonymous or web reference.
Three APA formatted short quotes used to support the paper
One APA formatted figure.
APA formatted paper including:
o
Font: Times New Roman, 12 point, and double spaced.
o
Margins: One inch margins, all around.
o
Indents: One-half inch indent as to begin a paragraph.
o
Proper APA citations and references.
o
Proper use of Level 1 headings as to label the
introduction, main body,
and
conclusions
segments.
o
Proper use of Level 2 headings as to label the sections within the
main body
and
conclusions
.
o
A proper title page.
o
A reference page utilizing hanging indents and alphabetized by the last name of the first author.
Free of spelling errors and minimal use of passive voice.
.
The tasks related to securing the homeland and its critical infr.docxsarah98765
The tasks related to securing the homeland and its critical infrastructure are shared among many organizations. Several universities participate in research projects in conjunction with the DHS. Additionally, other departments in the government have jurisdiction over certain elements of the critical infrastructure.
Describe two academic institutions helping to conduct research to protect the homeland.
Evaluate in detail one specific example of a research project conducted by each institution to protect the homeland. Be sure to explain the objectives of each project.
Analyze the outcomes, conclusions, and recommendations of each research project? Were these projects successful?
Identify opportunities for future research in the areas explored by these projects.
Select one governmental department other than the DHS or DOD, such as the Department of Energy or the Department of Agriculture. Discuss the department’s responsibilities concerning protection of critical infrastructure. Keep in mind that the term “critical infrastructure” refers to certain specific systems.
.
The task is to write up about the Impact of Technology on proj.docxsarah98765
The task is to write up about the
Impact of Technology on project management
Concisely introduce and describe the topic
10 subtopics/talking points
Present the main findings and conclusions of your research
Cite Sources of Information
Use images and/or charts or other graphics
1000 words +/- 10%
Harvard references
.
The task is to design and develop a prototype for one of the fea.docxsarah98765
The task is to design and develop a prototype for one of the features of an application which tracks the performance of the players.
The Application features a game with a number of levels; on successful completion of a level, a player moves to the next level. Players can register directly with the app itself or by supplying identification information from one of a number of linked social media apps.
Player data is stored in a single file either as delimited text format or object file. Player details are Id, Player Name, Image Filename, Current Level, Number of Attempts at Current Level, and, Total Points earned. For social media players the social media app name and identifier are stored.
Requirements
Develop a project with console menu-driven application. The project should contain a controller class with stubs for methods implementing the requirements listed below:
1. Load player performance information from a specified file into a players collection implemented using a repository
2. Add a new player with default values for current level, attempts and points and remove a player from the list.
3. List all players in ascending order of overall points earned
4. Update a player's performance data after an attempt at a level – overall points earned should be updated. On successful completion of a level the player should move to the next level and attempts returned to 0; otherwise, number of attempts should be incremented
5. Persist the collection to a specified file
The project should contain a model, repository and controller classes. A sample delimited text file is additionally supplied.
Development Approach
An incremental development approach should be used with the following increments:
Load players from a file and list in name order
This fulfils Requirement 1. To complete this increment you should:
a. Complete the
Player
and
SocialMediaPlayer
classes with required fields and methods
b. Decide on which type of collection you want the repository to define and make the necessary adjustments to the
Repository
class and
RepositoryInterface
.
c. Partially complete the
GameController
class by completing the constructor method which creates a new
Repository
object from a file if specified by the user
d. Partially complete the
GameController
class to implement the
listPlayers()
method
e. Create a
DAOImpl
class to realize the
DAOInterface
using either text file or object file format
f. Modify the
Repository
class to use the
DAOImpl
class to load players from a specified file
Document the results of your testing using screen snippets copied into a Word document. Take a copy of the
GameController
class and name it as
GameController_Increment1.java
.
Add new Player
This fulfils Requirement 2. To complete this increment you should:
a. Fully implement the
addPlayer()
method in the
GameController
class; this should ask the user for required details, create a new
Player
or
SocialMediaP.
The task is individualThe deliverable has to be a report 2,500-.docxsarah98765
The task is individual
The deliverable has to be a report: 2,500-3,000 words.
The weight is equivalent to 40% of the overall grade
.The report has to be delivered in Turnitin during Week 7 and before the end of week 23.59 CEST.
Harvard Referencing System has to be used.
Pick up one company from the following list
•Inditex
•VW Wolsfburg
•Starbucks
•Carrefour
•IKEA
•Inditex
•Unilever
•Nestle
•McDonald’s
•Nike
•H&M
•Amazon
•Samsung
1)Briefly describe the company (shareholders, products/services provided, sales figures, recent evolution)and identify its supply chain
2)Discuss how the selected company achieves a balance between Supply chain arrangements and consumer value
3)Identify their Supply Chain
4)Describe each of the three parts of this SC
a.Supplies
b.Manufacturing or creation of services
c.Distribution channels
5)Make a critical analysis of each of them and of the supply chain as a whole
6)Discuss availability in logistics customer service and provide examples of the different ways to monitor the company’s performance in availability
.
The task is attached here. Thanks a lotRubricsHighly develo.docxsarah98765
The task is attached here. Thanks a lot
Rubrics:
Highly developed skills in the expression and presentation of ideas. Fluent writing style. No major grammatical and spelling errors. All references (using Havard References), including recent literature, cited and used accurately.
Excellent use of knowledge gained and awareness of deeper and more subtle aspects of economic issues and theories. There is clear evidence of research/read more widely beyond the core materials.
Provides well-argued and articulated statements with supporting evidence. Evidence of originality and independent thought. Has highly developed analytical skills & consistently demonstrates high levels of critical analysis. Demonstrates ability to reflect on conclusions and their implications.
.
The task for this paper is toYou are to select a technology w.docxsarah98765
The task for this paper is to:
You are to select a technology we have been discussing from the approved list.
Write an introduction that will include different parts of the paper.
Discuss the technology of choice in detail.
How does a business incorporates this technology.
Discuss the relevance of technology to today's companies today.
Must include Excel charts to present any data of choice. Should be student generated.
Provide a conclusion that wraps up the paper.
The paper must be in APA Format (check on Blackboard for complete details).
Below are some of the parts that you can include in the paper:
Cover Page
Introduction
Technology
How does it relate today for companies?
Excel Charts
Conclusion
Reference Page (minimum 3 references)
Citations: at least 1 per section
Length: 4 or more written pages
Below is a list of technologies we have been discussing:
Green Computing
Data Centers
Software as a Service
Databases
Cloud Computing
M-Commerce
Enterprise Resource Planning
Business Intelligence
Artificial Intelligence
Cybercrime
Ethics
.
This document provides an overview of wound healing, its functions, stages, mechanisms, factors affecting it, and complications.
A wound is a break in the integrity of the skin or tissues, which may be associated with disruption of the structure and function.
Healing is the body’s response to injury in an attempt to restore normal structure and functions.
Healing can occur in two ways: Regeneration and Repair
There are 4 phases of wound healing: hemostasis, inflammation, proliferation, and remodeling. This document also describes the mechanism of wound healing. Factors that affect healing include infection, uncontrolled diabetes, poor nutrition, age, anemia, the presence of foreign bodies, etc.
Complications of wound healing like infection, hyperpigmentation of scar, contractures, and keloid formation.
Beyond Degrees - Empowering the Workforce in the Context of Skills-First.pptxEduSkills OECD
Iván Bornacelly, Policy Analyst at the OECD Centre for Skills, OECD, presents at the webinar 'Tackling job market gaps with a skills-first approach' on 12 June 2024
A workshop hosted by the South African Journal of Science aimed at postgraduate students and early career researchers with little or no experience in writing and publishing journal articles.
Leveraging Generative AI to Drive Nonprofit InnovationTechSoup
In this webinar, participants learned how to utilize Generative AI to streamline operations and elevate member engagement. Amazon Web Service experts provided a customer specific use cases and dived into low/no-code tools that are quick and easy to deploy through Amazon Web Service (AWS.)
This presentation was provided by Steph Pollock of The American Psychological Association’s Journals Program, and Damita Snow, of The American Society of Civil Engineers (ASCE), for the initial session of NISO's 2024 Training Series "DEIA in the Scholarly Landscape." Session One: 'Setting Expectations: a DEIA Primer,' was held June 6, 2024.
How to Make a Field Mandatory in Odoo 17Celine George
In Odoo, making a field required can be done through both Python code and XML views. When you set the required attribute to True in Python code, it makes the field required across all views where it's used. Conversely, when you set the required attribute in XML views, it makes the field required only in the context of that particular view.
Strategies for Effective Upskilling is a presentation by Chinwendu Peace in a Your Skill Boost Masterclass organisation by the Excellence Foundation for South Sudan on 08th and 09th June 2024 from 1 PM to 3 PM on each day.
Your Skill Boost Masterclass: Strategies for Effective Upskilling
The State of American Federalism2017–2018 Unilateral Execut.docx
1. The State of American Federalism
2017–2018: Unilateral Executive Action,
Regulatory Rollback, and State Resistance
Shanna Rose* and Greg Goelzhauser†
*Claremont McKenna College
†Utah State University; [email protected]
The state of American federalism in 2017^2018 is characterized
by federal policy reversals, as the
Trump administration and congressional Republicans continue
to undo many of the Obama
administration’s policies. Two themes are highlighted in this
essay. First, major policy changes
continue to be undertaken primarily through unilateral executive
action, even with Republicans
holding the presidency and both the House and Senate.
Ideological divisions within the
Republican Party prevented Congress from enacting major
legislation, save for a tax reform
measure, and resulted in policy changes on health care,
immigration, and the environment being
made through executive and administrative action. Another
prominent feature of governance in
the early part of theTrump administration has been state
resistance to federal directives, taking the
form primarily but not exclusively of state attorney general
(AG) lawsuits. Democratic AGs filed
lawsuits challengingTrump administration actions on
immigration and clean energy in particular.
Democratic governors and state legislators also took a variety of
other actions to resist Trump
2. administration policies. The federal courts also continue to play
an active role in shaping and
adjudicating controversies impacting federalism.
The state of American federalism in 2017–2018 is characterized
by federal policy
reversals, as the Trump administration and congressional
Republicans continue to
undo many of the Obama administration’s major policies
ranging from the
Affordable Care Act (ACA) to the Clean Power Plan. This
development reflects the
continuation of trends that emerged in the first few months of
the Trump
administration, when “the arrival of a new administration with
radically different
priorities” ushered in “broad policy reversals in arenas such as
health care,
immigration, and the environment, with potentially important
implications for
federalism and intergovernmental relations” (Goelzhauser and
Rose 2017).
Two additional themes emerged in 2017–2018. First, unilateral
executive action
continued to play a prominent role in policymaking at the
federal level despite
3. unified Republican control of the federal government. With the
exception of the
Publius:TheJournal of Federalism volume 48 number 3, pp.
319^344
doi:10.1093/publius/pjy016
AdvanceAccess publication May 24, 2018
� TheAuthor(s) 2018. Published by Oxford University Press on
behalf of CSFAssociates: Publius, Inc.
All rights reserved. For permissions, please email:
[email protected]
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Tax Cuts and Jobs Act that passed in December 2017, widening
ideological
divisions within the Republican Party prevented passage of
major legislation and
resulted in significant policy change occurring primarily
through administrative
action. As Republican lawmakers’ efforts to repeal and replace
4. the ACA succumbed
to legislative gridlock, the Trump administration chipped away
at the law by
withholding Obamacare subsidies and announcing a variety of
new rules making it
easier for insurers to sell, and consumers to buy, insurance
policies that do not
comply with ACA regulations. As immigration reform stalled in
Congress,
President Trump issued a series of executive orders limiting
entry to the United
States from certain countries—orders that were quickly
challenged in the courts.
The administration also took steps to limit environmental
protections—
withdrawing from the Paris Climate Agreement, ending the
Clean Power Plan,
and suspending the Clean Water Rule—and to reduce the size of
Obama-era public
lands designations.
A second emerging theme was state resistance to federal
directives, primarily but
not exclusively through a surge in state attorney general (AG)
lawsuits. As
5. discussed by Paul Nolette and Colin Provost in their article for
this issue, 2017–
2018 saw the continued—and accelerated—rise of litigation
brought by attorneys
general. Democratic state AGs brought scores of legal actions
against the Trump
administration over issues such as immigration and clean
energy, following in the
path of Republican AGs who filed lawsuits challenging Obama
administration
actions in these and other areas. In several of these cases,
federal judges issued
nationwide injunctions barring implementation of Trump
administration actions.
In cases filed or joined by state AGs, federal judges blocked
enforcement of several
of Trump’s executive orders that restricted entry to the United
States from certain
countries and also blocked a Trump effort to reverse an Obama
administration
policy protecting certain unauthorized immigrants from
deportation. Federal
judges also sided with state AGs in ruling that the Trump
administration could not
6. reverse or delay enforcement of certain EPA regulations and
could not alter the
Obama administration’s interpretation of the scope of the
ACA’s contraceptive
coverage requirement.
Democratic governors and state legislators also took a variety of
actions to resist
Trump administration policies. In passing measures inconsistent
with Trump
administration policies, Democratic officials embraced a course
of action pursued
on a regular basis by Republican governors and state legislators
during the Obama
administration, as discussed by Adam Olson, Timothy
Callaghan, and Andrew
Karch in their article for this issue. California Governor Jerry
Brown signed
landmark “sanctuary state” legislation, limiting the cooperation
of state and local
law enforcement with federal immigration authorities—
prompting a federal
lawsuit against the state. Despite the Trump administration’s
rescission of
7. Obama’s hands-off marijuana policy vis-�a-vis the states,
Vermont became the
320 S. Rose and G. Goelzhauser
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Deleted Text: Affordable Care Act (
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ninth state to legalize recreational use of the drug, and the first
to do so through
the legislative process.
Blue-state lawmakers also drafted and occasionally enacted
legislation making
creative end-runs around other federal policies. State officials
in the Northeast have
been particularly intent on pushing back against a provision of
8. the 2017 federal tax
law that caps state and local tax deductions at $10,000,
disproportionately affecting
Democratic-leaning states. Along with contemplating lawsuits
challenging this
change in federal tax law, state officials have considered
various other means of
passing legislation to limit the additional tax burden that the
federal law imposes
on residents of their states. States have also begun to respond to
the Trump
administration’s reversal of the Obama administration’s net-
neutrality regulation,
by enacting state net-neutrality laws that impose various
regulations on internet
service providers and thereby achieve the goals of the now
rescinded Federal
Communications Commission regulation. With Democratic
control of state
government at a low ebb—including only thirteen legislatures,
sixteen governors,
and twenty-two attorneys general—these actions reflect the
vehement resistance of
a remarkably small minority of state officials. Nonetheless,
9. Democratic resistance
to the Trump administration’s agenda seemed to dominate the
popular and
political discourse, leading Merriam-Webster Dictionary to
name “federalism” as
one of the top ten words of the year in 2017.
Public Policy
The next several sections analyze federal and state policy
developments in 2017 and
early 2018, focusing on the areas featuring some of the most
noteworthy
federalism-related developments: health care, immigration,
marijuana, education,
and the environment.
Health Care
The spring and summer of 2017 saw the repeated failure of
congressional efforts to
repeal and replace the ACA, as Frank J. Thompson, Michael K.
Gusmano, and
Shugo Shinohara discuss in their article for this issue.
Congressional leaders had
initially hoped to push through a speedy repeal-only option
following Trump’s
10. inauguration, but were stymied by resistance from some rank-
and-file members
and administration officials who feared political fallout from
eliminating popular
provisions such as the Medicaid expansion and regulations
prohibiting insurance
companies from discriminating against individuals with
preexisting conditions.
Throughout the spring, Congress considered a range of options
including the
Better Care Reconciliation Act, the so-called Skinny Obamacare
Repeal, and the
Graham-Cassidy bill, but each failed in turn. Despite
controlling both chambers of
Congress and the Oval Office, the Republican Party succumbed
to internal
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ideological divisions, status quo bias, and the sheer complexity
of the health care
issue.
In the absence of congressional action to repeal the ACA, the
Trump
administration took a series of executive actions to undermine
the law’s efficacy. In
October 2017, the White House announced that it would stop
making the “cost-
sharing reduction” payments to insurers that subsidize the
purchase of insurance
by millions of low-income Americans. In January 2018, the
administration
unveiled sweeping new rules allowing small businesses to join
together to create
“association” health plans that are exempt from the consumer
protections
mandated by the ACA. State officials joined with consumer
groups and health
insurers to oppose the measure, arguing that the inexpensive,
skimpy plans would
12. attract the youngest, healthiest workers—leaving older, sicker
employees in
traditional health plans and contributing to rising insurance
premiums. In
February 2018, the administration announced a new rule that
makes it easier for
consumers to buy inexpensive insurance policies that do not
comply with ACA
regulations by redefining “short-term, limited-duration
insurance” as plans
covering a period of less than one year; previously, such plans
were defined as
covering less than three months.
Congressional Republicans did enjoy a significant victory in
their battle against
the ACA in December 2017, when Congress passed and
President Trump signed
the most sweeping tax reform bill since 1986. Among other
provisions, the new tax
law eliminates the penalty imposed by the ACA’s individual
mandate, effective
2019. The Congressional Budget Office estimated that repealing
the individual
mandate penalty will reduce federal deficits by approximately
13. $338 billion between
2018 and 2027 and increase the number of uninsured people by
13 million in 2027
(U.S. Congressional Budget Office 2017).
Some Republican-led states also took individual actions to
undermine the
ACA’s efficacy. To be sure, state officials’ actions regarding
the ACA have not
always fallen along partisan lines, as Philip B. Rocco, Andrew
S. Kelly, and Ann C.
Keller demonstrate in their article for this issue analyzing state
participation in the
ACA’s State Innovation Models initiative. On a number of other
issues concerning
ACA implementation, however, Republican state officials have
been active in
undercutting the law’s effectiveness. Most notably, Idaho made
headline news in
January 2018 when Republican Governor C. L. “Butch” Otter
issued an executive
order instructing his state’s insurance department to allow
“creative options” in
health coverage, free from “the overreaching, intrusive nature
of Obamacare and its
14. infringement on Idahoans’ freedoms.” The insurance department
subsequently
pronounced that as long as insurance companies offer at least
one health plan that
complies with ACA rules, they may defy the ACA in other
ways, including selling
low-cost policies that lack certain basic services, imposing
yearly coverage limits,
and discriminating against people with preexisting conditions.
The Trump
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administration rejected Idaho’s plan, however, explaining in a
letter from CMS
administrator Seema Verma that the ACA “remains the law, and
15. we have a duty to
enforce and uphold the law . . . although it is certainly not our
preference.”
However, the letter noted that “with certain modifications,” the
proposal might be
acceptable, and encouraged the Otter administration to
“continue to engage in a
dialogue with [CMS] staff regarding this and other potential
options” (Verma
2018).
In contrast, a number of Democrat-led states responded to
federal efforts to
dismantle the ACA by replacing or shoring up the law at the
state level. Following
the repeal of the federal individual mandate penalty, at least
nine states considered
passing laws that would require residents to have health
insurance, although
prospects for passage remained unclear at the time of writing
(Armour 2018). As
the Trump administration cut back on ACA marketing and
outreach, some states
invested heavily in efforts to enroll new individuals. And as the
administration
16. paved the way for stripped-down, short-term health plans, some
states looked into
tightening regulations on such plans. Whereas the ACA
originally sought to reduce
health disparities among states, such actions in certain states—
and their absence in
others—looked likely to further widen the health care gap
(Sanger-Katz 2018).
In 2017–2018, Republican states continued to seek conservative
new twists on
the optional expansion of Medicaid under the ACA through the
use of waivers.
The scope for such efforts expanded in January 2018, when the
Centers for
Medicare and Medicaid Services (CMS) issued a letter to state
Medicaid directors
providing new guidance for waiver proposals under Section
1115 of the Social
Security Act that would impose work requirements (referred to
as “community
engagement”) as a condition of Medicaid eligibility—an option
that had previously
been firmly rejected by the Obama administration.
Conservatives hailed the
17. development as pro-work and anti-poverty, while liberals saw it
as a thinly-veiled
attempt to reduce coverage of vulnerable groups.
In early 2018, the Trump administration approved three states’
waiver
applications including work requirements. First, CMS approved
a waiver
application from the Republican Governor of Kentucky, Matt
Bevin, titled
“Kentucky Helping to Engage and Achieve Long Term Health”
or KY HEALTH, in
January 2018. In addition to a work requirement, the waiver
included several other
conservative provisions including premiums of up to four
percent of income—
greater than the level approved in any other waiver to date—as
well as coverage
“lock-out periods” for a variety of reasons including
nonpayment of premiums.
Shortly thereafter, CMS approved a similar waiver application
from Indiana, which
had unsuccessfully sought approval of work requirements from
the Obama
18. administration in 2015. In March, CMS approved Arkansas’s
work requirement
application, but deferred the state’s request to reduce eligibility
by lowering the
income threshold from 138 percent to 100 percent of the poverty
level. All three
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states planned to exempt Medicaid beneficiaries from the work
requirement if they
fall into certain categories such as disabled, pregnant, or
primary caregiver,
although the states’ definitions of who meets these criteria
varied.
19. Promptly after CMS approved KY HEALTH, Governor Bevin
issued an
executive order calling for the end of Kentucky’s Medicaid
expansion if the waiver
were to be struck down in court. Undeterred, fifteen Kentucky
Medicaid
beneficiaries filed suit against the Trump administration in the
case of Stewart v.
Hargan (now Stewart v. Azar). The suit charged that Kentucky’s
recently approved
waiver violates the Secretary of HHS’s authority under the
Social Security Act,
because it is not an experimental project consistent with the
objectives of the
Medicaid Act. As Sara Rosenbaum observed, the recently
approved waivers
represent a dramatic departure from those approved by previous
administrations,
which had balanced risks, such as those arising from spending
curbs, against gains,
such as enrollment expansions. Moreover, this strategy for
“selectively culling the
Medicaid population” was particularly striking as it was “set to
unfold against
20. perhaps the nation’s most successful ACA Medicaid
expansion”—championed by
Governor Bevin’s predecessor, Democrat Steve Beshear—under
which upwards of
400,000 people gained coverage (Rosenbaum 2018).
Several other states have expressed an interest in Medicaid
work requirements.
As of March 2018, seven Republican-led states—Arizona,
Kansas, Maine,
Mississippi, New Hampshire, Utah, and Wisconsin—had
pending waiver
applications featuring work requirements as a condition of
eligibility (Musumeci
et al. 2018). Utah’s application in particular received attention
because, like
Arkansas’s deferred request, it also sought to reduce eligibility
from 138 percent to
100 percent of the federal poverty level while continuing to
receive the same federal
contribution rate. A few other states, including Oklahoma and
Florida, mulled the
possibility of following suit with work-requirement waiver
applications of their
own. Meanwhile, an investigation by the Government
21. Accountability Office found
that there has been insufficient federal and state oversight of
Medicaid waivers, and
that waiver evaluations have “generally lacked rigor” and
suffered from “significant
methodological weaknesses,” calling into question the growing
use of waivers to
dramatically remake the Medicaid program (U.S. GAO 2018).
The ongoing opioid crisis in the United States prompted
governors to join with
medical providers and health-care advocates in pushing
Congress to repeal a long-
standing rule that limits states’ ability to use Medicaid to fund
care for opioid
addiction. The so-called “Institutions for Mental Diseases
(IMD) Exclusion”
restricts Medicaid payments to facilities with more than sixteen
beds from
providing substance abuse treatment, reflecting the federal
government’s efforts,
around the time of Medicaid’s enactment, to deinstitutionalize
mental-health
patients and integrate them into communities. The push to
repeal the rule
22. represents a rare instance of bipartisan consensus among
governors. In the absence
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of congressional action, the Trump administration granted
waivers allowing two
states (Kentucky and West Virginia) to get around the IMD
exclusion, and
signaled its openness to considering additional applications.
Immigration
Immigration federalism remains at center stage in the policy
arena, as described
more fully by Gary M. Reich in his article in this issue. Many of
the most
pressing issues are embroiled in ongoing litigation. Federal
23. courts enjoined the
first two iterations of President Trump’s executive orders in
early 2017 limiting
entry from certain countries. The Supreme Court in June 2017
agreed to review
the validity of the second executive order, but this order expired
and the case was
dismissed from the docket. Upon the second executive order’s
expiration,
President Trump in September 2017 issued Proclamation 9645
(2017) limiting
entry from nationals of Chad, Iran, Libya, North Korea, Syria,
Venezuela, and
Yemen (though Chad was removed in April 2018). After the
U.S. Court of
Appeals for the Ninth Circuit largely upheld but narrowed a
district court’s
injunction against this third version of the travel ban, the
Supreme Court again
granted review and the case is set for oral argument in April
2018. The Court
granted certiorari to address several questions, including
whether the claims are
justiciable, whether the proclamation falls within the
24. president’s statutory and
constitutional authority, and whether it violates the First
Amendment’s
Establishment Clause.
Policies concerning so-called “sanctuary” jurisdictions continue
to raise
important federalism issues. As municipal governments
continue to adopt policies
that limit cooperation with federal law enforcement officials
with respect to
immigration, several states have moved to limit local
government authority in this
area. Most prominently, Texas enacted legislation in 2017
preventing local entities
from passing policies that “prohibit[] or materially limit[] the
enforcement of
immigration laws” (Texas Senate Bill 4 [2017]). Moreover, the
bill commands local
law enforcement to “comply with, honor, and fulfill” ICE
detainer requests (Texas
Senate Bill 4 [2017]). The City of El Cenizo initiated litigation
alleging, among
other claims, that federal law preempts the bill; that it violates
the U.S.
25. Constitution’s First and Fourteenth Amendments; and that it
violates separation of
powers and home rule provisions of the Texas Constitution.
After a federal district
court initially enjoined enforcement of parts of the law (City of
Cenizo v. Texas,
No. SA-17-CV-404-OLG [2017]), the Fifth Circuit stayed part
of the injunction
(City of Cenizo v. Texas, No. 17-50762 [2017]) and litigation to
resolve the case on
its merits is in progress. Moving in the other direction, several
cities in California
are poised to sue the state in an effort to secure exemptions
from its sanctuary
policies (Holder 2018), which are discussed in more detail
below.
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26. Litigation is also ongoing regarding Executive Order 13768
(2017), where
President Trump stated intent to deny federal funds to
jurisdictions that do not
comply with federal immigration law. In the most thorough
decision on the merits
to date, a federal district court in California enjoined
enforcement of the order,
finding that plaintiff municipalities are likely to prevail in
arguing that the order is
unconstitutional (County of Santa Clara v. Trump, 250 F. Supp.
3d 497 [2017]).
Specifically, the court indicated that municipalities were likely
to succeed in
arguing that the order violated the separation of powers; usurps
congressional
spending authority; violates the Spending Clause, even if the
president had that
authority; violates the Tenth Amendment’s prohibition on
commandeering local
officials; and violates the Fifth Amendment’s Due Process
Clause as a result of
27. various ambiguities, including a lack of clarity on what
constitutes a “sanctuary”
jurisdiction and what actions would constitute violations of the
order. Aside from
the merits, this litigation poses potentially interesting
justiciability questions given
that the order has not yet been enforced. In County of Santa
Clara v. Trump, the
district court argued that it was sufficient that municipal
policies were inconsistent
with the order, that there was expressed intent to enforce the
order, and that
budgetary uncertainty constituted sufficient injury.
Meanwhile Congress continues to consider legislation aimed at
thwarting
sanctuary jurisdictions. In 2017, the House passed the “No
Sanctuary for Criminals
Act” (H.R. 3003). It declares that no governmental entity or
individual may
“prohibit or in any way restrict” efforts to comply with federal
immigration law.
While Senate passage is less likely in its current partisan
configuration, President
Trump continues to lobby for action. In his weekly address on
28. March 10, 2018, he
said, “Sanctuary jurisdictions are the best friend of smugglers,
gang members, drug
dealers, human traffickers, killers, and other violent offenders.
We want our cities
to be sanctuaries for Americans, not safe havens for criminals.
That is why I am
calling on Congress to block funds for jurisdictions that shield
dangerous
criminals.”
On March 6, 2018, the Trump administration brought suit
against California
arguing that federal immigration law preempts recently enacted
California
legislation limiting the ability of employers to provide
nonpublic access to the
workplace without a warrant for immigration enforcement
purposes, directing the
state AG to inspect facilities holding immigration detainees, and
limiting state and
local cooperation with federal immigration enforcement. In its
initial complaint,
the administration argued that these statutes “reflect a
deliberate effort by
29. California to obstruct the United States’ enforcement of federal
immigration law,
to regulate private entities that seek to cooperate with federal
authorities consistent
with their obligations under federal law, and to impede
consultation and
communication between federal and state law enforcement
officials” (Complaint
2018, 2). Consistent with how changing partisan perspectives
have driven recent
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federalism debates more broadly (Goelzhauser and Rose 2017),
the tenor of this
litigation resembles questions resolved by the Supreme Court in
Arizona v. United
30. States, 132 S. Ct. 2492 (2012), where the Obama administration
successfully argued
that antiimmigration laws in Arizona were preempted by federal
immigration law.
Judicial proceedings also continue in the dispute over the
Deferred Action for
Childhood Arrivals (DACA) policy. Announced by President
Obama in 2012,
DACA allowed certain individuals who entered the country as
minors and
remained undocumented to receive renewable two-year permits
and avoid
deportation. After President Obama in 2014 sought to expand
the program, by
putting in place a Deferred Action for Parents of Americans and
Lawful
Permanent Residents (DAPA) program, numerous states
challenged the validity
of the DAPA order. The Supreme Court ultimately affirmed an
injunction against
DAPA by an equally divided vote after Justice Scalia’s passing
(United States v.
Texas, 136 S. Ct. 2271 [2017]). When President Trump moved
to end DACA,
31. numerous states, municipalities, and other entities brought suit
raising various
claims, including that the rescission violated the Administrative
Procedure Act,
the Fifth Amendment’s Due Process Clause, and the Fourteenth
Amendment’s
Equal Protection Clause. Finding that plaintiffs were likely to
succeed on the
merits of the claim that rescission was arbitrary and capricious
and thus invalid
under the Administrative Procedure Act, a federal district court
mandated that
the program be continued (Regents of the University of
California v. United States
Department of Homeland Security, 3: 17-cv-05211 [2018]).
Subsequently, the
Supreme Court denied the government’s request for expedited
review and further
litigation is pending. Simultaneously, Congress continues to
discuss legislative
reform.
Marijuana
Marijuana policy was characterized by growing federal-state
32. conflict in 2017–2018.
In January 2018, U.S. AG Jeff Sessions rescinded a triad of
Obama administration
memos that had established a hands-off policy with regard to
state laws legalizing
marijuana. The Obama administration memos, issued by Deputy
Attorneys
General David Ogden and James Cole, had stated that although
marijuana
remained illegal at the federal level, federal prosecutors should
place low priority
on prosecuting growers, sellers, and consumers as long as they
complied with state
laws. Calling the change in policy a “return to the rule of law,”
Sessions instructed
“federal prosecutors deciding which cases to prosecute to weigh
all relevant
considerations of the crime, the deterrent effect of criminal
prosecution, and the
cumulative impact of particular crimes on the community”
(Sessions 2018).
However, Sessions later clarified that federal law enforcement
lacks the resources to
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prosecute “small” or “routine” cases, and would instead
continue to focus on drug
gangs and other major cases (Gurman 2018).
Political leaders in states where marijuana is legal denounced
the change in
federal guidance. California Lieutenant Governor Gavin
Newsom complained that
the Trump administration had “destructively doubled down on
the failed, costly
and racially discriminatory policy of marijuana criminalization,
trampling on the
will of California voters” (Newsom 2018). Oregon Governor
Kate Brown called the
34. reversal “deeply concerning and disruptive to our state’s
economy,” and protested
that “voters in Oregon were clear when they chose for Oregon
to legalize the sale
of marijuana and the federal government should not stand in the
way of the will of
Oregonians” (Brown 2018). Many state leaders complained that
they had not been
consulted or notified in advance about the change.
Sessions also sent a letter to congressional leaders in 2017,
asking them to repeal
the Rohrabacher-Blumenauer (formerly Rohrabacher-Farr)
Amendment, which
since 2014 has blocked the Justice Department from using
federal tax dollars to
prosecute states where medical marijuana is legal. However,
after two brief
government shutdowns and considerable budgetary uncertainty,
Congress finally
hammered out a budget deal that preserves the amendment, at
least for the time
being.
In stark contrast to the Trump administration’s efforts to crack
down on
35. marijuana, public opinion polls indicated record high support
for legalization of
the drug. According to an October 2017 poll by Gallup, 64
percent of Americans
say the drug should be legal—the highest level of support in the
nearly five decades
Gallup has been polling on the topic. Although a partisan divide
remains, with 72
percent of Democrats favoring legalization compared to 51
percent of Republicans,
2017 was the first time a majority of Republicans have
expressed support for
legalization. The 51 percent approval rate reflects a sizeable
nine percentage-point
increase relative to the previous year. As the Gallup report
observed, “Attorney
General Jeff Sessions could find himself out of step with his
own party if the
current trends continue” (Gallup 2017).
State and local efforts to legalize marijuana progressed in 2017–
2018. Most
notably, Vermont became the ninth state to legalize recreational
use of the drug—
36. and the first to do so through the legislative process.
1
After the state’s Democrat-
controlled legislature passed the bill, Republican Governor Phil
Scott signed it into
law with “mixed emotions,” observing: “A number of states
have already legalized
it surrounding us. Whether we like it or not, it’s here and it’s
being utilized, so we
have to take steps to promote the general public” (Sanders
2018). Reflecting a
bipartisan compromise, the Vermont law does not go as far as
those of other states
that have legalized marijuana. It allows individuals aged
twenty-one years and over
to possess one ounce and to grow up to two plants at home, but
does not permit a
legal retail market for the drug.
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Vermont’s law set an important new precedent that the
Democratic leaders of
several other states signaled they wished to emulate. New
Jersey’s new governor,
Democrat Phil Murphy, campaigned on the issue and, upon
taking office,
expressed his desire to sign legislation legalizing marijuana
during his first year. As
of spring 2018, a bill to legalize the possession and use of small
amounts of the
drug and establish a legal retail market was under consideration
in the state
legislature, but prospects for passage were murky due to
ambivalence or opposition
among lawmakers of both parties. Rhode Island’s Democrat-
controlled general
assembly set up a commission to study legalization, and
Delaware’s Democrat-
controlled general assembly established a task force to do the
same. Meanwhile,
38. advocates in a handful of other states including Michigan and
Ohio pushed to get
recreational marijuana on the 2018 ballot.
Legalization of recreational marijuana in California, passed by
ballot measure in
2016, went into full effect on January 1, 2018, when
recreational sales became legal
for the first time. Although the law allows adults twenty-one
and older to possess
up to one ounce of the drug and to grow up to six plants at
home, the state’s anti-
tobacco laws prohibit residents from smoking the drug in
public. Despite
marijuana’s new legal status within the state, some local
governments moved to
regulate or ban its sale and use. Four of the state’s largest
cities—Los Angeles, San
Diego, San Jose, and San Francisco—allow recreational
cannabis shops, but many
other localities including Bakersfield and much of Orange
County ban all
marijuana businesses. The result is “a rapidly evolving
patchwork of rules that can
39. vary widely from one city to the next” (Staggs 2018).
Implementation of 2016 ballot measures legalizing recreational
marijuana in two
other states—Massachusetts and Maine—was slower, following
months of
deliberations over rules and regulations governing sale of the
drug.
Massachusetts’s Cannabis Control Commission finalized its
rules in March 2018,
paving the way for retail sales to begin in July. In Maine,
Republican Governor
Paul LePage vetoed the legislature’s first bill to regulate
marijuana sales in 2017,
arguing that it conflicted with federal law, was inconsistent
with the state’s medical
marijuana program, and created “a bifurcated regulatory
structure with two
Executive Branch departments regulating the market, which is
almost certain to
create unnecessary additional administrative costs and
confusion,” among other
concerns (LePage 2017). In 2018, state lawmakers set to work
drafting a revised
bill, but its prospects for passage and avoiding another
40. gubernatorial veto
remained unclear.
Lawmakers in several states including California, Alaska, and
Massachusetts
responded to the Trump administration’s reversal of Obama-era
protections for
states that have legalized marijuana by considering bills that
would provide
“sanctuary status” for licensed cannabis businesses. Borrowing
an idea from the
recent state and local movement to protect undocumented
immigrants, the
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measures would prohibit the use of state or local resources to
assist in federal drug
41. enforcement efforts, in the absence of a court order, targeting
businesses or
individuals who are in compliance with state marijuana laws.
Berkeley, California,
passed a resolution making it a marijuana sanctuary city in
February 2018.
Efforts to legalize medical marijuana and decriminalize
possession of small
amounts of the drug also inched forward. West Virginia became
the twenty-ninth
state to legalize the use of marijuana for certain medical
conditions in 2017; the
law only applies to cannabis-infused products, excluding
smokable marijuana.
Several other states including Kentucky, Oklahoma, South
Dakota, Utah, and
Missouri mulled legalization of medical marijuana in 2018,
either through
legislation or ballot initiatives (Sanders 2018). Although
decriminalization of
marijuana stalled in Alabama, several cities including Atlanta,
Albuquerque, and
Kansas City decriminalized the possession of small amounts of
the drug. And San
42. Francisco moved to automatically dismiss all marijuana
misdemeanor convictions
dating back to 1975 and clear the records of individuals who
faced such charges.
Education
The Trump administration’s efforts to scale back the role of the
federal
government in education policy continued in 2017–2018. One
area in which this
shift was particularly apparent was school accountability. The
Every Student
Succeeds Act (ESSA), signed by President Barack Obama in
2015, replaced No
Child Left Behind and diminished the federal role in improving
or closing low-
performing schools by allowing states to establish their own
accountability systems.
In early 2017, congressional Republicans further reduced the
federal role by
rescinding Obama-era regulations clarifying how states should
measure schools’
performance and hold low-performing schools accountable
under the law. U.S.
Secretary of Education Betsy DeVos subsequently released a
43. scaled-back application
template for states to use in developing their accountability
plans that included
fewer requirements than before, particularly with regard to
soliciting input from
the education community. She said the new guidelines would
allow states and
districts to implement the law with “maximum flexibility,” but a
variety of
stakeholders including the National Governors Association,
American Federation
of Teachers, and National PTA expressed disapproval (Klein
2017).
The process by which the Department of Education vetted state
accountability
systems in late 2017 and early 2018 was turbulent. In approving
thirty-five states’
plans while sending others’ back for revisions, DeVos vexed
both congressional
Democrats, who accused the Education Department of rubber-
stamping
inadequate plans, and Republicans eager for maximum state
flexibility.
Education and civil rights groups joined Democrats in
44. criticizing the approval of
state plans that inadequately measured the performance of
certain groups such as
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minority students and inadequately enforced improvement for
those groups
(Camera 2018). DeVos responded by pointing her finger back at
the states for
failing to take full advantage of the new freedom they had been
afforded by
innovating in educational programming. Complaining about
“too many plans that
only meet the bare minimum required by the law,” DeVos
nonetheless vowed not
to fall into the “trap of a top-down approach” that had been
45. pursued by her
predecessors (DeVos 2018).
Another area characterized by federal policy reversals and
federal-state conflict
was Title IX of the Education Amendments of 1972, a federal
civil rights law that
prohibits discrimination on the basis of sex in any educational
program that
receives federal funding. In February 2017, the Trump
administration revoked an
Obama-era guidance letter specifying that public schools should
allow students to
use bathrooms that align with their gender identity. In
rescinding the guidance,
DeVos and Sessions said that Title IX did not compel schools to
allow transgender
students to use the bathroom of their choice, and argued that
states and school
districts should be permitted to determine how to best
accommodate the needs of
transgender students. Civil rights groups criticized the move as
leaving transgender
students susceptible to aggression and violence. One year later,
the Education
46. Department confirmed that it had dismissed several civil rights
complaints from
transgender students who had been prohibited from using school
bathrooms
matching their gender identity, and clarified that it did not plan
to hear or take
action on such complaints.
The Education Department rescinded another Obama-era Title
IX guidance
letter when it offered new guidelines on how schools should
respond to allegations
of sexual assault. In September 2017, the Trump administration
replaced Obama’s
2011 “Dear Colleague” letter with a “Q&A on Campus Sexual
Misconduct” stating
that to protect due process for the accused, schools could use a
more rigorous
standard of proof known as “clear and convincing evidence”
instead of the
“preponderance of the evidence” standard that had been
advanced by the Obama
administration (U.S. Department of Education 2017). The new
guidance also
47. allowed schools to pursue informal resolutions such as
mediation if both parties
agree to it, and to establish an appeals process. The move drew
both praise and
criticism from various groups, but many campuses indicated
that it would have
little effect on their sexual assault policies.
Following the February 2018 mass shooting at Marjory
Stoneman Douglas High
School in Parkland, Florida, public pressure mounted for new
federal and state
policies to promote school safety. In March, the Florida
Legislature passed
sweeping bipartisan legislation that, among other measures,
funded additional
school security and mental health personnel and permitted
certain staff members
to carry guns in schools. Subsequently, several other states
mulled similar
measures. Florida is not the first state to allow teachers to carry
guns, although
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many educational groups including the National Education
Association and
American Federation of Teachers are opposed to the policy
(Hobbs and Brody
2018). For its part, the White House announced a few token
measures—including
the creation of a school safety commission led by DeVos and a
pledge to fund
firearm training to school personnel through the Department of
Justice—but
otherwise left policy changes up to states and school districts,
calling school safety
“a state and local issue” (Camera 2018).
Environment
The Trump administration continues to take steps to limit
environmental
49. protections. As David M. Konisky and Neal D. Woods explain
more fully in this
issue, the federalism implications have been striking. In June
2017, the
administration announced that it would withdraw from the Paris
Climate
Agreement. The agreement is a global pact to reduce emissions
and manage the
global average temperature to counteract climate change.
Examples of important
regulatory maneuvers include the October 2017 announcement
that the
administration would end the Clean Power Plan and January
2018 suspension of
the Clean Water Rule. The former is an Obama-era regulation
that seeks to reduce
carbon dioxide emissions, while the latter subjects certain
waterways to regulation
under the Clean Water Act.
One emerging federalism dispute involves the Corporate
Average Fuel Economy
(CAFE) standards. By regulating vehicle fuel efficiency
standards, the CAFE
standards are widely considered to be an important tool for
50. mitigating emissions
and greenhouse gases. Three recent events surrounding the
CAFE standards are
notable. First, in a lawsuit brought by five states among other
entities, the U.S.
Court of Appeals for the Second Circuit vacated the
administration’s decision to
delay implementation of an Obama-era rule to increase
noncompliance penalties,
which had eroded over time through inflation (National
Resources Defense Counsel
v. National Highway Traffic Safety Administration, 17-2780
[2018]). Second, in a
move “sure to spark major political and legal battles,” the
administration
announced that it would revoke Obama-era standards mandating
certain vehicles
to average more than fifty miles per gallon by 2025 (Eilperin
and Denis 2018).
Third, as discussed in detail in last year’s Annual Review
(Goelzhauser and Rose
2017, 299–300), California’s preemption waiver to adopt more
stringent emission
standards—which in turn have been adopted by numerous
51. states—were thought to
be one of the administration’s key targets for regulatory
rollback. While
announcing a plan to revise CAFE standards, Administrator
Pruitt declared, “EPA
will set a national standard for greenhouse gas emissions that
allows auto
manufacturers to make cars that people both want and can
afford—while still
expanding environmental and safety benefits of newer cars”
(Kulish 2018).
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Referring to California’s waiver specifically, Pruitt added,
“Cooperative federalism
52. doesn’t mean that one state can dictate standards for the rest of
the country”
(Kulisch 2018).
States and municipalities are combatting efforts to limit
environmental
protection in several additional ways. During the Trump
administration’s first year,
Democratic state attorneys general brought dozens of legal
actions over issues such
as clean energy, pollution, and federal lands (Grandoni 2018).
In February 2018,
for example, New York led a coalition of eleven states
challenging the Clean Water
Rule’s suspension as a violation of the Administrative
Procedure Act. In the
complaint, plaintiff states argued that the suspension “harms the
States’ waters by
limiting the [Clean Water] Act’s protections and by making
implementation of the
Act more difficult,” while also impos[ing] economic burdens
and costs upon the
States and harm[ing] their proprietary interests” (Complaint
2018, 4). Litigation
over the Clean Power Plan also remains active.
53. Aside from litigation, states and municipalities are taking a
variety of steps
toward enhancing environmental protection. After the Trump
administration
announced withdrawal from the Paris Climate Agreement,
numerous governmental
entities pledged support for the agreement (Jordans and
Thiesing 2017). At the
state level, California continues to lead the way toward
enhanced environmental
protection, aggressively pursuing emissions cuts while outlining
new strategies in
areas such as renewable power and transportation (e.g., Plumer
2017). Legislative
leaders in Oregon are hoping to pass a cap on greenhouse gas
emissions in 2019
(Selsky and James 2018). And while the effort failed,
Washington’s Governor Jay
Inslee pursued “the nation’s first tax on planet-warming carbon
dioxide pollution”
in what may have been a play for visibility as a Democratic
candidate for president
in 2020 (Davenport 2018). At the municipal level, New York
City sued oil
54. companies such as BP, Chevron, and ExxonMobil to recover for
alleged past and
future injuries resulting from company actions that may have
contributed to
climate change (Mooney and Grandoni 2018).
The administration’s efforts to drill for oil and gas have also
generated
federalism controversies. In January 2018, the Trump
administration announced a
proposal to permit drilling for oil and gas in various waters
comprising the outer
continental shelf. The proposal was met with immediate
disapproval from various
state leaders, and Interior Secretary Ryan Zinke emphasized that
“states, local
communities and congressional delegations will all have a say”
(Fears 2018). A few
days later, Secretary Zinke met with Florida’s Republican
Governor Rick Scott,
who earlier announced opposition to the proposal, and declared
the state “unique”
and “off the table” with respect to coastal drilling (Bousquet
2018). This exemption
55. led politicians from other states to seek exemptions, and several
Democrats alleged
that the disparate treatment was a result of partisan divergence
rather than
Florida’s unique circumstances (Daley 2018). The
administration subsequently
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walked back the promise of an exemption for Florida, but the
debate continues
and numerous states are exploring legal efforts to frustrate the
proposal’s
implementation (Muoio and French 2018).
As John Freemuth details in this issue, public lands have also
been a hotbed for
debate concerning federalism and the environment. Upon taking
56. office, President
Trump ordered review of twenty-seven national monuments
designated since 1996
under the Antiquities Act (Eilperin 2017). Several public lands
designations by
President Obama proved particularly controversial. In December
2017, President
Trump dramatically reduced the size of two Obama-era
designations in Utah—
Bears Ears and Grand Staircase-Escalante—citing the
importance of local control
(Gonzales, Siegler, and Dwyer 2017). Subsequently, evidence
from a public records
request litigated by The New York Times revealed that a desire
to open certain
public lands to oil and gas drilling motivated the decisions
(Lipton and Friedman
2018). While litigation over the scope of presidential power to
shrink designations
under the Antiquities Act continues, the administration
continues to review public
lands boundaries for reshaping.
The Supreme Court
The judiciary remains an active arena for federalism. In its 2016
57. Term, which
spanned October 2016 through June 2017, the Supreme Court
did not issue any
decisions fundamentally altering core areas of federalism
jurisprudence such as
commerce or the Tenth Amendment. Nonetheless, numerous
decisions have
important federalism implications. With the Court returning to
full strength in
April 2017 after Justice Neil Gorsuch’s confirmation, it is
poised to address a
number of critical questions concerning federalism during its
2017 Term. While
this section focuses on the Supreme Court, the reservoir of
percolating issues is
well stocked. As Nolette and Provost demonstrate in their
article for this issue,
state attorneys general remain active participants in the judicial
arena, challenging
various executive branch actions. Immigration and
environmental policymaking
are areas where important litigation is likely to reach the Court
in the near future
as we discussed previously. The rest of this part of the article
58. discusses decisions
implicating federalism from the Court’s most recently
completed term as well as
important pending cases in its current term.
The 2016 Term
One consequential case joined the issues of federalism, race
discrimination, and
housing policy. In Bank of America v. City of Miami, 137 S. Ct.
1296 (2017), the
Court allowed the city of Miami to bring suit against two banks
for alleged
violations of the Fair Housing Act (FHA). Miami argued that
Bank of America and
Wells Fargo issued riskier mortgages to black and Latino
customers in violation of
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59. the FHA, resulting in harm to the city as a result of factors such
as decreased tax
revenue and increased spending on municipal services as a
result of foreclosures.
While it is common for states and municipalities to sue on
behalf of their citizens
as parens patriae, Miami alleged that it was an “aggrieved
person” under the FHA.
The Court held five-three that the city’s alleged injuries were
within the “zone of
interests” the statute was designed to protect. Although the
Court remanded the
case for reconsideration of whether the banks’ alleged
discriminatory lending
practices actually caused the city’s financial injuries, allowing
municipalities to seek
recovery under the FHA has important federalism implications.
The Court decided two important redistricting cases. These
cases demonstrated
the Court’s willingness to grapple with redistricting and help
set the stage for what
promises to be an active 2018 on this front as discussed in more
detail below. In
60. Cooper v. Harris, 137 S. Ct. 1455 (2017), the Court held by a
five-three vote that
two of North Carolina’s congressional districts were drawn to
pack-in black voters
in violation of the Fourteenth Amendment’s Equal Protection
Clause. North
Carolina argued that one of the district’s boundaries nonetheless
satisfied strict
scrutiny because it was drawn to satisfy the Voting Rights Act
(VRA)—an
argument the Court rejected. Writing in dissent, Justice Alito
suggested that “if a
court mistakes a political gerrymander for a racial gerrymander,
it illegitimately
invades a traditional domain of state authority, usurping the role
of a state’s
elected representatives” (1490). Importantly, Justice Thomas
provided a fifth vote
for the majority.
In Bethune-Hill v. State Bd. Of Elections, 137 S. Ct. 788
(2017), the Court
considered whether twelve Virginia legislative districts
explicitly drawn to create a
61. black voting-age population of at least 55 percent violated the
Fourteenth
Amendment’s Equal Protection Clause. The three-judge district
court upheld the
constitutionality of each district. With respect to one of those
districts, the Court
held that the state’s effort to comply with the VRA was
sufficient for satisfying
strict scrutiny. With respect to the other eleven districts,
however, the Court held
that the three-judge district court panel applied the wrong test
and remanded for
reconsideration. Specifically, the Court clarified two points of
law. First, it noted
that a plaintiff need not show actual conflict between a
redistricting plan and
traditional redistricting principles; rather, racial predominance
can be shown
through evidence with respect to legislative purpose or more
circumstantial
evidence concerning district lines or demographics. Second, the
Court held that
analyses regarding racial predominance in line drawing should
be holistic rather
62. than limiting the consideration of racial motive to the extent
that plaintiffs identify
deviations from traditional redistricting criteria specifically
attributable to race.
The Court decided several preemption cases, but none make a
major
contribution preemption jurisprudence. In Howell v. Howell,
137 S. Ct. 1400
(2017), the Court held that the Uniform Services Former
Spouses’ Protection Act
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preempts a state court’s order treating a portion of retirement
pay waived to
receive disability benefits as community property for division in
divorce. In
Kindred Nursing Centers v. Clark, 137 S. Ct. 1421 (2017), the
63. Court held that the
Federal Arbitration Act preempted a state court decision
refusing to recognize the
validity of arbitration agreements executed by individuals who
held power of
attorney, when federal law otherwise requires such agreements
to be treated the
same as other contracts. And in Coventry Health Care of
Missouri v. Nevils, 137 S.
Ct. 1190 (2017), the Court held that the Federal Employees
Health Benefits Act
preempts state law prohibiting private carriers providing
insurance to public
employees under the Act from seeking reimbursement (i.e.,
recovering payment
received from another entity) and subrogation (i.e., transfer of a
right to a third-
party payment to the insurer who can then pursue recovery)
after an insured wins
judgment from a third party. All judgments were unanimous
except Kindred
Nursing, where Justice Thomas adhered to his view that the
Federal Arbitration Act
does not apply in state court proceedings.
64. With respect to decisions affecting state actions and
policymaking, the Court
decided several cases with First Amendment implications. In
Packingham v. North
Carolina, 137 S. Ct. 1730 (2017), the Court unanimously
invalidated a state law
making it a felony for registered sex offenders to access a social
networking site
known to permit use by minors. Although the Court recognized
the state’s
significant interest in protecting minors from sexual
exploitation, it found that
North Carolina’s regulatory approach was too broad. In
Expressions Hair Design v.
Schneiderman, 137 S. Ct. 1144 (2017), the Court considered the
validity of a New
York law prohibiting sellers from imposing a surcharge on
credit card transactions
while allowing the economic equivalent of offering a cash
discount. Whereas the
lower court held that the law permissibly regulated conduct as
opposed to speech,
the Court unanimously held that the law regulated speech by
dictating how
65. businesses communicate with respect to the discount/fee.
However, the Court
sidestepped the underlying constitutional question, remanding
the case for
reconsideration in light of the speech versus conduct
distinction. This “quarter-loaf
outcome” (1153), as Justice Sonia Sotomayor put it in a
concurrence in the
judgment joined by infrequent ally Justice Samuel Alito, may
have reflected
division on the underlying merits question absent a ninth
justice. Turning to the
religion clauses, in Trinity Lutheran Church of Columbia v.
Comer, 137 S. Ct. 2012
(2017), the Court invalidated a state agency’s decision to
categorically deny
churches access to grant money to purchase recycled tire
material for playgrounds.
Although the agency argued that its refusal was dictated by a
state constitutional
provision prohibiting any money from being “taken from the
public treasury” and
given “directly or indirectly in aid of any church” (2017,
quoting the Missouri
66. Constitution), the Court held seven-two that denial of access to
monies otherwise
available on a general basis violates the Free Exercise Clause.
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The Court also addressed an important question at the
intersection of property
rights and environmental protection—with widespread
implications for states and
municipalities. At issue in Murr v. Wisconsin, 137 S. Ct. 1933
(2017), was how to
define the relevant unit of property when assessing a regulatory
takings claim. As
opposed to state seizure of property in a traditional takings
dispute, a regulatory
takings dispute arises when a landowner attributes government
67. action to a loss in
property value or economic use. The plaintiffs in Murr owned
two adjacent lots
abutting a river, and wanted to sell a single 1.25 acre lot. A
regulation dictated that
at least 1.0 acre be suitable for development to sell one of two
commonly owned
adjacent lots, but after unsuitable areas were subtracted
pursuant to regulations
designed to protect the river area plaintiffs were left with a 0.5
acre lot for
development purposes. After being denied a variance by the
county board,
plaintiffs sought recovery for a regulatory taking. Finding that
plaintiffs retained
options for land use in the adjacent lots, the Wisconsin Court of
Appeals held that
the regulations did not deprive plaintiffs of all or substantially
all economic value
in the property. Plaintiffs, however, argued that the court
improperly calculated
value by combining both parcels rather than focusing on the
parcel they were not
allowed to sell.
68. States were active as amici in Murr. Eight states argued that
aggregating the
adjacent lots for valuation purposes was improper, preferring to
base the decision
on the fact that state law joined the parcels for development
purposes. They
contended that their interests as amici were “at its apex” due to
the potential
impairment of property rights for “citizens vis-a-vis the States”
and “States as
against the federal government” (Brief for Nevada et al. as
Amici Curiae 2016, 1).
Nine states, meanwhile, argued for aggregation, contending that
their interests lie
in balancing property rights with a desire to “protect the
environment” and
“ensure that development occurs in a balanced manner,
benefiting both property
owners and the larger community” (Brief for California et al. as
Amici Curiae
2016, 1). State and municipal interests such as the Council of
State Governments,
National Association of Counties, National League of Cities,
and U.S. Conference
69. of Mayors also filed a joint amicus brief for the respondent. In a
five-three
decision, the Court ruled for the respondent and proposed a
multifactor test to
guide future decisions that includes considering how property is
treated under state
law, the property’s physical characteristics, and the land’s
prospective value.
Writing in dissent, Chief Justice John Roberts lamented that the
new test
“compromises the Takings Clause as a barrier between
individuals and the press of
the public interest” (1956).
Several of the Court’s decisions have implications for how
states implement the
death penalty. The Court granted certiorari in McWilliams v.
Dunn, 137 S. Ct. 1790
(2017), to determine whether a prior precedent clearly dictated
that states must
afford indigent defendants meaningful expert assistance
independent of the
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prosecution. In what a four-justice dissent called “a most
unseemly maneuver”
(1802), the five-justice majority sidestepped this question but
found that Alabama’s
provision of mental health assistance during the underlying
capital proceedings
“fell . . . dramatically short” of the constitutional minimum
(1801). In Moore v.
Texas, 137 S. Ct. 1039 (2017), the Court vacated a Texas Court
of Criminal
Appeals decision to disregard contemporary guidelines for
determining whether a
capital defendant is intellectually disabled in favor of
guidelines adopted by the
Texas court in 1992. And In Buck v. Davis, 137 S. Ct. 759
(2017), the Court
71. granted habeas relief for ineffective assistance of counsel after
a psychologist
testifying for the defendant, who is black, claimed that the
defendant’s race was
“know[n] to predict future dangerousness” (769), thus aiding
the prosecution in
demonstrating a necessary element for a death sentence, which
the jury
subsequently imposed.
The Court also continues to actively use its “shadow docket,”
which refers to
“a range of orders and summary decisions that defy its normal
procedural
regularity” (Baude 2015, 1), to dispose of important issues, and
several of last
term’s summary decisions impact states. In Bosse v. Oklahoma,
137 S. Ct. 1
(2016), the Court unanimously vacated a decision by the
Oklahoma Court of
Criminal Appeals stating that the Court had “implicitly
overruled” (2) a prior
precedent holding that the Eighth Amendment prohibited the use
of victim
impact evidence unrelated to the crime at a capital sentencing
72. hearing. The Court
also unanimously vacated a decision by the Nevada Supreme
Court in Rippo v.
Baker, 137 S. Ct. 905 (2017), which it deemed had applied the
wrong legal
standard in declaring that a request for judicial recusal due to
bias could not go
forward absent evidence of actual bias, whereas the Court had
previously
indicated that such a claim could go forward under the
Fourteenth Amendment’s
Due Process Clause when “the probability of actual bias . . . is
too high to be
constitutionally tolerable” (907). And in Pavan v. Smith, 137 S.
Ct. 2075 (2017),
the Court summarily reversed an Arkansas Supreme Court
ruling that a state
requirement to list the name of a mother’s male spouse on a
birth certificate need
not be applied to same-sex couples. In a six-three per curiam
decision, the Court
held that this was included in the “constellation of benefits”
(2078) the state
linked to marriage and was thus encompassed by the Court’s
73. ruling in Obergefell
v. Hodges, 135 S. Ct. 2584 (2015). Justice Gorsuch dissented,
joined by Justices
Alito and Clarence Thomas, arguing that “the strong medicine
of summary
reversal” (2080) is not warranted where the outcome is not
clearly dictated by
Obergefell. Although the dissenters did not reach a conclusion
on the merits,
Justice Gorsuch’s opinion offers an early signal of his position
on questions
concerning Obergefell’s application. On the other side, that
Chief Justice Roberts
joined the majority disposition is notable.
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74. Percolating Issues
With a full Court for a complete term for the first time since
Justice Antonin
Scalia’s passing, the 2017 Term promises to be a blockbuster
compared to recent
years. Murphy v. National Collegiate Athletic Association, 16-
476 (2016), is perhaps
the most important case with respect to core federalism
doctrine. It considers
whether a federal law prohibiting states from authorizing sports
betting
unconstitutionally commandeers New Jersey—in violation of
the Tenth
Amendment and broader constitutional structure—in the wake
of the state
partially repealing its sports betting law. Perhaps the most
salient case more
generally, which also has important federalism implications, is
Masterpiece
Cakeshop v. Colorado Civil Rights Commission, 16-111 (2016).
After being held on
the Court’s docket for nearly a year, this case considers whether
a state’s
antidiscrimination law can be used to require a custom cake
75. maker to provide
service to a same-sex couple under the First Amendment’s
Speech and Free
Exercise Clauses. In addition to the case’s First Amendment
implications, it
promises to further the Court’s development of jurisprudence on
issues concerning
discrimination on the basis of sexual orientation.
The Court’s 2017 Term includes several other First Amendment
cases with
policy implications for the states. In Janus v. American
Federation of State, County,
and Municipal Employees, No. 16-1466 (2017), the Court
revisits the issue of
whether mandatory union fees violate the Speech Clause, a
question on which it
deadlocked in 2016 after Justice Scalia’s passing. Thus, Justice
Gorsuch’s vote will
presumably be decisive. In Minnesota Voters Alliance v.
Mansky, No. 16-1435
(2017), the Court considers whether a Minnesota law
prohibiting political badges,
buttons, and insignia from being worn around a polling place on
election day
76. violates the Speech Clause. In National Institute of Family Life
v. Becerra, 16-1140
(2017), the Court will address whether a California law
requiring antichoice, state
regulated clinics to provide information on issues such as state-
funded abortion
services violates the Speech and Free Exercise Clauses. The
Court considers whether
a plaintiff alleging retaliatory arrest under Section 1983 must
plead and prove the
absence of probable cause in Lozman v. City of Riviera Beach,
17-21 (2017), a
question that arises out of a long-running dispute between a
resident and city
council. In Benisek v. Lamone, 17-333 (2017), the Court
considers a First
Amendment retaliation claim in the context of a Maryland
redistricting dispute.
Several other redistricting and voting cases are on the Court’s
current docket. With
respect to voting, Husted v. A Philip Randolph Institute, 16-980
(2017), examines
whether Ohio’s decision to trigger removal from its voter file
after two years of
77. inactivity is consistent with federal law. The most prominent
redistricting cases are Gill
v. Whitford, 16-1161 (2017), which raises a variety of questions
concerning a state
legislative redistricting plan in Wisconsin, and Benisek v.
Lamone, which addresses
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claims of partisan gerrymandering regarding a congressional
redistricting plan in
Maryland. In addition to the substantive questions presented in
these cases, the Court
is considering whether partisan gerrymandering claims are
justiciable—an issue that
could have important implications for future litigation. The
78. Court turns to the subject
of racial gerrymandering in Abbot v. Perez, 17-586 (2017).
Supporting Texas, seven
states filed a joint amicus brief urging the Court to note
probable jurisdiction and
reverse the lower court’s decision invalidating certain state
congressional districts,
warning that the district court decision could “throw[] elections
into disarray” and
have “widespread implications for States entering the 2018
election cycle and the
coming 2020 redistricting cycle, destabilizing the democratic
system in all States” (Brief
for Louisiana et al. as Amici Curiae 2017, 1). Aside from these
docketed cases, the
Court also entered a partial stay of a lower court’s decision
invalidating districts in
North Carolina. However, the Court declined to stay a
Pennsylvania Supreme Court
decision invalidating the state’s congressional map under the
Pennsylvania
Constitution as the product of partisan gerrymandering.
Another case on the Court’s current docket worth watching for
its federalism
79. implications is South Dakota v. Wayfair, 17-494 (2017). In
Quill v. North Dakota,
504 U.S. 298 (1992), the Court reaffirmed a long-standing
precedent that a state
violates the dormant Commerce Clause when requiring out-of-
state companies
with no instate physical presence to pay taxes on sales to state
residents. At issue in
Wayfair is whether the physical-presence rule, which emanates
from cases
concerning the mail-order industry, should be jettisoned in an
era where e-
commerce plays an integral role in the marketplace. In support
of South Dakota’s
effort to overturn Quill, forty-one states filed a joint amicus
brief arguing that the
status quo leaves them “in an increasingly untenable position,”
depriving states of
“billions of dollars in tax revenue each year, requiring cuts to
critical government
programs” (Brief for Colorado et al. as Amici Curiae 2018, 1).
Conclusion
The key themes that characterized the state of American
federalism in 2017–2018
80. included federal policy reversal, executive action, and state
resistance. As we
observed in last year’s annual review, “unified government is
not necessarily a
panacea for increased legislative production” (Goelzhauser and
Rose 2017, 308).
With the Republican-controlled Congress largely sidelined by
partisan infighting,
the Trump administration stepped into the vacuum, with wide-
ranging
consequences for both the Obama administration’s legacy and
intergovernmental
relations. In the absence of federal legislation on health care
reform, immigration
reform, and a host of other pressing issues, federal policy
change emanated
primarily from the White House. In a sense, these developments
reflect the
continuation of Obama-era trends; however, what is striking in
the current
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political environment is that executive action continues to be so
prominent in the
context of unified party control of government.
State resistance to the Trump administration’s agenda also took
place largely
outside the legislative arena. Taking a cue from the Republican
attorneys general
who had challenged the ACA, EPA rules, and other Obama-era
policies in court,
Democratic attorneys general stepped into the fray in 2017–
2018 with scores of
legal actions against the Trump administration, many of which
were still making
their way through the courts at the time of writing. “Once a
staid backwater
mostly seen as a political stepping stone,” the office of the state
AG has emerged as
82. a major bulwark, playing “among the most pivotal roles slowing
and stopping the
march of the Trump agenda” (Neuhauser 2017). The prominent
role of
Democratic state attorneys general in fighting administration
policies is, in part, a
function of the Democratic Party’s limited control of state
legislatures and
governorships—something that could change following the 2018
election.
Notes
The authors are listed in reverse alphabetical order but
contributed equally to the article.
The authors thank John Dinan and two anonymous referees for
helpful comments on earlier
drafts. S.R. thanks Ellen Lempres for research assistance and
the Rose Institute of State and
Local Government for support.
1. Colorado, Washington, Alaska, Oregon, California, Nevada,
Maine, Massachusetts, and
Washington, DC, legalized recreational use of marijuana
through ballot initiatives.
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