Project Updates – Health and Human Services

  • Wednesday
    March 20th,
    2013

    Letter to OIRA on Review Delay

    Policy Integrity submitted a letter to OIRA on its long delay in reviewing two rules from the Department of Labor. The rules, Occupational Exposure to Crystalline Silica and Occupational Injury and Illness Recording and Reporting Requirements, have been under review for 764 and 483 days, respectively. OIRA review of rules from the Department of Labor since 1994, the first full year of review under the 90-day framework established by Executive Order 12866, has lasted an average of only 60 days.

    Undue delay in the regulatory review process can impose costs on the public, create uncertainty for regulated parties, and undermine OIRA’s credibility. Therefore, our letter requests that OIRA either release the rules it has been reviewing for more than 90 days, return those rules to the promulgating agency, or publically disclose the reasons for delay and propose an alternative schedule to complete the regulatory review.

    Issue(s): Health and Human Services   Type: Letters

  • Wednesday
    February 27th,
    2013

    Michael Livermore Gives Congressional Testimony on the Affordable Care Act

    Michael Livermore, director of Policy Integrity, presents testimony today on the Affordable Care Act’s Summary of Benefits and Coverage (SBC) rule to the Senate Committee on Commerce, Science, and Transportation. The testimony will be featured in a hearing entitled, “The Power of Transparency: Giving Consumers the Information They Need to Make Smart Choices in the Health Insurance Market.”

    Michael will be speaking on the importance of the SBC rule in increasing transparency in the health insurance market, with the ultimate aim of improving consumer welfare via informed consumer decision-making. The hearing can be viewed on the Senate Commerce Committee website

    Issue(s): Health and Human Services  

  • Tuesday
    October 9th,
    2012

    Comments on Mortgage Servicing Rules

    In compliance with the Dodd-Frank Act, the Bureau of Consumer Financial Protection has proposed mortgage regulations to address many of the concerns from the subprime mortgage crisis. Policy Integrity submitted comments to the Bureau on two mortgage servicing rules: (1) the RESPA Rule, which lays out requirements for how servicers must interact with the homeowners whose mortgages they service and (2) the TILA rule, which describes certain disclosures that mortgage servicers must send to their customers at particular points.

    Our recommendations to the Bureau for maximizing net social benefits include ensuring that regulatory goals are clearly defined in order to be able to successfully evaluate the effectiveness of different policy alternatives in meeting those goals and assess the performance of the rules on an ongoing basis. The Bureau should also consider ways to improve the disclosures themselves, such as whether to conduct additional consumer testing, whether to adjust the timing of the notices, and whether to add more balanced information regarding the initial interest rate adjustment disclosure. We also urge the Bureau to conduct retrospective analysis of the regulations to determine their effectiveness on an ongoing basis and how they might be improved.

    Issue(s): Health and Human Services  

  • Monday
    July 16th,
    2012

    Comments to the US Sentencing Commission on Sentencing Guidelines

    Policy Integrity sent our report, Balanced Justice, to United States Sentencing Commission in response to its call for public comments on possible priority issues for forthcoming amendments to the Sentencing Guidelines. The guidelines are used to set a uniform sentencing policy for individuals and organizations convicted of felonies and serious misdemeanors.

    We hope to highlight with our submission the ability of applying cost-benefit analysis to criminal justice policy to reveal areas of improvement that can save billions of taxpayer dollars without compromising public safety. The report draws attention to some state initiatives that cost less than incarceration and whose future benefits can dwarf the administrative costs of implementing new criminal justice programs.

    Issue(s): Health and Human Services  

  • Monday
    June 11th,
    2012

    Letter to OMB on Interagency Data Interoperability

    Today, we sent a letter to the White House’s Office of Management and Budget suggesting ways that that federal agencies can use data to work more closely and maximize their efforts on behalf of the American public.

    Different social services programs, overseen by different agencies, often perform similar functions or have similar goals. For instance, many programs distribute financial assistance to reduce poverty or homelessness, or administer services aimed at enhancing access to health care or education. These social services programs also often serve or interface with overlapping populations. The efficacy and cost-effectiveness of these programs is hard to assess for a number of reasons, including that multiple programs contribute to the same output (for instance, better health or educational outcomes).

    However, one of the main reasons that evaluations and comparisons are difficult is because of insufficient or incompatible data. Data from one program may not be compatible with data from another, or a program may not collect information that evaluators of that program or other programs would find useful. Improving data collection and interoperability would enhance the government’s ability to evaluate the success of these programs, both individually and comparatively. These evaluations, in turn, can inform funding allocations to help better ensure that funds are spent where they return the greatest benefit.

    Our letter offers ideas and recommendations on how to overcome these kinds of problems and use data to improve government spending.

    Issue(s): Health and Human Services   Type: Letters