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Recent Projects

Viewing recent projects in Safety and Consumer Protection
  • Public Comments

    Comments on Repeal of Payday Lending Rule

    May 14, 2019

    The Consumer Financial Protection Bureau is proposing to repeal a rule that protects borrowers from exploitative payday lending practices. We submitted comments focusing on CFPB’s failure to provide a reasoned explanation for reversing key legal and economic conclusions of the rule.

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  • News

    Court Blocks Rule Making Harmful Changes to Title X Women’s Health Services

    April 26, 2019

    The Institute for Policy Integrity helped contribute to a significant legal victory, as district courts in Washington State, Oregon, and California blocked a Trump administration rule that makes harmful changes to federally-funded women’s health services. In February, the Department of Health and Human Services (HHS) announced onerous restrictions to its Title X program, likely forcing the shutdown of some family planning clinics and closing off access to others for low-income women. We submitted comments on the rule and amicus briefs supporting requests for preliminary injunction in four court cases. The Eastern District of Washington refers to our brief in the reasoning for its decision to grant an injunction. The Northern District of California’s ruling cites our brief and devotes a lengthy discussion to the arguments we advanced.

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  • Court Filings

    Amicus Brief on Harmful Changes to Title X Women’s Health Services

    April 5, 2019

    The Department of Health and Human Services (HHS) issued a final rule that makes detrimental revisions to the federal Title X program, which funds free or low-cost reproductive health services for millions of women each year. HHS would impose onerous restrictions that will likely force the shutdown of key health clinics that rely on federal funding. We submitted an amicus brief to the U.S. District Court for the Northern District of California in support of the plaintiff’s motions for preliminary injunction. Plaintiffs argue that the final rule is arbitrary and capricious because HHS failed to accurately assess the rule’s health costs, compliance costs, and alleged benefits. Our brief provides the court with context on the legal and economic standards for regulatory impact analysis to detail how HHS’s assessment of the rule thoroughly flunks those standards.

    We also filed briefs in Title X cases in the District of Oregon, Eastern District of Washington, and District of Maine.

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  • News

    New Tracking Resource: Health and Environmental Benefits Threatened by Deregulation

    March 14, 2019

    Our new tracking resource tallies the benefits to public health and the environment that are at risk due to regulatory repeals, delays, and revisions. Since 2017, numerous environmental rules have been the subject of the Trump administration’s deregulatory agenda. The original rules highlighted in our document were economically justified, meaning each was supported by a detailed account of its monetized benefits to the American public, which outweighed projected costs. Now, as the administration works to undo these rules, a wide range of crucial benefits could be lost. Our resource provides information on the kinds of benefits at risk, monetized gross and net benefit estimates, and other unquantified health and environmental effects of several federal rules.

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  • Public Comments

    Comments to EPA on Delay of Emissions Rule for Wood Heaters

    January 14, 2019

    The Environmental Protection Agency (EPA) is proposing to amend the 2015 New Source Performance Standards (NSPS) for residential wood heating devices. This change would allow retailers to sell non-compliant wood heaters for two years past the original 2020 compliance date. We submitted comments explaining that the proposed rule imposes net costs on society and is not justified by EPA’s faulty analysis.

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  • Public Comments

    Comments on Proposed Regulation to Require Drug Price Disclosures

    December 17, 2018

    The Centers for Medicare and Medicaid Services (CMS) recently proposed a rule that would require pharmaceutical companies to disclose the list prices of prescription drugs in television ads. We submitted comments pointing out flaws in the agency’s analysis of the proposal’s likely costs and benefits.

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  • Public Comments

    Comments on the Family Detention Rule

    November 6, 2018

    A recently proposed rule would allow the Department of Homeland Security to indefinitely detain immigrant children who enter the U.S. in the company of a parent or guardian. Under current law, such children must be released or transferred to a non-secure, state-licensed facility within 20 days. We filed comments critiquing the Department’s assessment of the costs and benefits of this policy change.

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  • Public Comments

    Comments to BLM on Wright Area Coal Lease Extensions in Wyoming

    October 4, 2018

    The Bureau of Land Management (BLM) recently published a draft environmental assessment (EA) of coal lease extensions in the Wright Area of Wyoming. BLM’s new analysis reaffirms its 2010 environmental impact statement (EIS) on the same lease extensions despite a court order instructing BLM to correct false assumptions of coal leasing economics.. We submitted comments describing how the agency fails to improve its analysis and instead makes the same critical omissions and mistakes.

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  • Court Filings

    Court Vacates Delays of Department of Education’s Borrower Defense Rule

    September 17, 2018

    A United States District Judge recently ruled that the Department of Education’s repeated delays of the Borrower Defense Rule were illegal. We submitted an amicus brief in this case. This 2016 regulation was designed to help students who have been defrauded by for-profit educational institutions discharge their federal student loans. Under Secretary Betsy DeVos, the Department of Education delayed implementation of the Borrower Defense Rule three times, prompting a legal challenge.

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  • Public Comments

    Comments to FDA on Limiting Nicotine Content of Cigarettes

    July 16, 2018

    As part of a larger plan to revise regulations on tobacco and nicotine, the U.S. Food and Drug Administration (FDA) is considering limiting the nicotine content of combusted cigarettes in an effort to make them less addictive. In response to FDA’s advance notice of proposed rulemaking on this potential policy, our comments offered advice, drawing from recent economic scholarship, on how the agency could assess a nicotine limit’s costs and benefits.

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