HealthLawProf Blog

Editor: Katharine Van Tassel
Akron Univ. School of Law

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Friday, March 18, 2011

From Guest Blogger Jennifer S. Bard: What Law Students Don’t Understand About The Us News Rankings, How It Can Hurt Them and What We as Law Professors Can Do About it.

 
Bard The US news rankings came out today and although I promise this won’t reduce the amount of health law blogging I’m going to do, there’s a convergence of events this year that deserves discussion.

I think it’s fair to say that these rankings affect us as law professors differently than they do our students or prospective students. A rise in the rankings brings happiness and increased applications while a reduction is often followed by a Dean’s departure.   Also, strong regional preferences aside law professors do give considerable thought to the prestige (and its proxy US News Rank) when choosing among employment offers.  We also spend a lot of time complaining about their inaccuracies and inconsistencies. Finally, at least in terms of the rankings we control—that in our own specialties—they do a good job of highlighting the schools that really are putting their resources into a specialty area.  None of us in Health Law would dispute that this year’s list encompasses the programs leading our field—and congratulations to those programs for being deservedly recognized.

But the question I have is what the general rankings mean to our students.  I’d suggest that since most of our students come to law school with the plan of becoming lawyers and then proceed to take on considerable financial debt, they are looking at ranking as a proxy for employability.  And if so, they are making a big mistake.

It’s certainly fair to say that law students are very aware of the rankings.  A Kaplan 2010 survey of LSAT takers revealed that 86% of respondents felt that “a law school’s ranking…very important” or “somewhat important” in their application decision-making. And although US News itself has tried to put these numbers in context, it is difficult to explain why higher isn’t always better. I think that reflects a serious misunderstanding of the fact that the law business is, for the most part, very regional.  While the large law conglomerates often describe themselves as “national” or “international” in fact that reflects their presence in a number of different locations.  While certainly Big Law partners and associates spend plenty of time travelling, in the end every practicing lawyer is licensed in one or two individual states.

Outside of Big Law, the emphasis on location is even greater.  Lawyers build practices and acquire clients in the state where they are located. If your dream is to go home to New Hampshire to practice law, it’s just not true that going to a school ranked 65 on the West Coast is better than going to the newly constituted University of Hampshire which seems to be bringing up the rear of this year’s rankings.

You wouldn’t know that by reading US News. Exhibiting a common mistake in statistics, most prospective law students seeing a list of law schools imagine that the ranking reflects directly the ability to get the job they want on graduation—wherever that happens to be.  Not true.  Just because you can put things in numerical order doesn’t mean you know what that means.  This is because “[o]rdinal measurements describe order, but not relative size or degree of difference between the items measured. “ A law school ranked 20 is not necessarily twice as good a choice for an individual student as one ranked 40.

At every level from number one in the class on down, most students get jobs with firms or companies who either know them through a part time job or (more likely and) have hired other graduates of their law school.  And although you wouldn’t know it from reading most of our websites, most law school graduates end up practicing either pretty close to where they went to school or somewhere they have personal ties –in which case familiarity with the law school itself isn’t so important.

What prospective law students in their 20’s don’t know yet is as exciting as it sounds to strike out on your own and get a job in the big city at some point family needs—whether of their own children or their parents—tend to nudge people in the direction of home.

While there are many examples of successful transplants, law firms with any interest in retaining a new hire beyond a year or two are well aware of how unlikely it is that a student from a very different region with no visible ties to their cities will actually make a permanent home, let alone be an asset in building a client base.  And the lower that student is in her class, the less likely they are to risk it.  The other important factor is debt load.  A generous scholarship may make it more reasonable to attend law school someplace you would never want to live. 

And yes of course, like everything else, things are probably different in the T-14.  I’m not worried that Ithaca can’t absorb the graduates pouring out of Cornell every year—but on the other hand I think a student in the bottom third of a T-14 law school on the West Coast will find more closed doors on the East Coast than if she had spent three years building her reputation with the bar of her chosen city using the resources of a top 50 law school in another location.  Dealing with the realities of life as we know it—yes, all things being equal, it’s probably better to go to Harvard than not.  But things drop off pretty quickly after that and employers in Chicago will need a good reason to overcome their skepticism that a law student from the Southeast is really going to get into ice fishing.

I think one reason students are misled is because other areas of academic competition are not so regionalized and really do value prestige over location. If you want to go to graduate school at Princeton it’s probably OK that you attended one of the UC schools and no one would suggest that transferring to Rutgers would make admission more likely.

It may well be that the frustration expressed over the last two years that students were “deceived” into going into substantial debt with no real prospect of work is because they borrowed money to go to a law school with a higher rank but less job prospects. See here  and here.  

What can be done?  One thing could be the transparency which the ABA and others are urging on us all.   Perhaps we should not just publish the range of salaries but also the locations of these jobs.  This could be harder than it sounds.  The first few years out of law school are often times of substantial movement.  It also won’t reflect students who have personal ties in a location or who follow a partner to his or her home. But the weight of those numbers will still be useful. Equally useful, and already available but probably not often used, is information about the location of a school’s alumni. 

Another thing we could do is intervene much more strongly in the choices they make as law students.  I see career services and externship programs working hard to make opportunities available which students don’t take because they are spending a lot of time on co-curricular activities which will “look good on their resume.”  Being an extern in a legal setting or even volunteering somewhere legal services are being provided is not only educational, it is a chance to approach employers with a solid track record rather than faceless strangers. That way even if the specific location does not have an opening, they have made themselves known to a network of lawyers who can sincerely recommend them to other employers on the base of their work product—not their participation in activities with other law students.   

This advice may brings cries of protest from everyone who believes it was their published note or moot court victory which got them the job they wanted but remember three things: 1) there are many fewer jobs available than when the vast majority of law professors graduation; 2) the students we teach are for the most part seeking careers as lawyers—not academics and 3) they are graduating with debt levels higher than our mortgages.

Am I suggesting students should ignore US News Rankings?  Not exactly.  Within individual cities or regions they probably do a pretty good job of at least reflecting, and probably shaping, local perceptions.  And, again, probably always better to go to Harvard than not.  But it is simply not true, as many law students may well believe, that a higher ranked school in an area where you don’t want to practice afterwards and with a limited alumni base in your dream location is automatically a better choice than a lower ranked school where you do want to practice. Throw in the debt load factor and the matrix is even further from US News’ list. All of us want to kvell when our schools rise in the ranks (or simply hover near the top) and for faculty there are very real differences in resources available for scholarship, but perhaps it would be helpful to look at our own employment history data and think about how it, and other realities of legal practice, could best be presented to both current and prospective students.

 --  Jennifer S. Bard, Guest Blogger

March 18, 2011 | Permalink | Comments (1) | TrackBack (0)

Adverse Hospital Action But No State Discipline?

The common law implications for institutions failing to disclose adverse results associated with individual physicians were recently discussed here. But what are the downstream results when institutions do take action against physicians with clinical privileges? The answer provided in the Public Citizen report, State Medical Boards Fail to Discipline Doctors With Hospital Actions Against Them, available here, is all too frequently, not much! 

The report analyses 10 years of data in the National Practitioner Data Bank, here. It found that 5,887, or 55%, of physicians who had their clinical privileges revoked or restricted had experienced no state licensing actions. Over 2000 of this cohort had one or more of the most serious violations, such as incompetence or "immediate threat to safety."

It is hard to fault Public Citizen's conclusion:

Hospital disciplinary reports are peer review actions that are one of the most important sources of information for medical board oversight. Subsequent state medical board action against a physician’s license provides a greater assurance than a hospital disciplinary action alone that the practitioners medical practice would be monitored or limited and that other state medical boards and future employers will have a more complete account of a practitioner’s practice history.

Our analysis of physicians with clinical privilege reports but no state licensure action raises serious questions about whether state medical boards are responding adequately to hospital disciplinary reports and whether, as required by federal law, state medical boards are receiving such reports.

[NPT]

 

March 18, 2011 | Permalink | Comments (1) | TrackBack (0)

Worth Reading This Week

Paul M. Secunda, The Forgotten Employee Benefit Crisis: Multiemployer Plans on the Brink, SSRN

Robert A. Mikos, A Critical Appraisal of the Department of Justice's New Approach to Medical Marijuana, SSRN/Stanford Law & Policy Rev.

Lawrence O. Gostin, Peter D. Jacobson, Katherine L. Record & Lorian Hardcastle, Restoring Health to Health Reform: Integrating Medicine and Public Health to Advance the Population's Wellbeing, SSRN/U.Pa.L.Rev.

Sallie Thieme Sanford, What Scribner Wrought: How the Invention of Modern Dialysis Shaped Health Law and Policy, SSRN/Richmond J. Law and Public Interest

[NPT]

 

March 18, 2011 | Permalink | Comments (0) | TrackBack (0)

Thursday, March 17, 2011

Doctors Wary of New IT

The Washington Post recently featured Lena Sun's reporting on why many physicians are wary of adopting an electronic medical records system.  As noted in the piece,

Many are aware that beginning this year, health-care professionals who effectively use electronic records can each receive up to $44,000 over five years through Medicare or up to $63,750 over six years through Medicaid.  But to qualify, doctors must meet a host of strict criteria, including regularly using computerized records to log diagnoses and visits, ordering prescriptions and monitoring for drug interactions. And starting in 2015, those who aren’t digital risk having their Medicare reimbursements cut.

Deven McGraw, director of the health privacy project at the Center for Democracy & Technology, complains that, despite all these requirements, patient confidentiality concerns are being neglected:

But no federal regulations clearly require that doctors turn the data encryption on or prevent those who don’t do so from getting paid. . . . “This is a point of frustration,” said McGraw, who sits on an advisory group that sought unsuccessfully to prevent those who violate privacy regulations of the federal Health Insurance Portability and Accountability Act, or HIPAA, from getting incentive money.

Some older doctors may find it easier to retire than to get on board with new EMR systems.  We frequently hear complaints about Luddite doctors resisting technology that has long been adopted by other sectors.   But, as one commentator recently insisted, a doctor is not a bank.  To get a sense of how frustrated doctors can become because of the new health IT (and the legal contracts that accompany it), check out this parody website for the faux firm Extormity.  It announces a memorable experience for doctor clients/conscripts: 

At the confluence of extortion and conformity lies Extormity, the electronic health records mega-corporation dedicated to offering highly proprietary, difficult to customize and prohibitively expensive healthcare IT solutions. Our flagship product, the Extormity EMR Software Suite, was recently voted “Most Complex” by readers of a leading healthcare industry publication.

I loved this description of a firm committed to maximizing the value of it's intellectual property:

The Extormity EMR Software Suite is built on a proprietary software model renowned for its complexity. This proprietary platform and all of its components must be procured and implemented as a complete package we call the Extormity BundleTM (which describes both our comprehensive package and its associated cost).

Operating the Extormity Bundle requires a phalanx of servers, which of course need to be replicated for redundancy. Fortunately, Extormity acts as a value-added reseller of these servers, which we pre-load with operating software. This allows us to mark-up the cost of the servers and charge for server configuration. In addition, the server software carries with it steep annual license fees.

Let's hope the ONC's ongoing regulatory process can help reduce the risk of Extormity-style raw deals for doctors. Given the recent flap over the FDA's effective imprimatur for an extreme drug price increase, no DC agency should set in motion a process that could lead to prohibitively expensive fees for an essential aspect of health care. [FP]

March 17, 2011 | Permalink | Comments (0) | TrackBack (0)

Wednesday, March 16, 2011

Patrick McKinley Brennan: "The Individual Mandate, Sovereignty, and the Ends of Good Government: A Reply to Professor Randy Barnett"

Patrick McKinley Brennan, Professor of Law at Villanova University School of Law, posted "The Individual Mandate, Sovereignty, and the Ends of Good Government: A Reply to Professor Randy Barnett" on SSRN:

Brennan Randy Barnett has recently argued that the individual mandate is unconstitutional because it is an improper regulation under the Necessary and Proper Clause (in conjunction with the Commerce Clause) because it improperly "commandeers" the people and thereby violates their sovereignty. In this paper, I counter that the argument from sovereignty is unavailing because it is, among other defects, hopelessly ambiguous. The variety of historically attested meanings of "sovereignty" renders the concept useless for purposes of answering questions of comparative authority, including the authority of the Congress to mandate that individuals purchase health insurance from a private market. There is no analytical help to be had from following the Supreme Court's lead and imputing "sovereignty" to the nation state, each of the fifty states, the people, the people of each state, tribes, and each individual. Sovereignty purports to be a scalar quantity, but such a quantity cannot be univocally predicated of these many different kinds of things. There is a better way forward. When the libertarian element in contemporary "conservatism" is judged against a traditional account of natural law and of the natural and positive-law rights it generates, there is room to ask whether the individual mandate is (1) within our particular government's scope and (2) good, in fact, for the people for whom the government exists. The paper argues that, in addition to being hopelessly ambiguous, claims to sovereignty are false.

March 16, 2011 | Permalink | Comments (0) | TrackBack (0)

Paul M. Secunda: "The Forgotten Employee Benefit Crisis: Multiemployer Plans on the Brink"

Paul M. Secunda, Associate Professor at Marquette University Law School, posted "The Forgotten Employee Benefit Crisis: Multiemployer Plans on the Brink" on SSRN:

PaulSecunda This article provides a first time look at the numerous challenges facing multiemployer or Taft-Hartley benefit plans in the post-global recession and health care reform world. These plans have provided pension, health, and welfare benefits to union members of smaller employers in itinerant industries for over sixty years and even today, these plans collectively have over ten million participants in over 1500 plans.

Multiemployer plans are increasingly mired in financial trouble and are finding it more difficult to continue to provide adequate retirement and health benefits to their members. Although they once represented one of the great triumphs in American labor relations, these plans are now becoming just another part of the growing employee benefits crisis confronting the United States.

The purpose of this article is to consider, and respond to, the various financial, healthcare, and judicial challenges that threaten the on-going viability of these plans. By addressing these challenges in a systematic manner, this article seeks to provide a more sustainable path forward so that multiemployer benefit plans can continue to provide crucial employee benefits to the next generation of union workers.

March 16, 2011 | Permalink | Comments (0) | TrackBack (0)

William M. Sage: "Brand New Law! The Need to Market Health Care Reform"

William M. Sage, Vice Provost and Professor at the University of Texas at Austin School of Law, posted "Brand New Law! The Need to Market Health Care Reform" on SSRN:

Sage_william_color The most serious problem with the Patient Protection and Affordable Care Act (ACA) is not its contents but its packaging. Because it requires significant departures from business as usual in health insurance, health care delivery, and health behavior, the ACA is unlikely to succeed unless Americans feel a shared stake in its success. Unfortunately, the new law has been branded only by its opponents. Neither the Obama administration nor its congressional allies have effectively communicated the law’s key elements to the public. Most surprisingly, the groundbreaking program of near-universal health coverage the ACA creates does not even have a name. This essay explores the process of branding major American social legislation such as the ACA, and suggests a strategy for improving public understanding and building loyalty. Legal brand equity, like its commercial counterpart, implies a functional, emotional, and expressive relationship between the law and its intended beneficiaries. Accordingly, an effective marketing strategy for the ACA means creating consistent expectations regarding the law’s goals and performance, and ensuring that those expectations are met.

March 16, 2011 | Permalink | Comments (0) | TrackBack (0)

Tuesday, March 15, 2011

Amy D. Ronner: "When Courts Let Insane Delusions Pass the Rational Basis Test: The Newest Challenge to Florida's Exclusion of Homosexuals from Adoption"

Amy D. Ronner, Professor of Law at St. Thomas University School of Law, has posted her article entitled "When Courts Let Insane Delusions Pass the Rational Basis Test: The Newest Challenge to Florida's Exclusion of Homosexuals from Adoption" on SSRN:

Amyronner Florida was the only state to categorically exclude homosexuals from adopting children. Recently, a gay prospective father, Frank Martin Gill, successfully challenged the constitutionality of that homophobic statutory provision. The State of Florida appealed and The Third District Court of Appeal, affirming Judge Cindy S. Lederman, concluded that Florida’s statute violated Gill’s equal protection rights. See Fla. Dep’t of Children & Families v. In re Matter of Adoption of X.X.G. and N.R.G., 35 Fla. L. Weekly D2107 (Sept. 22, 2010).

This article, one of the first to address this high profile decision, looks at the constitutional issue in a new way. It yokes together what might seem to be two distinct areas of the law: the doctrine of insane delusion under wills and trusts’ law and rational basis review in constitutional law. Its narrow thesis is that the statutory exclusion of homosexuals from adoption is based on an insane delusion and that any court upholding it under the rational basis test is itself insanely deluded. On a broader level, however, this article explores the damage that results when courts use the rational basis test to uphold legislation which is premised on an irrational belief that is refuted by ample evidence to the contrary.

March 15, 2011 | Permalink | Comments (0) | TrackBack (0)

Monday, March 14, 2011

Alberto Alemanno & Enrico Bonadio: "Do You Mind My Smoking? Plain Packaging of Cigarettes Under the WTO TRIPS Agreement"

Alberto Alemanno and Enrico Bonadio posted "Do You Mind My Smoking? Plain Packaging of Cigarettes Under the WTO TRIPS Agreement" on SSRN:
 
Plain packaging, a new tobacco control tool that is currently being considered by a growing number of countries, mandates the removal of all attractive and promotional aspects of tobacco product packages. As a result, the only authorized feature remaining would be the use of brand name, which would be displayed in a standard font, size, color and location on the package. In opposing this new strategy, the tobacco industry is particularly keen in emphasizing both the ineffectiveness of plain packaging in reducing smoking rates and its incompatibility with international trademark-related provisions. In particular, the tobacco industry as well as other regulated sectors, such as food, alcohol, and cosmetics, believe that plain packaging jeopardizes their trademark rights and particularly contravenes several trademark-related provisions as enshrined in the TRIPS Agreement and the Paris Convention for the Protection of Industrial Property. This article, after introducing the reader to the genesis and rationale of plain packaging within the broader context of the WHO Framework Convention on Tobacco Control, offers a detailed analysis of the compatibility of this new packaging measure with the international system for trade mark protection as enshrined in the TRIPS.
[KVT] 

March 14, 2011 | Permalink | Comments (0) | TrackBack (0)

Lucy Budd, Morag Bell & Adam Warren: "Global Health Governance in the UK: Airport Regulation and the Mobile Body"

Lucy Budd, Morag Bell, and Adam Warren have posted "Global Health Governance in the UK: Airport Regulation and the Mobile Body" on SSRN:
 
This paper contributes to ongoing debates surrounding the governance and security of global mobility regimes through a theoretical and empirical examination of the extent to which air transport liberalisation and contemporary practices of infectious disease governance demand a re-conceptualisation of national borders. Recent outbreaks of SARS and H1N1 influenza, which spread rapidly around the world via air travel, illustrated the ability of pathogens to disrupt patterns and practices of human mobility and directly led to the introduction of new health screening technologies at airports that were designed to restrict the spread of infection and maintain a sanitary border. Yet while medical specialists have debated the effectiveness of the various screening techniques, and privacy campaigners have expressed concern over some of the technologies that have been deployed in an attempt to intercept these disease threats, there has been no exploration of the extent to which recent regulatory and structural changes within the global aviation industry have exacerbated the challenges of safeguarding public health and simultaneously transformed practices and spatialities of sanitary border control by re-siting national borders within a range of offshore and domestic locations. Drawing on official airport passenger statistics from the UK, this paper contends that, in transforming the spatialities of contemporary patterns of aeromobility, the progressive liberalisation of the commercial aviation sector (and the dramatic rise in passenger numbers, flights and airports handling international services it effected) – has had unintended and hitherto unexplored consequences for the governance of infectious disease mobility and the material deployment of sovereign sanitary territoriality by creating more points through which an infectious disease may enter or leave a country and moving the border inside UK regions.
[KVT]

March 14, 2011 | Permalink | Comments (0) | TrackBack (0)

Book Review: After We Die: The Life and Times of the Human Cadaver, by Norman Cantor

CERMINARAK Kathy Cerminara from Nova Southeastern University’s Shepard Broad Law Center recently posted a book review on SSRN that could interest many of the people reading this blog.  The review discusses and recommends a highly readable, humorous, and yet thought-provoking book about the status custom and law have accorded to cadavers.  Yes, I said “humorous.”  Norman Cantor, professor emeritus of law at Rutgers – Newark, has combined history, cultural references, law and ethics into an entertaining book about dead bodies. You can read the review here. [KVT] 

 

March 14, 2011 | Permalink | Comments (0) | TrackBack (0)

Upcoming Action in Health Care Law

With federal district courts disagreeing on the constitutionality of the individual mandate to purchase health care coverage, appellate review will be closely watched. On May 10th, the U.S. Court of Appeals for the Fourth Circuit will hear oral arguments in the two cases that have come out differently in Virginia.  For more details, see SCOTUSblog.  The 6th Circuit will hear oral argument in the Michigan case between May 30 and June 10.

The U.S. Department of Health & Human Services plans to unveil  soon its eagerly anticipated rules for accountable care organizations (ACOs).  To many health care experts, ACOs provide an important path to the goal of higher-quality, lower-cost health care.  Critics wonder whether ACOs can succeed where HMOs have failed, and whether ACOs will use their market power to maintain high health care prices. [DO]

March 14, 2011 | Permalink | Comments (0) | TrackBack (0)

Sunday, March 13, 2011

Ian Brown, Lindsey Brown & Douwe Korff: "Using NHS Patient Data for Research Without Consent"

Ian Brown, Lindsey Brown & Douwe Korff posted "Using NHS Patient Data for Research Without Consent" on SSRN

This article analyses the legality of the use of electronic patient records in the NHS for research without explicit patient consent under UK and EU law, with particular reference to the adequacy of the information provided to patients and the increasing difficulties of achieving de-identification. In section II, we describe the main NHS databases used for medical research purposes in England and the transparency of this use, and the general problem of re-identification. In section III, we examine the English common law position of confidentiality in relation to the use of medical records for research. Section IV sets out the European data protection standards on such use of that data. In section V, we summarise our findings and assessments and set out our conclusions and recommendations.

[KVT]

March 13, 2011 | Permalink | Comments (0) | TrackBack (0)

William P. Warburton, Rebecca Warburton, Arthur Sweetman & Clyde Hertzman: "The Impact of Placing Adolescent Males into Foster Care on Their Education, Income Assistance and Incarcerations"

William P. Warburton, Rebecca Warburton, Arthur Sweetman & Clyde Hertzman posted "The Impact of Placing Adolescent Males into Foster Care on Their Education, Income Assistance and Incarcerations" on SSRN:

Understanding the causal impacts of taking youth on the margins of risk into foster care is an element of the evidence-base on which policy development for this crucial function of government relies. Yet, there is little research looking at these causal impacts; neither is there much empirical work looking at long-term outcomes. This paper focuses on estimating the impact of placing 16 to 18 year old male youth into care on their rates of high school graduation, and post-majority income assistance receipt and incarceration. Two distinct sources of exogenous variation are used to generate instrumental variables, the estimates from which are interpreted in a heterogeneous treatment effects framework as local average treatment effects (LATEs). And, indeed, each source of exogenous variation is observed to estimate different parameters. While both instruments are in accord in that placement in foster care reduces (or delays) high school graduation, the impact of taking youth into care on income assistance use has dramatically different magnitudes across the two margins explored, and, perhaps surprisingly, one source of exogenous variation causes an increase, and the other a decrease, in the likelihood of the youth being incarcerated by age 20. Our results suggest that it is not enough to ask whether more or fewer children should be taken into care; rather, which children are, and how they are, taken into care matter for long-term outcomes.

[KVT]

March 13, 2011 | Permalink | Comments (0) | TrackBack (0)

Lynn A. Karoly: "Toward Standardization of Benefit-Cost Analyses of Early Childhood Interventions"

Lynn A. Karoly, Director of Office of Research Quality Assurance, posted "Toward Standardization of Benefit-Cost Analyses of Early Childhood Interventions" on SSRN:

Karoly_lynn_a A growing body of benefit-cost analyses (BCAs) of early childhood programs has been prompted by the increased demand for results-based accountability when allocating public and private sector resources. While the BCAs of early childhood programs serve to make such investments more compelling, there are limitations in the current state of the art, including a lack of standardization in the BCA methods used, from discount rates to shadow prices. The objective of this paper is to delineate a set of standards for conducting BCAs of early childhood programs. The paper reviews the existing evidence of the economic returns from early childhood programs that serve children and families in the first five years of life, discusses the challenges that arise in applying the BCA methodology such programs, highlights the variation in current methods used, and proposes a set of standards for applying the BCA methodology to early childhood programs. The recommendations concern issues such as the discount rate to use and the age to which costs and benefits should be discounted; stakeholder disaggregation; outcomes to value, the associated values, and projections of future outcomes; accounting for uncertainty; sensitivity analysis; and reporting of results. The proposed standards can guide the choices that analysts need to make about the methods to use when performing BCAs for one or more early childhood programs and they can support greater transparency in the results the analysts provide. The standards can also support consumers of the BCA results in their need to understand the methods employed and the comparability across different studies.

[KVT]

March 13, 2011 | Permalink | Comments (0) | TrackBack (0)