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Comments in Response to the New York State Education Department’s Proposed Regulation: Substantially Equivalent Instruction for Nonpublic School Students
Re: I.D. No. EDU-27-19-00010-P: Substantially Equivalent Instruction for Nonpublic School StudentsIn NCLA’s view, the Department must withdraw the Substantial Equivalency Rule because it violates the New York State and United States Constitutions in at least two...
read moreComments in Response to the Department of Health and Human Services: Proposed Rule for Nondiscrimination in Health and Health Education Programs and Activities
Re: Nondiscrimination in Health and Health Education Programs or Activities, Docket No.: HHS-OCR-2019-0007According to the Executive Summary published in the Federal Register related to the Proposed Rule, “Section 1557 of the Patient Protection and Affordable Care Act...
read moreComments in Response to Alcohol and Tobacco Tax and Trade Bureau, Treasury: Modernization of the Labeling and advertising Regulations for Wine, Distilled Spirits, and Malt Beverages
Notice No. 176: Modernization of the Labeling and Advertising Regulations for Wine, Distilled Spirits, and Malt Beverage; Docket No. TTB-2018-0007While the Proposed Rule’s liberalization of Certificate of Label Approval (“COLA”) regulations reforms an overly...
read moreComments in Response to the U.S. Sentencing Commission: Proposed Amendment for Sentencing Guidelines
Sentencing Guidelines for the Court; Proposed Amendment 2018-27505 Amending § 4B1.2 NCLA applauds the Sentencing Commission’s desire to rectify serious issues pertaining to the Guidelines. NCLA does not take a position regarding the appropriate definition of the terms...
read moreComments in Response to the Department of Education’s Proposed Rule: Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance
Re: Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance, Docket Number ED-2018-OCR-0064 NCLA sincerely appreciates this opportunity to comment and express its concerns about the Proposed Rule. NCLA abhors...
read morePetition for Rulemaking: Promulgate Regulations Prohibiting the Issuance, Reliance On or Defense of Improper Agency Guidance
Re: Petition for Rulemaking to Promulgate Regulations Prohibiting the Issuance, Reliance on, or Defense of Improper Agency Guidance As the petition sets out in detail, NCLA asks DOT to cease its ad hoc promulgation of guidance by which DOT or the agencies under its...
read moreComments in Response to HHS, CMS: Regulation to Require Drug Pricing Transparency
Re: Medicare and Medicaid Programs; Regulation to Require Drug Pricing Transparency Proposed Rule CMS-4187-P The Drug Pricing Rule is fatally flawed in two principal ways. First, CMS lacks the statutory authority to regulate the subject matter of the proposed Rule,...
read morePetition to Amend: SEC Rule Imposing Speech Restraints in Consent Orders
In re SEC Rule Imposing Speech Restraints in Consent Orders The SEC Rule adopts “the policy that in any civil lawsuit brought by it or in any administrative proceeding of an accusatory nature pending before it, it is important to avoid creating, or permitting to be...
read moreComments in Response to the Bureau of Consumer Financial Protection: Request for Information Regarding Bureau Guidance and Implementation Support
Re: Request for Information Regarding Bureau Guidance and Implementation Support, Docket No. CFPB-2018-0013 NCLA sincerely appreciates this opportunity to provide commentary on the Bureau’s past use of guidance and its invitation for suggestions as to how it can...
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