Corporate Free Exercise of Religion and the Interpretation of Congressional Intent: Where Will It End?

Once known merely as an arts-and-crafts chain, Hobby Lobby now holds a special place in American legal lexicon as the personification of for-profit corporate religious exercise. This is the result of a decision by the United States Supreme Court last term in which the Court held that business practices compelled or limited by the religious beliefs of corporate owners deserve some measure of protection against interference by the federal government. The religious belief at issue in Burwell v. Hobby Lobby Stores, Inc., 134 S. Ct. 2751 (2014) is that life begins at conception; the business practice is group health insurance coverage for corporate employees and their families; the government interference is the Affordable Care Act which mandates that group health plans offer no-cost contraceptive coverage; and the source of protection against that mandate is the Religious Freedom Restoration Act of 1993. The Court’s holding is far-reaching, controversial, and, in the authors’ opinion, wrong. The ink was barely dry from the publication of the Hobby Lobby decision when the Court, three days later, handed a temporary victory to organizations exempt from the contraception mandate. Pending appellate review of the underlying case, the Court enjoined the federal government from enforcing a regulation requiring such organizations to certify its religious objections to the mandate on a government-issued form and to send a copy of the form to the third-party administrator of its health insurance plan. Wheaton College v. Burwell, 134 S. Ct. 2806 (2014). A second generation of litigation is now winding its way through the courts on whether exempt organizations—claiming religious scruples do not permit the “triggering” of contraceptive access—are required to notify the federal government of the contact information of their insurer or administrator. But how else, if not through federal government facilitation, one may ask, are women to obtain the full contraceptive coverage promised by Congress? This demand for an extension of a religious accommodation by anti-contraceptive believers should be rejected

Oak forest carbon and water simulations:Model intercomparisons and evaluations against independent data

Models represent our primary method for integration of small-scale, process-level phenomena into a comprehensive description of forest-stand or ecosystem function. They also represent a key method for testing hypotheses about the response of forest ecosystems to multiple changing environmental conditions. This paper describes the evaluation of 13 stand-level models varying in their spatial, mechanistic, and temporal complexity for their ability to capture intra- and interannual components of the water and carbon cycle for an upland, oak-dominated forest of eastern Tennessee. Comparisons between model simulations and observations were conducted for hourly, daily, and annual time steps. Data for the comparisons were obtained from a wide range of methods including: eddy covariance, sapflow, chamber-based soil respiration, biometric estimates of stand-level net primary production and growth, and soil water content by time or frequency domain reflectometry. Response surfaces of carbon and water flux as a function of environmental drivers, and a variety of goodness-of-fit statistics (bias, absolute bias, and model efficiency) were used to judge model performance. A single model did not consistently perform the best at all time steps or for all variables considered. Intermodel comparisons showed good agreement for water cycle fluxes, but considerable disagreement among models for predicted carbon fluxes. The mean of all model outputs, however, was nearly always the best fit to the observations. Not surprisingly, models missing key forest components or processes, such as roots or modeled soil water content, were unable to provide accurate predictions of ecosystem responses to short-term drought phenomenon. Nevertheless, an inability to correctly capture short-term physiological processes under drought was not necessarily an indicator of poor annual water and carbon budget simulations. This is possible because droughts in the subject ecosystem were of short duration and therefore had a small cumulative impact. Models using hourly time steps and detailed mechanistic processes, and having a realistic spatial representation of the forest ecosystem provided the best predictions of observed data. Predictive ability of all models deteriorated under drought conditions, suggesting that further work is needed to evaluate and improve ecosystem model performance under unusual conditions, such as drought, that are a common focus of environmental change discussions

Mental health in hospital emergency departments: cross-sectional analysis of attendances in England 2013/2014

Objective: To describe the population of patients who attend emergency departments (ED) in England for mental health reasons. / Methods: Cross-sectional observational study of 6 262 602 ED attendances at NHS (National Health Service) hospitals in England between 1 April 2013 and 31 March 2014. We assessed the proportion of attendances due to psychiatric conditions. We compared patient sociodemographic and attendance characteristics for mental health and non-mental health attendances using logistic regression. / Results: 4.2% of ED attendances were attributable to mental health conditions (median 3.2%, IQR 2.6% to 4.1%). Those attending for mental health reasons were typically younger (76.3% were aged less than 50 years), of White British ethnicity (73.2% White British), and resident in more deprived areas (59.9% from the two most deprived Index of Multiple Deprivation quintiles (4 and 5)). Mental health attendances were more likely to occur ‘out of hours’ (68.0%) and at the weekend (31.3%). Almost two-thirds were brought in by ambulance. A third required admission, but around a half were discharged home. / Conclusions: This is the first national study of mental health attendances at EDs in England. We provide information for those planning and providing care, to ensure that clinical resources meet the needs of this patient group, who comprise 4.2% of attendances. In particular, we highlight the need to strengthen the availability of hospital and community care ‘out of hours.

Weak charge form factor and radius of 208Pb through parity violation in electron scattering

We use distorted wave electron scattering calculations to extract the weak charge form factor F_W(q), the weak charge radius R_W, and the point neutron radius R_n, of 208Pb from the PREX parity violating asymmetry measurement. The form factor is the Fourier transform of the weak charge density at the average momentum transfer q=0.475 fm$^{-1}$. We find F_W(q) =0.204 \pm 0.028 (exp) \pm 0.001 (model). We use the Helm model to infer the weak radius from F_W(q). We find R_W= 5.826 \pm 0.181 (exp) \pm 0.027 (model) fm. Here the exp error includes PREX statistical and systematic errors, while the model error describes the uncertainty in R_W from uncertainties in the surface thickness \sigma of the weak charge density. The weak radius is larger than the charge radius, implying a "weak charge skin" where the surface region is relatively enriched in weak charges compared to (electromagnetic) charges. We extract the point neutron radius R_n=5.751 \pm 0.175 (exp) \pm 0.026 (model) \pm 0.005 (strange) fm$, from R_W. Here there is only a very small error (strange) from possible strange quark contributions. We find R_n to be slightly smaller than R_W because of the nucleon's size. Finally, we find a neutron skin thickness of R_n-R_p=0.302\pm 0.175 (exp) \pm 0.026 (model) \pm 0.005 (strange) fm, where R_p is the point proton radius.Comment: 5 pages, 1 figure, published in Phys Rev. C. Only one change in this version: we have added one author, also to metadat

Effect of Oral Iron Repletion on Exercise Capacity in Patients With Heart Failure With Reduced Ejection Fraction and Iron Deficiency: The IRONOUT HF Randomized Clinical Trial.

Importance: Iron deficiency is present in approximately 50% of patients with heart failure with reduced left ventricular ejection fraction (HFrEF) and is an independent predictor of reduced functional capacity and mortality. However, the efficacy of inexpensive readily available oral iron supplementation in heart failure is unknown. Objective: To test whether therapy with oral iron improves peak exercise capacity in patients with HFrEF and iron deficiency. Design, Setting, and Participants: Phase 2, double-blind, placebo-controlled randomized clinical trial of patients with HFrEF ( Interventions: Oral iron polysaccharide (n = 111) or placebo (n = 114), 150 mg twice daily for 16 weeks. Main Outcomes and Measures: The primary end point was a change in peak oxygen uptake (V̇o2) from baseline to 16 weeks. Secondary end points were change in 6-minute walk distance, plasma N-terminal pro-B-type natriuretic peptide (NT-proBNP) levels, and health status as assessed by Kansas City Cardiomyopathy Questionnaire (KCCQ, range 0-100, higher scores reflect better quality of life). Results: Among 225 randomized participants (median age, 63 years; 36% women) 203 completed the study. The median baseline peak V̇o2 was 1196 mL/min (interquartile range [IQR], 887-1448 mL/min) in the oral iron group and 1167 mL/min (IQR, 887-1449 mL/min) in the placebo group. The primary end point, change in peak V̇o2 at 16 weeks, did not significantly differ between the oral iron and placebo groups (+23 mL/min vs -2 mL/min; difference, 21 mL/min [95% CI, -34 to +76 mL/min]; P = .46). Similarly, at 16 weeks, there were no significant differences between treatment groups in changes in 6-minute walk distance (-13 m; 95% CI, -32 to 6 m), NT-proBNP levels (159; 95% CI, -280 to 599 pg/mL), or KCCQ score (1; 95% CI, -2.4 to 4.4), all P \u3e .05. Conclusions and Relevance: Among participants with HFrEF with iron deficiency, high-dose oral iron did not improve exercise capacity over 16 weeks. These results do not support use of oral iron supplementation in patients with HFrEF. Trial Registration: clinicaltrials.gov Identifier: NCT02188784

Personality preference influences medical student use of specific computer-aided instruction (CAI)

BACKGROUND: The objective of this study was to test the hypothesis that personality preference, which can be related to learning style, influences individual utilization of CAI applications developed specifically for the undergraduate medical curriculum. METHODS: Personality preferences of students were obtained using the Myers-Briggs Type Indicator (MBTI) test. CAI utilization for individual students was collected from entry logs for two different web-based applications (a discussion forum and a tutorial) used in the basic science course on human anatomy. Individual login data were sorted by personality preference and the data statistically analyzed by 2-way mixed ANOVA and correlation. RESULTS: There was a wide discrepancy in the level and pattern of student use of both CAI. Although individual use of both CAI was positively correlated irrespective of MBTI preference, students with a "Sensing" preference tended to use both CAI applications more than the "iNtuitives". Differences in the level of use of these CAI applications (i.e., higher use of discussion forum vs. a tutorial) were also found for the "Perceiving/Judging" dimension. CONCLUSION: We conclude that personality/learning preferences of individual students influence their use of CAI in the medical curriculum