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Archive for March, 2011

New From the GAO

March 31, 2011 Comments off

New GAO Reports, Correspondence and Testimonies (PDFs)
Source: Government Accountability Office
31 March 2011

Reports

1. State and Local Governments: Knowledge of Past Recessions Can Inform Future Federal Fiscal Assistance. GAO-11-401, March 31.  Highlights

2. Medicaid: Improving Responsiveness of Federal Assistance to States during Economic Downturns. GAO-11-395, March 31.  Highlights

3. 2011 Tax Filing: IRS Dealt with Challenges to Date but Needs Additional Authority to Verify Compliance. GAO-11-481, March 29.

4. Tax Preparer Regulation: IRS Needs a Documented Framework to Achieve Goal of Improving Taxpayer Compliance. GAO-11-336, March 31.  Highlights

5. Refugee Assistance: Little Is Known about the Effectiveness of Different Approaches for Improving Refugees’ Employment Outcomes. GAO-11-369, March 31.  Highlights

Correspondence

1. Federal Reserve Banks: Areas for Improvement in Information Systems Controls. GAO-11-447R, March 31.

Testimonies

1. H-1B Visa Program: Multifaceted Challenges Warrant Re-examination of Key Provisions, statement for the record by Andrew Sherrill, director, education, workforce, and income security, before the Subcommittee on Immigration Policy and Enforcement, House Committee on the Judiciary. GAO-11-505T, March 31.

2. Border Security: DHS Progress and Challenges in Securing the U.S. Southwest and Northern Borders, by Richard M. Stana, director, homeland security and justice issues, before the Senate Committee on Homeland Security and Governmental Affairs. GAO-11-508T, March 30.  Highlights

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Review of VBA’s Pension Management Centers

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Review of VBA’s Pension Management Centers (PDF)
Source: U.S. Department of Veterans Affairs, Office of Inspector General

We conducted this review to determine if the Veterans Benefits Administration’s (VBA) Pension Management Centers (PMCs) ensure that pensioners receive timely benefit payments. We also assessed the implementation of prior recommendations from OIG’s FY 2007 audit of VBA’s Pension Maintenance Program. PMCs assumed processing responsibilities for live and death pension applications and Dependency and Indemnity Compensation in FY 2008 and 2009, respectively. This change increased the claims processing workload significantly at the PMCs. We found VBA did not process original death pension claim benefits timely because PMCs were not adequately prepared to process additional claims added to their workload from VA Regional Offices in FYs 2008 and 2009. In addition, VBA did not process Internal Revenue Service and Social Security Administration Income Verification Matches (IVM) timely, which resulted in overpayments. Lastly, VBA’s PMC performance measures in the Performance and Accountability Report do not adequately measure all the work processed. VBA has taken sufficient measures to address prior OIG recommendations. We identified an opportunity for VBA to ensure IVM actions are processed timely that can potentially save $205 million in overpayments. We recommended establishment of an operational plan to ensure PMCs efficiently and effectively manage the workload. VBA also needs to establish timeliness performance standards for completing Income Verification Matches to reduce overpayments, and to modify the Performance and Accountability Report performance measures to reflect the current workload and ensure transparency over actual performance. The Acting Under Secretary for Benefits agreed with our report findings and recommendations and plans to complete all corrective actions by November 30, 2011.

Report to nation finds continued declines in many cancer rates; special feature highlights changes in brain tumor rates and survival

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Report to nation finds continued declines in many cancer rates; special feature highlights changes in brain tumor rates and survival
Source: National Cancer Institute

Rates of death in the United States from all cancers for men and women continued to decline between 2003 and 2007, the most recent reporting period available, according to the latest Annual Report to the Nation on the Status of Cancer. The report also finds that the overall rate of new cancer diagnoses for men and women combined decreased an average of slightly less than 1 percent per year for the same period.

A graph with two lines, one in blue showing lung cancer death rates peaking for men in the 1980s and another in red showing lung cancer death rates for women just starting to decline in 2007The drop in cancer death rates continues a trend that began in the early 1990s. The report finds, for the first time, lung cancer death rates decreased in women, more than a decade after rates began dropping in men.

The report is co-authored by researchers from the North American Association of Central Cancer Registries (NAACCR), the National Cancer Institute (NCI), part of the National Institutes of Health, the Centers for Disease Control and Prevention, and the American Cancer Society. It appeared online March 31, 2011, in the Journal of the National Cancer Institute, and in print on May 4, 2011.

Of special note, childhood cancer incidence rates (rates of new diagnoses) continued to increase while death rates in this age group decreased. Childhood cancer is classified as cancers occurring in those 19 years of age or younger.

Overall cancer incidence rates in men were essentially unchanged. There was a very small uptick in prostate cancer rates, and if these rates were excluded from the analysis, there would be a continued decline in overall male incidence rates.

In the Special Feature section of the report, the authors explore the diversity of brain tumors and other nervous system cancers beyond those that are identified as malignant, including those that are borderline and benign. The researchers analyzed data between 2004 and 2007 and found that in adults, non-malignant tumors were about twice as common as malignant tumors.

+ Full Report (PDF)
+ Annual Report to the Nation on the Status of Cancer, 1975-2007, Featuring Trends in Brain Cancer: Questions and Answers

Guide for Implementing or Enhancing an Endangered Missing Advisory

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Guide for Implementing or Enhancing an Endangered Missing Advisory (PDF)
Source: Office of Juvenile Justice and Delinquency Prevention (DoJ)

The unauthorized absence of a child from the home is a family crisis that requires immediate and collaborative attention. Over the past two decades the AMBER Alert Program has grown into a nationally coordinated effort under the Office of Justice Programs, which has significantly improved the strategies and the methods for recovering endangered and abducted children. More than 500 children have been returned home as a result of AMBER Alert plans, which have been established in every state.

Despite such progress, however, gaps remain in the recovery of missing children whose cases do not meet the strict criteria for AMBER Alert and of missing adults, whose cases are not covered by AMBER Alert. To assist communities in closing these gaps, the Office of Juvenile Justice and Delinquency Prevention has initiated a project to help states, communities, and law enforcement agencies develop a strategy in which the Endangered Missing Advisory (EMA) plays a crucial role.

This guide provides AMBER Alert coordinators, law enforcement, and public safety professionals with an effective and efficient way to implement an EMA plan. It offers recommendations to assist law enforcement in developing strategies to recover missing children and adults and includes relevant findings to inform policymakers’ efforts to address the problem.

Workplace Violence 1993-2009

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Workplace Violence 1993-2009
Source: Bureau of Justice Statistics

Presents information on violence in the workplace against employed persons based on the Bureau of Justice Statistics’ National Crime Victimization Survey and the Bureau of Labor Statistics’ Census of Fatal Occupational Injuries. This report includes both nonfatal and fatal forms of violence. Comparisons are made with violence against unemployed persons and violence against employed persons outside of the workplace. Information on type of workplace violence is included. Also discussed is violence by occupation as well as information on victim and crime characteristics such as gender and race distribution, offender weapon use, police notification, and victim injury.

Highlights include the following:

  • From 2002 to 2009, the rate of nonfatal workplace violence has declined by 35%, following a 62% decline in the rate from 1993 to 2002.
  • Between 2005 and 2009, law enforcement officers, security guards, and bartenders had the highest rates of nonfatal workplace violence.
  • Among workplace homicides that occurred between 2005 and 2009, about 28% involved victims in sales and related occupations and about 17% involved victims in protective service occupations.

+ Full Report (PDF)

Federal Agencies Address Legal Issues Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program

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Federal Agencies Address Legal Issues Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program
Source: U.S. Department of Health and Human Services, Office of Inspector General
From e-mail:

Today, as part of a cross-agency, coordinated effort, several Federal
agencies issued documents addressing legal issues regarding Accountable
Care Organizations participating in the Medicare Shared Savings Program
(Shared Savings Program).

The Centers for Medicare & Medicaid Services (CMS) issued a proposed
rule that would establish accountable care organizations (ACO) under the
Shared Savings Program. The CMS proposed rule is available online at
http://www.cms.gov/sharedsavingsprogram

CMS and HHS Office of Inspector General (OIG) jointly issued a notice
with comment period outlining proposals for waivers of certain Federal
laws-the physician self-referral law, the anti-kickback statute, and
certain provisions of the civil monetary penalty law-in connection with
the Shared Savings Program. CMS and OIG are also asking for comments on
further waiver design considerations for the Shared Savings Program and
for the separate waiver authority for the Center for Medicare and
Medicaid Innovation under section 1115A of the Social Security Act. The
joint notice with comment period is available online at
http://www.ofr.gov/inspection.aspx?AspxAutoDetectCookieSupport=1

The Federal Trade Commission and the Department of Justice jointly
issued a “Proposed Statement of Enforcement Policy Regarding Accountable
Care Organizations Participating in the Medicare Shared Savings Program”
(Antitrust Policy Statement). The Antitrust Policy Statement is
available online at: http://www.ftc.gov/opp/aco/

And the Internal Revenue Service (IRS) issued a notice requesting
comments regarding the need for guidance on participation by tax-exempt
organizations in the Shared Savings Program through ACOs. The IRS notice
is available online at
http://www.irs.gov/newsroom/article/0,,id=222814,00.html

CBO’s Analysis of the Major Health Care Legislation Enacted in March 2010 (Testimony)

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CBO’s Analysis of the Major Health Care Legislation Enacted in March 2010 (PDF)
Source: Congressional Budget Office
From CBO Director’s Blog:

Effects of the Legislation on Insurance Coverage and on the Federal Budget

  • Number of People with Insurance Coverage: We estimate that the legislation will increase the number of nonelderly Americans with health insurance by roughly 34 million in 2021. About 95 percent of legal nonelderly residents will have insurance coverage in that year, compared with a projected share of 82 percent in the absence of that legislation and 83 percent currently. The legislation will generate this increase through a combination of a mandate for nearly all legal residents to obtain health insurance; the creation of insurance exchanges through which certain people will receive federal subsidies; and a significant expansion of Medicaid.
  • Costs of Expanded Insurance Coverage: According to our latest estimate, the provisions of the laws related to health insurance coverage will have a net cost to the Treasury from changes in direct spending and revenues of $1.1 trillion during the 2012-2021 decade. (Direct spending is that which is not controlled by annual appropriation acts.) That amount is larger than CBO’s original estimate of the cost of those provisions during the 2010-2019 decade that represented the 10-year budget window when the original estimate was produced. The increase owes almost entirely to the shift in the budget window; as you can see in the figure below, the revisions in any single year are quite small. Over the eight-year period (2012-2019) that is common to our original analysis and the most recent one, the net cost of the coverage provisions is now 2 percent higher than CBO and JCT estimated in March 2010.

Comparison of CBO’s 2010 and 2011 Estimates for PPACA and the Health Care Provisions of the Reconciliation Act

(Billions of dollars, by fiscal year)

Review of CBO’s Cost Estimate for the Dodd-Frank Wall Street Reform and Consumer Protection Act (Testimony)

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Review of CBO’s Cost Estimate for the Dodd-Frank Wall Street Reform and Consumer Protection Act (PDF)
Source: Congressional Budget Office
From CBO Director’s Blog:

What Did the Legislation Do?

The Dodd-Frank Act made significant changes to the regulatory environment for banking and thrift institutions as well as for financial markets and their participants. The act expanded existing regulatory powers, granted new regulatory powers, and reallocated regulatory authority among several federal agencies—with the aim of reducing the likelihood and severity of future financial crises. The act also established new agencies and programs and provided grants to help communities address high foreclosure rates and subsidies to assist homeowners facing foreclosure.

The Budget Effects in Brief

The figure below summarizes CBO’s estimate of the budgetary effects of the legislation during the 2010-2020 period. CBO estimated that the act would increase both direct spending and revenues between 2010 and 2020, reducing deficits, on net, by $3.2 billion. (Direct spending is that which is not governed by appropriation acts.) In addition, CBO estimates that the Dodd-Frank Act will lead to an increase of $2.6 billion in discretionary spending over the five-year period ending in fiscal year 2015 (and additional sums in subsequent years), assuming that lawmakers provide the necessary appropriations in the future.

Certain provisions of the act were estimated to increase direct—or mandatory—spending by $37.8 billion over that period. Most of those costs, $26.3 billion, would result from a new program created to resolve insolvent or soon-to-be insolvent financial entities, which would be financed through an Orderly Liquidation Fund, or OLF. Other provisions would increase spending by an additional $11.5 billion, we expected. At the same time, different provisions of the act were estimated to reduce direct spending by $27.6 billion during the coming decade. The biggest share of those savings, $16.6 billion, would result from changes to federal deposit insurance programs. The remainder of the savings, $11.0 billion, would arise from a decrease in authority for the Troubled Asset Relief Program, or TARP.

CBO’s Estimate of the Effects on Direct Spending and Revenues of the Dodd-Frank Wall Street Reform and Consumer Protection Act Over the 2010–2020 Period

Speech — FCC Chairman — “The Cloud: Unleashing Global Opportunities”

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“The Cloud: Unleashing Global Opportunities” (PDF)
Source: Federal Communications Commission (Chairman Julius Genachowski)

The advent of cloud computing, with its ability to enable collaboration in ways no other technology has before, can multiply the benefits of a free and open Internet.

Consider that in the United States, the number of ads for full-time IT jobs focused on cloud computing grew more than 300 percent last year.

And the benefits of cloud computing and a widely available Internet extend as well to health care, education, and energy – improving quality of life, while also generating new markets and new businesses in each of those categories.

This can be true all over the world. Cloud computing is already a $68 billion global industry, and worldwide cloud adoption is expanding at roughly 17 percent per year, according to Gartner. European companies like Flexiant and Mvine in the U.K. and GreenQloud in Iceland are offering innovative cloud computing solutions.

The opportunities and benefits of cloud computing are not limited by geography. Nor are the challenges to unleashing its opportunities.

Who Watches What (and How Much)? U.S. TV Trends by Ethnicity

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Who Watches What (and How Much)? U.S. TV Trends by Ethnicity
Source: Nielsen

How and what Americans watch on TV varies to some degree based on their ethnicity according to a Nielsen report of TV viewing and usage trends in 2010.

In November 2010, African-Americans used their TVs an average of 7 hours 12 minutes each day–far above the total U.S. average of 5 hours 11 minutes. Asians used their TVs the least, just 3 hours and 14 minutes on average. African-Americans also used DVD players and video game consoles more than average.

nielsen-ethnic-tv-report

+ Full Report (Free registration required.)

Americans Want More Coverage of Teacher Performance and Student Achievement

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Americans Want More Coverage of Teacher Performance and Student Achievement
Source: Brookings Institution

Americans want more media coverage of their local schools. In particular, they want more information than they now receive about teacher performance, student academic achievement, crime, and violence in their schools – and more as well about curricula, finances and reform efforts. While there is a great interest in receiving this information through new technological sources more so than ever before (http://pewresearch.org/pubs/1924/state-of-the-news-media-2011), Americans however, continue to rely on traditional media, particularly newspapers, for information on their schools. There is an imperative to improve both education journalism and the ways in which schools communicate directly to parents, students, and citizens.

In an earlier report (West, Whitehurst, and Dionne, 2009), we noted several problems with the way the media system reports on education, the most basic being that there little national coverage of education. During 2009, only 1.4 percent of national news coverage from television, newspapers, news Web sites, and radio dealt with education. In our content analysis, we found this paucity of coverage was not unique to 2009. In 2008, only 0.7 percent of national news coverage involved education, while 1.0 percent did so in 2007.

Of the education news that is reported, little relates to school policies and ways to improve the curriculum or learning processes. There was hardly any coverage of school reform, teacher quality, or other matters thought to be crucial for educational attainment. Instead, most 2009 stories focused on budget problems, school crime, and the H1N1 flu outbreak. The lack of news coverage of the actual work of schools represents a significant problem for the education area.

+ Full Report (PDF)

Urban world: Mapping the economic power of cities

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Urban world: Mapping the economic power of cities
Source: McKinsey & Company

The urban world is shifting. Today only 600 urban centers generate about 60 percent of global GDP. While 600 cities will continue to account for the same share of global GDP in 2025, this group of 600 will have a very different membership. Over the next 15 years, the center of gravity of the urban world will move south and, even more decisively, east.

Today, major urban areas in developed regions are, without doubt, economic giants. Half of global GDP in 2007 came from 380 cities in developed regions, with more than 20 percent of global GDP coming from 190 North American cities alone. The 220 largest cities in developing regions contributed another 10 percent.

But by 2025, one-third of these developed market cities will no longer make the top 600; and one out of every 20 cities in emerging markets is likely to see their rank drop out of the top 600. By 2025, 136 new cities are expected to enter the top 600, all of them from the developing world and overwhelmingly—100 new cities—from China.

To help companies looking for growth opportunities and policy makers to manage the increasing complexity of larger cities more effectively, MGI has built on its extensive research on the urbanization of China, India, and Latin America to develop Cityscope to develop a database of more than 2,000 metropolitan areas around the world, the largest of its kind.

Companies looking for cities that will generate the most GDP growth will find another different list of potential urban hot spots. The top 100 cities ranked by their contribution to global GDP growth in the next 15 years—we call this group the City 100—will contribute just over 35 percent of GDP growth to 2025. And the top 600—the City 600—will generate 60 percent of global GDP growth during this period.

Read the executive summary (PDF – 1.5 MB)
Read the full report (PDF – 3.50 MB)
Download eBook as ePub for Apple iPad, Barnes & Noble Nook, Sony Reader and other devices
Download eBook for Amazon Kindle

Country Analysis Brief: Venezuela

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Country Analysis Brief: Venezuela
Source: Energy Information Administration

Venezuela is one of the world’s largest exporters of crude oil and the largest in the Western Hemisphere. The oil sector is of central importance to the Venezuelan economy. As a founding member of the Organization of the Petroleum Exporting Countries (OPEC), Venezuela is an important player in the global oil market.
Map of Venezuela

Business Roundtable Releases First Quarter 2011 CEO Economic Outlook Survey

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Business Roundtable Releases First Quarter 2011 CEO Economic Outlook Survey
Source: Business Roundtable

The CEOs of America’s leading companies anticipate higher sales and plan to increase capital expenditures and employment over the next six months, according to the results of Business Roundtable’s first quarter 2011 CEO Economic Outlook Survey.

“With today’s survey results, the last three quarters have shown steady improvement in the CEO economic outlook. Our CEOs see momentum in the economy over the next six months, with increased demand fueling greater investment and job creation,” said Ivan G. Seidenberg, Chairman of Business Roundtable and Chairman and CEO of Verizon Communications. “This shift continues a trend as reflected in recent employment data, with the private sector leading the way in creating more jobs.”

See also: CEO Economic Outlook Survey Comparison of Results: 2010Q1– 2011Q1

Country Analysis Brief: Caribbean

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Country Analysis Brief: Caribbean
Source: Energy Information Administration

The islands of the Caribbean basin are predominantly net energy importers, with the exception of Trinidad and Tobago, which is a major exporter of liquefied natural gas (LNG). Venezuela provides a sizable amount of crude oil and refined products to its Caribbean neighbors at below-market prices and with favorable financing terms under the Petrocaribe initiative. Some islands, such as Aruba, Curacao, and the U.S. Virgin Islands, are important centers for oil refining and storage, due to their proximity to the U.S. market. In recent years, there has been concern that higher global oil prices will impair the Caribbean economies, as they are highly dependent upon oil for their energy needs. In response, the island nations have been discussing ways to promote alternative energy sources and better integrate their energy sectors.
Map of Caribbean Basin

China’s health reform push faces challenges at local government level

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China’s health reform push faces challenges at local government level
Source: World Bank

Health disparities remain significant between urban and rural areas, and among different localities and socio-economic groups in China, and more equitable allocation of government health resources is needed in order to fully achieve health reform objectives, according to a new report prepared jointly by staff of the World Bank and UNICEF. The report, entitled Equity and Public Governance in Health System Reform: Challenges and Opportunities for China, uses official data to analyze possible challenges to the implementation of China’s current health system overhaul.

According to the report, despite weaker health status in China’s poorer rural communities, per capita government allocations increasingly favour wealthier areas, and better quality health services are increasingly centralized in urban areas. The risk of financial catastrophe due to ill health remained much higher for rural residents, but was also increasing for urban residents when last surveyed in 2008. This risk is not being reduced by the new health insurance programs, which only provide a low level of benefit for members at this stage.

The report infers that one main objective of China’s health reforms, namely improving the accessibility and affordability of health care, will be difficult to achieve because of local reliance on national earmarked funding rather than adequate prioritization of basic services in provincial and sub-provincial government resource allocations. It suggests that the increasing disparity in public expenditure on social services, including health and education, requires better alignment of government priorities at provincial and sub-provincial levels with those developed at national level. Fully addressing the weaknesses identified may require complementary reforms to improve local governance and central-local fiscal relationships, the report concludes.

+ Full Report (PDF)

The Impact of Legislation on Credit Risk – Comparative Evidence From the United States, the United Kingdom and Germany

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The Impact of Legislation on Credit Risk – Comparative Evidence From the United States, the United Kingdom and Germany
Source: International Monetary Fund

This study investigates the link between bankruptcy and security legislation and potential credit losses faced by banks based on a cross-country study for the United States (US), the United Kingdom (UK) and Germany. Focusing on corporate credit, we find that legislation produces the highest credit risk in the US, followed by Germany, while UK law is found to be most favorable for banks. US banks gains from the higher number of informal restructurings (without losses) but lose from the low level of recovery in formal proceedings. German banks demand more credit risk mitigants than UK and US banks do, but still recover less than do UK banks. To be at par with UK banks, US banks would have to recover more than twice as much in formal proceedings, while German proceedings would have to be shortened by about one half.

+ Full Paper (PDF)

Sovereign Rating News and Financial Markets Spillovers: Evidence from the European Debt Crisis

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Sovereign Rating News and Financial Markets Spillovers: Evidence from the European Debt Crisis
Source: International Monetary Fund

This paper examines the spillover effects of sovereign rating news on European financial markets during the period 2007-2010. Our main finding is that sovereign rating downgrades have statistically and economically significant spillover effects both across countries and financial markets. The sign and magnitude of the spillover effects depend both on the type of announcements, the source country experiencing the downgrade and the rating agency from which the announcements originates. However, we also find evidence that downgrades to near speculative grade ratings for relatively large economies such as Greece have a systematic spillover effects across Euro zone countries. Rating-based triggers used in banking regulation, CDS contracts, and investment mandates may help explain these results.

+ Full Paper (PDF)

UK — Quality Governance in the NHS – A guide for provider board

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Quality Governance in the NHS – A guide for provider board
Source: National Health Service

The primary purpose of the NHS, and everyone working within it, is to provide a high quality service, free at the point of delivery to everyone who needs it. This common goal unites all those working in the NHS, from hospital doctors, to nurses, to GPs, to dentists, to allied health professionals, to clinical managers and non-clinical staff.

+ Full Document (PDF)

CRS — Middle East and North Africa Unrest: Implications for Oil and Natural Gas Markets

March 30, 2011 Comments off

Middle East and North Africa Unrest: Implications for Oil and Natural Gas Markets (PDF)
Source: Congressional Research Service (via Federation of American Scientists0

Political unrest in the Middle East and North Africa (MENA) has contributed to higher oil prices and added instability to energy markets. Supply disruptions and fears about the possible spread of unrest to major exporters have pushed prices higher. Even if the crisis abates, some risk premium may persist to the degree that market participants fear such an event could occur again.

Higher oil prices can negatively impact the economies of oil importing countries. The cost of oil is the primary determinant of gasoline prices and prices of other petroleum products; increased costs can be a burden on households and many businesses. Rising import costs for oil, natural gas and petroleum-based products can be a drag on economic growth by negatively affecting the trade balance. This may slow the current economic recovery, though it is not expected to derail it.

Many energy policy options to address vulnerability to disruptions and higher prices, such as what is taking place in MENA, are long-term in nature. It takes a long time for the energy sector to make material shifts, be they through renewables, efficiency, or increased domestic oil and gas production. Short-term energy policy options (as opposed to the broader national security and diplomatic issues) are limited. Oil exporters with spare production capacity, particularly Saudi Arabia, may make short-term decisions to try to moderate prices by adjusting production levels, but their ability and willingness to do so are often based on internal decisions. For more information on the political unrest in MENA, see the CRS Issue in Focus page on the Middle East and its associated reports.

Part of the U.S. energy policy debate around recent unrest has focused on whether it is appropriate to release oil from the Strategic Petroleum Reserve (SPR). The government holds the SPR to mitigate the impacts of a “severe energy supply interruption.” Proponents of using the SPR point out that there is a disruption to oil production in Libya and the resulting price increase negatively impacts the U.S. economic recovery. Critics question whether this is the appropriate time to release oil from the SPR or whether it should be saved to guard against larger future disruptions, and emphasize that the SPR has not traditionally been viewed as a device to manipulate prices.

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