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Approaches for Establishing Fraud Risk Assessment Programs and Conducting Fraud Audit Risk Assessments Within the Department of Defense

July 25, 2014 Comments off

Approaches for Establishing Fraud Risk Assessment Programs and Conducting Fraud Audit Risk Assessments Within the Department of Defense
Source: U.S. Department of Defense, Office of Inspector General

Objective
The objective of the review was to identify approaches for establishing fraud risk assessment programs and conducting fraud risk assessments within the DoD. The review focused on various DoD activities including procurement, retail, and financial operations.

What We Found
We identified numerous innovative approaches for conducting fraud risk assessments. Of the 33 DoD organizations we interviewed,* 13 were conducting entity-wide risk assessments, 26 were conducting fraud risk assessments when performing audit-related work, 23 were providing fraud awareness training, and 3 were concentrating on internal control evaluations.

DoD entities are encouraged to modify any of the described approaches to suit their specific mission, size, and fraud vulnerabilities. The approaches were developed through research and interviews with 100 subject matter experts representing DoD organizations, academic institutions, private companies, and nonprofit organizations.

Fraud risk assessment approaches developed by the Marine Corps Nonappropriated Funds Audit Service; Army and Air Force Exchange Service, Audit Division; and the Army Audit Agency are highlighted within this report. Additionally, entity-wide fraud risk assessment approaches developed by the DoD Investigative Organizations; Naval Exchange Service Command, Office of Internal Audit; and the Naval Sea Systems Command Office of the Inspector General are also discussed in detail. The report also contains information on auditor and entity-wide fraud risk assessment approaches developed by external DoD organizations.

We used documentation obtained from the subject matter experts to develop example documents included in the report Appendixes. Example documents include audit organization fraud risk assessment policies, financial statement audit fraud interview questionnaire, and an entity-wide fraud risk assessment report. The report also provides information on auditor fraud brainstorming and interviewing techniques and DoD fraud case study examples.

Management Comments and Our Response
We have incorporated draft report comments received from the Commander, Naval Sea Systems Command; Naval Audit Service; Defense Health Agency; Defense Information Systems Agency, Office of the Inspector General; Air Force Office of Special Investigations; and Board of Regents of the University System of Georgia. No further comments are required.

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CRS Insights — District of Columbia: Marijuana Decriminalization and Enforcement; Issues of Home Rule and Congressional Oversight

July 25, 2014 Comments off

CRS Insights — District of Columbia: Marijuana Decriminalization and Enforcement; Issues of Home Rule and Congressional Oversight (PDF)
Source: Congressional Research Service (via Federation of American Scientists)

Decriminalization of marijuana in the District is one of several issues that have engendered controversy and congressional intervention. Like the controversies surrounding the District’s medical marijuana initiative, needle exchange, and abortion services, the District’s marijuana decriminalization act pits the principle of home rule against Congress’s constitutional authority and prerogative to intervene in District affairs.

Supporters of the law point to the shift in public opinion surrounding the legalization of marijuana use; noting that the majority of the country favors legalization. They also note that the act is intended to address the racial disparities in marijuana arrest rates in the District. According to a committee report accompanying the legislation, blacks accounted for 90% of the marijuana arrests in the District despite evidence that they use marijuana at a rate comparable to use by whites. Supporters note that a single arrest for marijuana possession has a significant impact on future employment and career prospects.

Opponents of the law argue that enforcement will be problematic given the unique status of the District as the Nation’s Capital. On the one hand, possession of a small quantity of marijuana on non-federal lands would be reduced to a misdemeanor punishable by a small fine. On the other hand, possession of that same quantity of marijuana on federal lands, including the Mall, the National Zoo, and Rock Creek Park could be prosecuted, at the discretion of the Department of Justice, as a federal offense and subject the offender to six months in jail and up to a $5,000 fine, given that marijuana is defined as a Schedule I drug under the Controlled Substances Act (21 U.S.C. §811). The matter of enforcement is further complicated by the presence of 32 federal law enforcement agencies that provide assistance to the District’s Metropolitan Police Department (MPD) through cooperative agreements that expand the area of jurisdiction an agency’s law enforcement personnel may patrol with the power to arrest.

CRS — Unlawfully Present Aliens, Higher Education, In-State Tuition, and Financial Aid: Legal Analysis

July 25, 2014 Comments off

Unlawfully Present Aliens, Higher Education, In-State Tuition, and Financial Aid: Legal Analysis (PDF)
Source: Congressional Research Service (via Federation of American Scientists)

The existence of a sizable population of “DREAMers” in the United States has prompted questions about unlawfully present aliens’ eligibility for admission to public institutions of higher education, in-state tuition, and financial aid. The term DREAMer is widely used to describe aliens who were brought to the United States as children and raised here but lack legal immigration status. As children, DREAMers are entitled to public elementary and secondary education as a result of the Supreme Court’s 1982 decision in Plyler v. Doe. There, the Court struck down a Texas statute that prohibited the use of state funds to provide elementary and secondary education to children who were not “legally admitted” to the United States because the state distinguished between these children and other children without a “substantial” goal, in violation of the Equal Protection Clause of the Fourteenth Amendment to the U.S. Constitution.

Once DREAMers complete high school, however, they may have less access to public higher education. Plyler’s holding was limited to elementary and secondary education, and the Court’s focus on the young age of those whom Texas denied a “basic education” has generally been taken to mean that measures denying unlawfully present aliens access to higher education may be subject to less scrutiny than the Texas statute was. Thus, several states have adopted laws or practices barring the enrollment of unlawfully present aliens at public institutions of higher education. In addition, Congress has enacted two statutes that restrict unlawfully present aliens’ eligibility for “public benefits,” a term which has generally been construed to encompass in-state tuition and financial aid. The first of these statutes, the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA, P.L. 104-193) bars the provision of “state and local public benefits” to unlawfully present aliens unless the state enacts legislation that “affirmatively provides” for their eligibility. The second, the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA, P.L. 104-208) bars states from providing “postsecondary education benefits” to unlawfully present aliens based on their residence in the state unless all U.S. citizens or nationals are eligible for such benefits, regardless of their state of residence.

CRS — “Black Boxes” in Passenger Vehicles: Policy Issues

July 25, 2014 Comments off

“Black Boxes” in Passenger Vehicles: Policy Issues (PDF)
Source: Congressional Research Service (via Federation of American Scientists)

An event data recorder (EDR) is an electronic sensor installed in a motor vehicle that records certain technical information about a vehicle’s operational performance for a few seconds immediately prior to and during a crash. Although over 90% of all new cars and light trucks sold in the United States are equipped with them, the National Highway Traffic Safety Administration (NHTSA) is proposing that all new light vehicles have EDRs installed in the future. Under previously adopted NHTSA rules, these devices have to capture at least 15 types of information related to the vehicle’s performance in the few seconds just before and immediately after a crash serious enough to result in deployment of airbags.

EDRs have the potential to make a significant contribution to highway safety. For example, EDR data showed that in several cases a Chevrolet Cobalt’s ignition switch turned the engine off while the car was still moving, causing the car to lose power steering and crash; the data directly contributed to the manufacturer’s decision to recall 2.6 million vehicles. EDR data could also be used, sometimes in conjunction with other vehicle technologies, to record in the few seconds before an accident such data as driver steering input, seat occupant size and position, and sound within a car.

The privacy of information collected by EDRs is a matter of state law, except that federal law bars NHTSA from disclosing personally identifiable information. The privacy aspects of EDRs and the ownership of the data they generate has been the subject of legislation in Congress since at least 2004. The House passed a floor amendment to the transportation appropriations bill in 2012 that would have prohibited use of federal funds to develop an EDR mandate. This provision was not enacted. The Senate passed two EDR-related provisions in its surface transportation reauthorization bill (S. 1813) in 2012, mandating EDRs on new cars sold after 2015 and directing a Department of Transportation study of privacy issues. The provisions were not included in the final bill.

iDATA: Improving Defences Against Targeted Attack

July 24, 2014 Comments off

iDATA: Improving Defences Against Targeted Attack (PDF)
Source: Centre for the Protection of National Infrastructure (UK)

iDATA is a CPNI cyber research programme. The programme consists of a number of projects aimed at addressing threats posed by nation states and state-sponsored actors. iDATA has resulted in a number of outputs for the cyber security community. This document provides a description of the iDATA programme and a summary of the outputs.

State Laws and Legislation Related to Biologic Medications and Substitution of Biosimilars

July 24, 2014 Comments off

State Laws and Legislation Related to Biologic Medications and Substitution of Biosimilars
Source: National Conference of State Legislatures

For several decades, every state has regulated the use of brand-name and generic prescription drugs through statutes and agency or board rules. These state actions include when and how generics may be substituted for brand-name prescriptions, by pharmacists or others. Generic drugs typically have active ingredients that are identical to those of their brand-name counterpart. These traditional drugs include familiar pills used regularly by tens of millions of Americans as well as some specialty drugs.

Biologic medicines are much more complex than traditional chemically synthesized drugs. Biologics are manufactured from living organisms by programming cell lines to produce the desired therapeutic substances and consist of large molecules. Common biologics in use today include human growth hormone, injectable treatments for arthritis and psoriasis, the Hepatitis B vaccine and stem cell therapy.

Regulating biologics raises new issues for both state and federal policymakers. Because of their complexity, biologic drugs are much more difficult to replicate than the chemically produced generics for other drugs. The cell lines used and modifications in the manufacturing process affect biologic medicines. As a result, truly identical “generic” versions are currently virtually impossible to produce. However, once patents expire for the existing brand-name biologic drugs, “biosimilar” medicines can be produced, which is an occurrence that raises regulatory issues in the states.

Currently, there is concern that traditional statutes regulating “generic drugs” may be misapplied to new products that are not identical. This has led to a recent move to amend older state laws to address the medical and chemical characteristics of these “biologics,” as well as any future generic-style “follow-on biologics” or “biosimilars.”

In the past one and a half years at least 23 states have considered legislation establishing state standards for substitution of a “biosimilar” prescription product to replace an original biologic product.
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TIGTA — Fiscal Year 2014 Statutory Review of Disclosure of IRS Collection Activity With Respect to Joint Returns

July 24, 2014 Comments off

Fiscal Year 2014 Statutory Review of Disclosure of Collection Activity With Respect to Joint Returns
Source: Treasury Inspector General for Tax Administration

Highlights of Reference Number: 2014-30-046 to the Internal Revenue Service Commissioners for the Small Business/Self-Employed and Wage and Investment Divisions.

IMPACT ON TAXPAYERS
Internal Revenue Code (I.R.C.) Section (§) 6103(e)(8) gives joint filer taxpayers who are no longer married or no longer reside in the same household the right to request information regarding the IRS’s efforts to collect delinquent taxes on their joint tax return liabilities. If the IRS does not provide employees sufficient guidance for handling those requests, taxpayer rights could potentially be violated.

WHY TIGTA DID THE AUDIT
This audit was initiated because the IRS Restructuring and Reform Act of 1998 added I.R.C. § 7803(d)(1)(B), which requires TIGTA to annually review and certify the IRS’s compliance with I.R.C. § 6103(e)(8). The objective of this review was to determine whether the IRS is complying with the provisions of I.R.C. § 6103(e)(8) as related to the disclosure of collection activities with respect to joint filers.

WHAT TIGTA FOUND
IRS procedures provide employees with sufficient guidance for handling joint filer collection activity information requests. However, TIGTA could not determine whether the IRS fully complied with I.R.C. § 6103(e)(8) requirements when responding to written collection activity information requests from joint filers. IRS management information systems do not separately record or monitor joint filer requests, and there is no legal requirement for the IRS to do so. Further, TIGTA does not recommend the creation of a separate tracking system.

WHAT TIGTA RECOMMENDED
TIGTA made no recommendations in this report. IRS officials were provided an opportunity to review the draft report and did not provide any comments.

US: Terrorism Prosecutions Often An Illusion

July 24, 2014 Comments off

US: Terrorism Prosecutions Often An Illusion
Source: Human Rights Watch

The US Justice Department and the Federal Bureau of Investigation (FBI) have targeted American Muslims in abusive counterterrorism “sting operations” based on religious and ethnic identity, Human Rights Watch and Columbia Law School’s Human Rights Institute said in a report released today. Many of the more than 500 terrorism-related cases prosecuted in US federal courts since September 11, 2001, have alienated the very communities that can help prevent terrorist crimes.

The 214-page report, “Illusion of Justice: Human Rights Abuses in US Terrorism Prosecutions,” examines 27 federal terrorism cases from initiation of the investigations to sentencing and post-conviction conditions of confinement. It documents the significant human cost of certain counterterrorism practices, such as overly aggressive sting operations and unnecessarily restrictive conditions of confinement.

Family Law: A Beginner’s Guide – Part 2: Child Custody, Support, and Adoption

July 23, 2014 Comments off

Family Law: A Beginner’s Guide – Part 2: Child Custody, Support, and Adoption
Source: Law Library of Congress

In Part Two of our Family Law Beginner’s Guide, we are shifting our focus to what the law says about children’s roles in the family—focusing on their custody and care. Below, please find information and resources for legal researchers regarding child custody, child support, and domestic adoption.

Family Law: A Beginner’s Guide – Part 1: Formation and Dissolution of Marriage

July 23, 2014 Comments off

Family Law: A Beginner’s Guide – Part 1: Formation and Dissolution of Marriage
Source: Law Library of Congress

Whether it be in relation to marriage, the birth of children, adoption, or divorce, family law is one area of the law that affects nearly everyone. But even though family law is a part of daily life, legal issues in this area can quickly become complex. Below, we have collected a sampling of the marriage and divorce law resources available, both at the Law Library of Congress and on the free web, to help researchers get a better handle on these issues.

Upcoming Federal Court Decision Could Mean Premium Increases for Nearly 5 Million Americans

July 23, 2014 Comments off

Upcoming Federal Court Decision Could Mean Premium Increases for Nearly 5 Million Americans
Source: Avalere Health

A new analysis from Avalere Health finds that without action from the federal government nearly 5 million Americans would receive an average premium increase of 76 percent if the courts ultimately rule that consumers in the federal exchange cannot receive premium subsidies.

Halbig v. Burwell asserts that the Internal Revenue Service exceeded its authority in issuing a May 2012 rule that provides premium subsidies to individuals purchasing coverage through the federally facilitated exchange. While the ACA specifies that subsidies should be administered “through an exchange established by the state,” the law also gives the federal government the authority to establish an exchange on the state’s behalf. Only 16 states and the District of Columbia opted to create their own exchanges in time for the 2014 plan year.

“The court case has major implications for future insurance coverage and access to care for millions of Americans,” said Caroline Pearson, vice president at Avalere Health. “Depending on the ultimate decision by the courts and absent some other remedy, individuals in at least 25 states who remain in their current plans could see an average premium increase of over 70 percent.”

How the Health Insurance Portability and Accountability Act (HIPAA) and Other Privacy Laws Affect Public Transportation Operations

July 23, 2014 Comments off

How the Health Insurance Portability and Accountability Act (HIPAA) and Other Privacy Laws Affect Public Transportation Operations
Source: Transportation Research Board

TRB’s Transit Cooperative Research Program (TCRP) Legal Research Digest 46: How the Health Insurance Portability and Accountability Act (HIPAA) and Other Privacy Laws Affect Public Transportation Operations explores whether the privacy and security rules established by HIPAA apply to transit agencies that possess patrons’ health information.

The first seven sections of this digest discuss HIPAA and whether various entities are subject to HIPAA’s privacy and security provisions applicable to the protection of protected health information, as defined by HIPAA. This digest also analyzes how protected health information is defined by HIPAA and discusses HIPAA’s Privacy Rule and Security Rule as defined by the U.S. Department of Health and Human Services in its most recent final rule.

This digest summarizes other important aspects of HIPAA including whether protected health information must be produced in response to a subpoena, discovery request, or a request under a freedom of information act (FOIA) or similar law. The remainder of the digest discusses the privacy of health information under other federal and state laws. The digest also covers industry standards and best practices used by transit agencies to protect the privacy of patrons’ health information.

67 Law Enforcement Officer Fatalities Nationwide in First Half of 2014

July 22, 2014 Comments off

67 Law Enforcement Officer Fatalities Nationwide in First Half of 2014
Source: National Law Enforcement Officers Memorial Fund

Today the National Law Enforcement Officers Memorial Fund issued a new report stating that 67 officers have been killed in the line of duty during the first half of 2014—a 31 percent increase over the same period last year.

Of these 67 officers, 26 were killed in traffic-related incidents; 25 were killed by gunfire; and 16 died due to job-related illnesses and other causes.

Key Facts

  • Traffic-related incidents were once again the leading cause of officer fatalities, with 26 officers killed in the first half of 2014—a 37 percent increase over the same period last year.
  • Firearms-related fatalities spiked to 25 in the first half of this year—a 56 percent increase over the first six months of 2013. Investigating suspicious persons or situations was the leading circumstance of fatal shootings, with six officer fatalities; followed by ambushes, with five officer fatalities.
  • Sixteen officers died due to other causes in the first half of 2014, the same as the number reported during the same time last year. Job-related illnesses, such as heart attacks, increased 62 percent in the first half of 2014, with 13 officer fatalities compared to eight during the same period last year.
  • California led all states with eight officer fatalities; followed by Florida, New York, Texas and Virginia each with four peace officer fatalities.

The Application of Platforms to Prevent Child Pornography

July 21, 2014 Comments off

The Application of Platforms to Prevent Child Pornography (PDF)
Source: International Journal of Scientific & Engineering Research

The advancement of information and communication technology specifically the Internet has used by many people especially young people to facilitate their daily life activities, for instance, e-learning. Through e-learning facility, some abuse it by involving into the business of pornography. This paper tries to explore the application of platforms, whether can prevent child pornography over the capturing end user technique, dilemma international child pornography law, imposing severe punishment, education and public awareness raising with respect to the Theory of Planned Behavioral (TPB). The survey shows that in the behavioral belief’s factor scored low correlations. However, the education and public awareness raising, blocking and filtering platforms and harmonization of the dilemma international child pornography law showed a slight high scored value. This indicates that, not only blocking, filtering platforms, education, public awareness raising, and harmonization of the dilemma international child pornography law can prevent child pornography but also imposing severe punishment and capturing end user technique can prevent child pornography with the make use of Theory of Planned Behavioral (TPB).

State Government Indigent Defense Expenditures, FY 2008–2012

July 21, 2014 Comments off

State Government Indigent Defense Expenditures, FY 2008–2012
Source: Bureau of Justice Statistics

Provides data on state government indigent defense expenditures for fiscal years 2008 through 2012. Trends in spending and comparisons with total state government judicial-legal expenditures are also included. The report uses administrative data from the U.S. Census Bureau’s Government Finance Survey. This is a companion report to the Census Bureau’s report, Indigent Defense Services in the United States, FY 2008-2012.

Highlights:

  • In 2012, state governments spent $2.2 billion nationally on indigent defense, the lowest amount spent during the 5-year period from 2008 to 2012.
  • State government indigent defense expenditures showed an average annual decrease of 1.1% from 2008 to 2012.
  • From 2011 to 2012, state government indigent defense expenditures decreased by $45 million nationally (down 2.0%).
  • As a share of total judicial-legal expenditures by state governments, spending on indigent defense held steady between 9.5% and 10.0% from 2008 to 2012.

Cyber Risks: The Growing Threat (III – updated)

July 21, 2014 Comments off

Cyber Risks: The Growing Threat
Source: Insurance Information Institute

Amid a rising number of high profile mega data breaches—most recently at eBay, Target and Neiman Marcus—government is stepping up its scrutiny of cyber security. This is leading to increased calls for legislation and regulation, placing the burden on companies to demonstrate that the information provided by customers and clients is properly safeguarded online.

Despite the fact that cyber risks and cyber security are widely acknowledged to be a serious threat, many companies today still do not purchase cyber risk insurance. However, this is changing. Recent legal developments underscore the fact that reliance on traditional insurance policies is not enough, as companies face growing liabilities in this fast-evolving area.

Specialist cyber insurance policies have been developed by insurers to help businesses and individuals protect themselves from the cyber threat. Market intelligence suggests that the types of specialized cyber coverage being offered by insurers are expanding in response to this fast-growing market need.

There is also growing evidence that in the wake of the Target data breach and other high profile breaches, the number of policies is increasing, and that insurance has a key role to play as companies and individuals look to better manage and reduce their potential financial losses from cyber risks in future.

Information Exposed: Historical Examination of Data Breaches in New York State

July 21, 2014 Comments off

Information Exposed: Historical Examination of Data Breaches in New York State (PDF)
Source: New York State Attorney General
From press release:

Attorney General Eric T. Schneiderman today issued a new report examining the growing number, complexity, and costs of data breaches in the New York State. Using information provided to the Attorney General’s Office pursuant to the New York State Information Security Breach & Notification Act, the report, titled “Information Exposed: Historical Examination of Data Security in New York State, analyzes eight years of security breach data and how it has impacted New Yorkers.

The report reveals that the number of reported data security breaches in New York more than tripled between 2006 and 2013. In that same period, 22.8 million personal records of New Yorkers have been exposed in nearly 5,000 data breaches, which have cost the public and private sectors in New York upward of $1.37 billion in 2013. In addition, the report also found that hacking intrusions – in which third parties gain unauthorized access to data stored on a computer system – were the leading cause of data security breaches, accounting for roughly 40 percent of all breaches. Attorney General Schneiderman’s report also presents new recommendations on steps that both organizations and consumers can take to protect themselves from data loss.

CRS — Unaccompanied Alien Children: Potential Factors Contributing to Recent Immigration

July 21, 2014 Comments off

Unaccompanied Alien Children: Potential Factors Contributing to Recent Immigration (PDF)
Source: Congressional Research Service (via U.S. State Department Foreign Press Center)

Since FY2008, the growth in the number of unaccompanied alien children (UAC) from Mexico, El Salvador, Guatemala, and Honduras seeking to enter the United States has increased substantially. Total unaccompanied child apprehensions increased from about 8,000 in FY2008 to 52,000 in the first 8 ½ months of FY2014. Since 2012, children from El Salvador, Guatemala, and Honduras (Central America’s “northern triangle”) account for almost all of this increase. Apprehension trends for these three countries are similar and diverge sharply from those for Mexican children. Unaccompanied child migrants’ motives for migrating to the United States are often multifaceted and difficult to measure analytically.

Four recent out-migration-related factors distinguishing northern triangle Central American countries are high violent crime rates, poor economic conditions fueled by relatively low economic growth rates, high rates of poverty, and the presence of transnational gangs.

CRS — Unaccompanied Alien Children – Legal Issues: Answers to Frequently Asked Questions

July 21, 2014 Comments off

Unaccompanied Alien Children – Legal Issues: Answers to Frequently Asked Questions (PDF)
Source: Congressional Research Service (via U.S. State Department Foreign Press Center)

Recent reports about the increasing number of alien minors apprehended at the U.S. border without a parent or legal guardian have prompted numerous questions about so-called unaccompanied alien children (UACs). Some of these questions pertain to the numbers of children involved, their reasons for coming to the United States, and current and potential responses of the federal government and other entities to their arrival. Other questions concern the interpretation and interplay of various federal statutes and regulations, administrative and judicial decisions, and settlement agreements pertaining to alien minors. This report addresses the latter questions, providing general and relatively brief answers to 14 frequently asked questions regarding UACs.

Impact of San Francisco’s Toy Ordinance on Restaurants and Children’s Food Purchases, 2011–2012

July 21, 2014 Comments off

Impact of San Francisco’s Toy Ordinance on Restaurants and Children’s Food Purchases, 2011–2012
Source: Preventing Chronic Disease (CDC)

Introduction
In 2011, San Francisco passed the first citywide ordinance to improve the nutritional standards of children’s meals sold at restaurants by preventing the giving away of free toys or other incentives with meals unless nutritional criteria were met. This study examined the impact of the Healthy Food Incentives Ordinance at ordinance-affected restaurants on restaurant response (eg, toy-distribution practices, change in children’s menus), and the energy and nutrient content of all orders and children’s-meal–only orders purchased for children aged 0 through 12 years.

Methods
Restaurant responses were examined from January 2010 through March 2012. Parent–caregiver/child dyads (n = 762) who were restaurant customers were surveyed at 2 points before and 1 seasonally matched point after ordinance enactment at Chain A and B restaurants (n = 30) in 2011 and 2012.

Results
Both restaurant chains responded to the ordinance by selling toys separately from children’s meals, but neither changed their menus to meet ordinance-specified nutrition criteria. Among children for whom children’s meals were purchased, significant decreases in kilocalories, sodium, and fat per order were likely due to changes in children’s side dishes and beverages at Chain A.

Conclusion
Although the changes at Chain A did not appear to be directly in response to the ordinance, the transition to a more healthful beverage and default side dish was consistent with the intent of the ordinance. Study results underscore the importance of policy wording, support the concept that more healthful defaults may be a powerful approach for improving dietary intake, and suggest that public policies may contribute to positive restaurant changes.

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